Potential Visibility Map and Letter to PSB 

May 4, 2010
Dear Mr. Volz, Mr. Burke, and Mr. Coen, Vermont Public Service Board:

The potential visibility map (attached) provided by Green Mountain Power (GMP) for the Kingdom Community Wind (KCW) project in Lowell in their 45 day letter of intent is inadequate as a tool to help communities understand the scope and impact of the proposed project. On the surface it would appear to be an attempt to intentionally misinform by minimizing the potential visibility and impact on the region.

The calculations represented by the map use the hub height of 287 feet, eliminating the 156 foot long blades (34% of the total height). How is this acceptable to determine impact? Why is the hub height in meters? Since when do we use meters to convey measurement? Again, this appears to be a deliberate attempt to minimize the size of the turbines. Are the nacelles being considered or only a tower with nothing on it? Using only the tower completely eliminates the entire 312 foot diameter of the rotor blades, the bus size nacelle (31.85 ft L × 12.7 ft W × 13.2 ft H), and the nose cone (11.88 ft D × 13.86 ft W × 14.52 ft L). The human eye is drawn to moving objects making the nacelle/nose cone/blades assembly the most visible element.

The swept area of each turbine’s blades is 76,415 sq ft or 1.75 acres. The 24 turbines will have a total potential visible area of 42 vertical acres. Why isn’t this visual impact captured in the mapping … or anywhere in the letter of intent? If GMP says they can’t do potential visibility simulations for moving objects then they should have to provide them for all elements as if they were stationary.

Why should GMP limit the potential view on their map to ten miles when the turbines and the lights on them will be visible beyond that distance? Notice is required to be given to all “ten mile towns.” This does not mean that GMP is entitled to limit the potential view to ten miles. If this is the logic then the map should include the potential view from all points in the ten mile towns.

The met tower is visible from areas that the potential visibility map indicates there is no potential view of the proposed turbines. How can this be acceptable?

The small print includes: “Forested areas are assumed to have no visibility due to intervening vegetative cover” and is calculated at 40 feet. This is specious posturing given the high percentage of deciduous trees in the view shed and that they have NO leaves for more than half the year. Trees and vegetation also have the potential to be cut down revealing a view of the turbines.

GMP’s submitted potential visibility map has no credibility, even with the variables that have to be account for. In its present form the map is not useful to help communities assess impact – which is the purpose of the map. The content and methodology of this mapping is another example of how the developers are trying to mask the impact from these machines.

We the undersigned ask the Board to:

• not allow GMP to file for a CPG until a more accurate map is made available;
• require that GMP provide a more accurate map that includes:
• all potential view points in the 10 mile towns instead of within a 10 mile radius
• assumes visibility for at least 50% of forested areas
• indicates distance from which beacon lights will be visible on a clear night.

Thank you for you attention to our concerns.

Sincerely,
Residents of Lowell and ‘Ten Mile Towns’