Resource Documents: Wisconsin (72 items)
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Author: Amstadt, James; Kuehne, Carl; Meyer, Tom; Schwalbach, Glen
In 2009, Wisconsin Act 40 directed the Public Service Commission of Wisconsin (Commission or PSC) to appoint a Wind Siting Council (Council or WSC) to provide advice to the PSC during the rule- making process for the siting of wind turbines. Act 40 also requires that Council to submit a report to the Legislature every 5 years to provide updated information about health research and regulatory developments, as well as to provide recommendations for legislation if needed.
Act 40 specifies the makeup of the membership of the Wind Siting Council and it created a bias in the form of a majority made up of several pro-wind energy interests and pro-wind environmentalists versus a minority of others who would focus on safety and health. Because of that built-in pro-wind bias, the Council’s minority created this Minority Report to reveal the information that the Council majority omitted from the Wind Siting Council report to the Legislature.
The pro-wind bias, as found on the Wind Siting Council, is found on the PSC staff as well. One reason for the PSC’s bias is that it seems they deem that the statute for Renewable Portfolio Standards requires them to “go easy” on safety and health restrictions for wind energy projects. This bias has created wind siting rules in Wisconsin that are not as protective as they should be. Wisconsin’s wind siting law and rules (PSC 128) require local units of government to process applications for all but the largest wind projects. These wind projects are extremely complicated and are often unique to the local land features. But local governments are not allowed to consider safety and health protections that are more restrictive than PSC 128. So, they cannot require protections to suit the local circumstances, to adopt the recommendations of their medical or technical experts or engineers, to accommodate the latest science, or to require the latest protective technologies. Wisconsin law and PSC 128 require local government units to approve these wind projects with noise restrictions and setbacks that the Council’s current regulatory review would consider to be some of the least protective in the country.
This Minority Report highlights areas in PSC 128 that differ from health standards and best practices found in the documents reviewed by the Council for the Majority Report, differences that were downplayed by the pro-wind Council majority. These health standards and best practices are designed to protect non-participating homeowners’ health and property rights. These best practices strike a balance between protecting residents and creating a regulatory environment that the wind industry can use to get approvals that work for both the industry and the communities where they are built.
Because Wisconsin’s wind siting law is so dysfunctional, wind turbine development plans are met with great opposition by the communities where they are proposed. The communities that object are aware of the health concerns that are described in the Minority Report. Wind turbine noise is linked to chronic sleep disturbance, which is linked to more serious physical maladies. Wisconsin law does not allow setbacks that adequately prevent harmful noise impacts to homeowners. Officials are not permitted to set wind turbine setbacks any farther than an arbitrary 1250-foot or 3.1 times the total height, whichever is less, from a neighbor’s occupied structure.
The Council’s regulatory review also found that, because Wisconsin’s setback is from a wind turbine to a neighbor’s occupied structure, some of that neighbor’s land is now inside the “safety setback” distance from the wind turbine. This “safety setback” can overlap as much as 800 feet of that neighbor’s property. This is a “taking” of the owner’s property right to use their land for intended purposes because it is no longer possible to build with local building setbacks near their property line and stay outside of the “safety setback” due to a turbine being located nearby. In other states there is a trend to create setbacks a safe distance from the neighbor’s property line instead of the neighbor’s structure.
A significant study done by a member of the Council showed that the towns in which wind projects have been built in Wisconsin have population densities generally much higher than towns or townships in neighboring states where similar projects have been built. Couple this with the fact that the wind resource in Wisconsin is much less than in these neighboring states, and it is like forcing a square peg into a round hole, whereby there is likely to be some severe damage. Wisconsin’s existing wind projects have been permitted in our more populated areas, and thus, are more often too close to residences with more resultant negative health impacts than in other states.
This Council minority concludes that Wisconsin’s wind siting law needs revision for noise protection and property rights protection. Also, a restructuring of the Wind Siting Council makeup is needed to eliminate bias, as is a restructuring of what information the Council is allowed to review in order to advise the Legislature about wind energy systems. Rewriting the wind siting laws to offer better protections for non-participating residents and correcting the bias of the Wind Sting Council will restore the public trust in the wind-siting laws of Wisconsin, creating a win-win situation for both the wind industry and non-participating residents.
To proceed wisely, the minority, the majority and numerous technical and public policy experts agree that more acoustic and epidemiological studies are needed. Wisconsin wind projects are ripe for such studies before more damage is done, but government funding is needed.
Also, Wisconsin needs a process to compensate those citizens who had to abandon their homes to get relief from negative health effects, who have not moved and suffer negative health effects, or who have taken a financial loss due to a neighboring wind project.
Prepared by Dr. James Amstadt, Carl Kuehne, Tom Meyer, and Glen Schwalbach, P.E.
Additionally signed onto by Mary Brandt and Tim Roehl
(As presented in Appendix F of the Wind Siting Council October 2014 Report)
Download original document: “Wisconsin Wind Siting Council – Minority Response”
Author: Lasee, Frank
This bill states that, in an action for damages caused by a wind energy system, the prevailing plaintiff may recover damages for his or her physical and emotional harm, compensation for loss of property value and for expenses incurred by the injured person if he or she moves as a result of harms caused by a wind energy system, and other damages. The bill allows a prevailing plaintiff to recover reasonable attorney fees. Under the bill, if a wind energy system is located within one and a half miles from the plaintiff’s residence, it is not a defense to the action to assert that the wind energy system was operating pursuant to an appropriate legal permit or local governmental approval.
The people of the state of Wisconsin, represented in senate and assembly, do enact as follows:
Section 1. 895.095 of the statutes is created to read:
895.095 Actions for damages caused by wind energy systems.
(1) In this section, “wind energy system” has the meaning given in s. 66.0403(1)(m).
(2) In an action for damages caused by a wind energy system, the court shall grant a prevailing plaintiff all of the following:
(a) Actual damages for physical and emotional harm suffered by the plaintiff, including for medical expenses, pain, and suffering.
(b) Compensation for loss of value to any property owned by the plaintiff that was caused by the proximity of the property to the wind energy system.
(c) Compensation for expenses incurred by the plaintiff for moving to another residence to escape the effects of the wind energy system.
(d) Any lost profits that are attributable to the proximity of the wind energy system to the plaintiff’s residence and that were not taken into account in determining the amount of actual damages under par. (a).
(e) Notwithstanding the limitations under s. 799.25 or 814.04, costs, disbursements, and reasonable attorney fees.
(3) If a wind energy system is located within 1.5 miles of the residence of a plaintiff in an action to recover damages caused by the wind energy system, it is not a defense to claim that the public service commission granted a certificate of public convenience and necessity for the wind energy system under s. 196.491 (3) or that an application for the wind energy system was approved under s. 66.0401(4).
2013 Wisconsin Senate Bill 167
April 30, 2013
Introduced by Senator Lasee, cosponsored by Representatives Thiesfeldt, Jacque, Bies and Schraa.
Referred to Committee on Judiciary and Labor.
Wednesday, November 20, 2013
Room 412 East in the State Capitol
Author: Schomer, Paul
Would you please state your name and address?
My name is Paul D. Schomer. My business address is 2117 Robert Drive, Champaign, Illinois 61821.
Have you previously provided testimony in this proceeding?
Yes. I evaluated the Highland application for noise level exceedances and testified on the probable adverse impacts to the health and safety of the Town of Forest residents. I also participated in the Shirley Wind infrasound study conducted in December 2012 to evaluate the cause of adverse health effects from the same or similar large wind turbines that are proposed in this docket.
What is the purpose for your testimony?
I intend to testify on the new proposal by Highland to mitigate its exceedance of the PSC 128 Nighttime Noise Standards of 45 dBA.
What materials have you reviewed?
In addition to the original application materials, exhibits, and testimony from the prior proceedings, I have now reviewed the testimony and exhibits of Tim Osterberg, Michael Hankard, JoAnne Blank, and Jesse Stowell with respect to their proposal to rely on proprietary software of the wind turbine manufacturers to curtail the violation of PSC 128 sound limits. I have also reviewed the recent filings from Mr. Hankard and Mr. Osterberg on the effect of a 40 dBA daytime sound limit and Highland’s assurances that all sound limits imposed will be met if the project is built.
Is curtailment a viable strategy to reduce power and sound for wind turbines?
Curtailment can be done on a limited, turbine-by-turbine basis for a variety of reasons such as reducing power during low demand periods, performing maintenance on the turbine, and responding to high wind events. Power reduction occurs by simply reducing the speed of the rotor through feathering the blades and spilling wind – much like a sailboat reduces speed by adjusting sails. Reducing rotor speed will tend to reduce sound levels, but there is no guarantee. Under some conditions, feathering the rotors to reduce rotor speed may actually increase sound levels.
To your knowledge has a wind farm ever been designed with a curtailment strategy in the United States?
No. Wind turbines and wind farms are designed to operate at maximum capacity. It makes little sense to invest in larger turbines and then reduce power output to comply with noise limit regulations. The solution to Highland’s design flaws is to use smaller turbines, which would allow the turbines to operate at full power as they were designed, and comply with all applicable noise regulations. Relying on untested software to predict when noise limits are being exceeded for a particular residence within a large wind farm, and expecting that the software will successfully reduce noise levels to maximum limits for each affected residence, is ludicrous.
Are you familiar with other methods employed to use curtailment as a mitigation strategy for wind turbines?
Yes. I consulted with Michael Hankard in his efforts to reduce noise from a 49-turbine wind farm to two “neighboring” residences in Oregon.
How does the Oregon project compare with the proposal now being made by Highland and Mr. Hankard here?
They are very different in scope and design. Mr. Hankard presented a paper on this subject to the Acoustical Society of America in Canada this year. His paper has been provided in his July 19, 2013 supplemental direct testimony as Ex.-HWF-Hankard-13 (PSC Ref. # 187658). One principal difference is that Mr. Hankard’s proposed solution was designed to mitigate violations of Oregon noise limits at two residences, rather than the far more extensive incorporation of a mitigation plan into the design of the wind farm. Additionally, the mitigation plan in Oregon involved obtaining real time noise data from noise monitors at each of the two residences, wind speed and direction at each of the noise monitors, and wind speed reported by the wind turbines at hub height. Software developed by Mr. Hankard used these various inputs to develop a real time protocol and procedure to initiate the mitigation plan. When conditions indicate that a curtailment is required, a warning is placed on the screen of the operator of the wind farm, who is located in Chicago, IL. Within 30 minutes of such warning, the ten turbines nearest to these two residences are being shut down.
Here, Highland is proposing to use the curtailment function built into each turbine to mitigate predicted noise violations to 30 residences produced by the cumulative noise of an entire wind farm. Highland’s mitigation plan would be on a trial and error basis, with no real time noise data at each affected residence. This proposal is infinitely more complex. Yet, Highland proposes to collect no real time data, and instead rely on proprietary turbine software rather than an operator to reduce power and noise to acceptable levels.
In your opinion, is Highland’s curtailment mitigation strategy in the public interest?
No, absolutely not. To permit this wind farm with mitigation as the principal means of protecting the public would not be in the public interest. The solution is to build the wind farm with smaller, quieter turbines that will run at maximum capacity without requiring curtailment. Highland is proposing a grand experiment with the Town residents as the guinea pigs. The proposed turbines are too big and emit too much noise energy. In the wake of the severe health impacts experienced by some residents in the Town of Glenmore, which has similarly large turbines, it is troubling that Highland refuses to consider a full redesign of this project.
Do you have any criticisms of the proposal suggested by Michael Hankard?
Yes. Mr. Hankard and I worked on a project in Oregon in which wind turbine noise exceeded the state noise limits at two “neighboring” residents. [There are only five houses within many miles of this wind farm. Two of the five houses are the two discussed above; two of the houses are not in violation of the Oregon regulation; and the fifth house is owned by the landowner who sold all the land for development of the wind farm. He uses this house for some of his farm help.] These wind turbines were just 1.5 MW, but the noise they produced was in excess of Oregon regulation.
In order to mitigate the noise problems with these turbines, Mr. Hankard developed a clever mitigation strategy to shut down the ten nearest turbines to these houses. The on-site data, which includes the acoustic levels, the wind speed and direction at each residence, and specific turbine operating parameters, are all transferred in real time to the central office in Chicago. There, software determines the conditions under which the sound is predicted to be too high, and issues a warning to the operator that he should initiate a shutdown of the ten turbines.
How does the curtailment mitigation strategy purposed by Mr. Hankard in the Highland farm differ from the system he created in Oregon?
The starkest difference is that the Highland curtailment proposal relies exclusively on automated programming of proprietary software. There is no ground truth of noise levels at each residence. As I understand it, the only data relied upon by the software would be from the wind speed anemometer on each turbine, which would then be programmed to reduce power output at 8 meters per second. There would be no ground truth, such as real time microphones collecting data, to determine whether the curtailment is effective at all residential facilities. Mr. Hankard does propose limited ground truth in three locations accumulating data sporadically. However, this is not nearly as effective as continuously accumulating data through all seasons and wind conditions. Additionally, none of these data are going directly to a wind farm operator that can immediately adjust the wind turbines to maintain acceptable noise levels.
Do you believe that Mr. Hankard’s suggestion of using curtailment as a strategy to bring Highland into conformance PSC 128 noise limits is in the public interest?
In my opinion, no. The current proposal simply tries to squeeze a square peg into a round hole. As I have testified previously, the wind turbines suggested in this proceeding are simply too large for the layout of the Project, producing too much noise.
Is the proposed mitigation plan workable?
Anything is possible, but the real question here is whether it is worth the long-term risk to area residents – who will have to live with this experiment for the next 30 years. Since there will be no real time noise data collected at each residence as the experiment unfolds, the burden will shift to the residents to prove that the noise limits are being exceeded. The problem is that the turbines proposed by Highland are too big, and their acoustic emission levels are too high, to meet current PSC regulations. Highland proposes a complex solution to a problem with a simple solution: the use of smaller turbines that produce less noise and require no curtailment.
Are you still concerned about the health impacts of large mega turbines such as those proposed in the Town of Forest?
Yes. There is significant evidence from all over the world that large turbines placed too close to residences cause very serious health problems. While the research is underway, there is continuing focus on balancing the size and output of wind turbines with public health. I do not believe that the right balance has yet been struck. The wind industry continues to claim that there is no known link between wind turbine noise and health effects.
In a recent paper, which is being submitted as Ex.-Forest-Schomer-20, I show that for a small group of specially selected people, the probability that motion sickness-like symptoms experienced by wind farm residents are unrelated to wind turbine noise is less than two in a million. This analysis proves that it is virtually certain that these individuals are adversely affected with serious health effects that result from the acoustic emission of nearby wind turbines. This changes the dynamic of the situation. Since it can no longer be said that there are no known health effects related to wind farms, it follows that the industry must prove that there will be no adverse health effects from what they plan to do, or that the industry must state what the adverse health effects will be.
Is there a sound scientific basis for imposing a 40 dBA noise limit for day and night, as proposed by the PSC, for the six homes that are identified as “sensitive”?
Yes. George and David Hessler have coauthored an article that recommended a noise limit of 40 dBA for wind farms, which has been shown to virtually eliminate noise related complaints and health problems. I have done independent work and concluded that 39 dBA should be the maximum limit to avoid annoyance and health impacts from wind turbine noise. A recent paper that George Hessler and I coauthored, which is being submitted as Ex.-Forest-Schomer-21, explains how we independently arrived at these limits of 40 and 39 dBA.
Where was your article presented?
It was presented at the Acoustical Society of America/International Congress of Acoustics that occurred in Montreal in June of 2013. Michael Hankard presented his paper in the same technical session at this conference.
Have some jurisdictions adopted the 39 or 40 dBA maximum limit?
Jurisdictions all over the world have adopted a wide range of limits. Europe and South Australia tend to have limits in the range of 35 dBA, sometimes even as low as 30 dB. On the other extreme, some jurisdictions have a limit of 55 dBA. George Hessler and I wrote this paper together because we thought it was important to show to the scientific community that we arrived at essentially the same answer, even though we used different methods and approaches to get there.
Did the Massachusetts wind turbine study, upon which the environmental assessment relied, support these noise limits?
Yes. It supported the same 40 dBA limit at night.
Have the Massachusetts study’s conclusions on adverse health effects from wind turbines held up to recent scrutiny?
No. In a paper to be presented and to be published in December 2013, which is being submitted as Ex.-Forest-Schomer-22, we show that the Massachusetts study’s conclusions about the lack of connection between human health and infrasound and wind turbine noise are flat out wrong.
Do you believe that a 40 dBA limit is needed to avoid adverse health effects from audible and infrasound?
Yes. All the experts in this proceeding agree that the louder the turbines are in audible noise and the larger the turbines are in structure, the more infrasound will be produced. The larger mega turbines seem to correlate very starkly with health impacts. It is significant that in a wind farm with only eight turbines, three families have left their homes in the Town of Glenmore. As I testified earlier, if this farm is built as designed, it is likely that the same result will occur – with or without curtailment.
Without ground truth to accurately measure sound levels at all locations, how would the wind turbine operator or the PSC be informed that noise limits are exceeded?
Without ground truth data, no one will know whether noise levels are exceeded. The burden of proof would shift to property owners to prove the cause of their problems.
What is your reaction to Mr. Hankard’s suggestion to use wind speed and direction to calculate the wind turbine noise emission levels?
To my knowledge, it has never been used anywhere for wind turbine noise assessment, and is completely untested in practical use. It introduces a new form of average levels where 50% or more could end up not meeting the limit – at least part of the time. The noise model used in this case, ISO 9613-2, already takes directionality into account by requiring a downwind prediction in all directions. Reducing predicted sound levels further with a directivity analysis makes any prediction model less conservative.
This proposal institutes averages that change with direction, but otherwise have the same effect as the averaging inherent in the use of impedance coefficients greater than 0,0,0 in ISO 9613-2. It recreates a situation where many residences exceed the limit for large percentages of the time. Also, this novel approach immeasurably complicates the noise impact analysis for each home. Not all the residences will have the same juxtaposition to the wind at any given wind speed and direction. When the wind shifts, these directivity analyses will change. Given the infinite number of variables concerning wind speed and direction, predicting noise levels at each residence will become very complex. Additionally, the conservative value of ISO 9613-2 always predicting the “downwind” solution will be lost if Mr. Hankard’s directivity analysis is adopted.
Does Mr. Hankard’s directivity analysis assure that the Highland mitigation curtailment plan will work?
No. Mr. Hankard’s statement that the radiation pattern of the wind turbines is a dipole is an over simplification and does not appear to be justified by his own data. For instance, Ex.-HWF-Hankard-9 (PSC Ref. # 186229) does little to support Mr. Hankard’s assertion that he can apply a directivity pattern without introducing significant new uncertainty. According to the data in Ex.-HWF-Hankard-9 (PSC Ref. # 186229), the most common “directivity” value for the first study listed is −3 dB, which occurs at 45°, 135°, 180°, and 270° with −4 dB at 90°. Yet the first study in Ex.-HWF-Hankard-9 (PSC Ref. # 186229) indicates virtually no change in sound with wind direction and does not support Mr. Hankard’s assertion. If any of the wind turbines in Forest operate in a similar fashion to Ex.-HWF-Hankard-9 (PSC Ref. # 186229), then the measured levels would be smaller than predicted. In contrast, if some of the turbines at Forest follow the second study presented in Ex.-HWF-Hankard-9 (PSC Ref. # 186229), then noise levels at two of the turbines would be under predicted by 1 dB. This directivity factor needs substantial research to demonstrate that it will not increase uncertainty and error. No persuasive data are shown that the individual turbines in the Town of Forest will instantaneously respond to wind direction and take on this pattern in all directions. The second study Mr. Hankard presents in Ex.-HWF-Hankard-9 (PSC Ref. # 186229) has directivity values of 0, 0, +1, and +1 dB at the 45°, 135°, 235°, and 315° angles to the wind. Mr. Hankard’s method would subtract 1 dB at each of 19 these directions, when according to the second study 1 dB should be added, yielding a net error of 2 dB. If this directivity pattern is so prevalent, and the wind turbine manufacturers want to report the loudest direction per IEC 61400-11, why does the IEC 61400-11 standard call for measurements in four directions instead of just one? This proposed change by Mr. Hankard makes no practical sense. Subtracting some generalized average can only introduce new error.
Does Mr. Hankard’s proposal to assess wind direction to determine sound levels at each residence assure that the problems encountered at Shirley will not be repeated?
No. While this directivity effect might reduce audible sound in some cases, infrasound flows in all directions and its amplitudes are not reduced by which direction the sound originates. Adverse health effects from infrasound will not be abated by directivity. This is another reason to stick with ISO 9613-2 and IEC 61400-11, each as is, and not venture into the unknown.
Mr. Hankard treats the inputs to and predictions from ISO 9613-2 as absolute maximum noise levels. Is this the case?
No, it is not the case. I have closely examined the data presented in Ex.-HWF- Hessler-3 (PSC Ref. # 172233) in this matter, which attempted to measure the accuracy of noise level predictions made by using ISO 9613-2. The Hessler data show that turbine noise tends to be louder at night. These data result from two weeks of continuous measurements at 1000 feet in three directions (north, south and east) from the east end of an east-west line of wind turbines in 10-minute intervals. Averaging the daytime data (7 AM to 10 PM) reveals values of 31, 30, and 30 dB for the three directions. During the night (11 PM to 5AM) the average noise levels increase by 6 dB to 37, 37, and 36 dB from the same three locations. This same “nighttime” effect is likely to occur in the Town of Forest. Although data collection of turbine noise levels during various times of the year would likely produce different average sound levels, the important point is that there is a significant increase in noise levels at night which is between 3 and 6 dB.
How does this relate to the requirement that nighttime levels not exceed 45 dBA?
What this means is that it would be misleading to use a 24 hour noise prediction for a wind farm to calculate the nighttime levels. The 24 hour prediction averages lower daytime levels with higher sound levels at night. The reality is that the night-only levels will be on the order of 3 dB louder than the 24 hour prediction.
How does all of this apply in the current matter?
This means that Highland must take into account the “nighttime” effect revealed in the Hessler data by developing mean values and standard deviations empirically in the Town of Forest area in sufficient quantity for the sources and receivers to generalize to the entire wind farm. In the alternative, Highland must assume a conservative stance by predicting that the effective nighttime emissions will be 4 dB greater than those currently stated.
Has Mr. Hankard adequately explained the procedure used to reduce the turbine noise levels to verify the reliability of his calculations?
No. Ex.-HWF-Hankard-11 (PSC Ref. # 186231) fails to include critical information necessary to understand its reliability. Ex.-HWF-Hankard-11 (PSC Ref. # 186231) shows turbine noise levels dropping by up to 6 dBA with no explanation of how the reductions were selected, how long they will be in effect and why these turbines were curtailed while others were not. Eight solution sets are reported to exist for the eight compass wind directions, north through northwest, but only one of the eight solution sets is given. Also it is stated that these eight solution sets are sufficient for all wind directions.
But, once again, no data are provided to substantiate this assertion. Further, the rate at which the solution set is changed is not explained. Is it updated once per second? Once per minute? Once per hour? What triggers a change? How long does a change take to effect? The unanswered questions are almost limitless. It is impossible to judge the veracity of a procedure when we are not told what the procedure is.
Are there issues with any of the other testimony?
Yes. Mr. Stowell testified that this mitigation scheme is not stable, and is therefore not suitable for the long term. Specifically, he reports that the curtailment scheme will slip in and out of compliance. A system that slips in and out of compliance is unsatisfactory.
Are bigger wind turbines better for people?
The history of wind turbines, as young as they are, is one of ever increasing size. Current units go from 1.5 to 3.5 MW, and bigger units can be expected in the future. Larger turbines may have the advantages of greater efficiency and net profit but they create more problems for people living close by. There is strong evidence that the very low infrasound frequencies produced by large wind turbines are the sources of acoustic emission that are adversely affecting people. As the power generated by wind turbines grows, the blades grow and hence the tip’s speed is reduced to avoid too high an advancing blade tip Mach number.
According to a paper by van den Berg (2004), which is being submitted as Ex.-Forest-Schomer-22, the increase due to a typical nighttime wind profile (the change in velocity with altitude) was 5 dB for a wind turbine with a 58 m hub height, and up to 15 dB for a turbine with a 98 m hub height. That is, the increase in low frequency energies in size and magnitude may be substantial because of this blade-loading, wind-gradient effect, much greater than what is predicted for constant blade loading. The conclusion is that unless mitigation methods and strategies can be developed and implemented, bigger turbines are not necessarily better. They may actually be much worse for people.
Have all your opinions been given to a reasonable degree of professional certainty? Yes Does this conclude your testimony?
OFFICIAL FILING BEFORE THE PUBLIC SERVICE COMMISSION OF WISCONSIN
Application of Highland Wind Farm, LLC, for a Certificate of Public Convenience and Necessity to Construct a 102.5 MW Wind Electric Generation Facility and Associated Electric Facilities, to be Located in the Towns of Forest and Cylon, St. Croix County, Wisconsin
Docket No. 2535-CE-100
Download original document: “Rehearing Direct Testimony of Paul D. Schomer”
Author: Schomer, Paul
The Town of Forest requested that we respond to the Supplemental Environmental Assessment’s conclusion of “no significant impact” to the environment based upon the recent Shirley Wind Farm study. It is my opinion that the Shirley Wind Study does show the need for an Environmental Impact Statement for the reasons outlined below …
In summary, the Shirley study added considerably to the knowledge base of why some people leave their homes when mega wind turbines are built nearby and requires an Environmental Impact Study to assess the costs and benefits of such a project. I give this opinion for the following reasons:
First, the Wind Industry has continually denied that wind turbines produce any LFN. This study showed that it does. At R-2 it was measured as clearly as if the turbine had left a fingerprint on the inside of the house.
Second, the Shirley study fully and completely corroborates Falmouth and fills the knowledge gap suggested by the MA study which was a literature review, not a hands-on field study. There is no reason to corroborate it again.
Third, the measurement of ultra low frequencies produced by mega turbines such as those at Shirley and proposed for Highland are the key to avoiding significant impacts to human health from wind turbines. As the Minnesota study concludes, the low frequencies must be studied further as part of the project planning. In the case of Forest, this study of the low frequency isopleths must be a part of an in-depth EIS, or the project must be redesigned with smaller turbines that are not likely to precipitate such severe health problems that people have no choice but to abandon their homes. These are precisely the studies that we recommended in our Shirley report and the EIS is a perfect way to obtain the information before the project is built.
Fourth, the record as a whole in this case as well as the literature and case studies all over the world have suggested that people are leaving their homes because they are being exposed to significant levels of pulsating ultra low frequency sound produced by wind turbines. In addition there is no question that larger turbines produce more infrasound below 1 hertz which increases the likelihood that health problems will occur unless noise limits are dramatically reduced through the use of smaller turbines or lower noise limits are required at each house. To conclude that the Highland project will have no significant impact to the human environment and that no further study is needed in the face of people leaving their homes on an identical project is wishful thinking and in my opinion will be proven to be wrong if the project is built as designed.
Paul Schomer, PhD, PE
Member; Board Certified, Institute of Noise Control
February 8, 2013
To: Kathleen J. Zuelsdorff
Environmental Analysis and Review Coordinator
Public Service Commission of Wisconsin
610 North Whitney Way
P.O. Box 7854
Madison, WI 53707-7854
Re: Application of Highland Wind Farm, LLC, for a Certificate of Public Convenience and Necessity to Construct a 102.5 Megawatt Wind Electric Generation Facility and Associated Electric Facilities, to be Located in the Towns of Forest and Cylon, St. Croix County, Wisconsin.
Docket No. 2535-CE-100; Supplemental Environmental Assessment
Download original document: “Shirley wind turbine noise study shows need for Environmental Impact Statement”