RE: Petition of Cape Wind Associates for a Certificate of Environmental Impact and Public Interest 

Ian A. Bowles, Chairman
Executive Office of Energy & Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Petition of Cape Wind Associates, LLC for a Certificate of Environmental Impact and Public Interest, pursuant to G.L. c. 164, § 69K, with respect to jurisdictional facilities approved by the Siting Board in EFSB 02-2. EFSB07-8.

Dear Chairman Bowles:

Thank you for your consideration of this evidence [link below] that defines Cape Wind as a proposed public safety hazard in the location of Nantucket Sound.

Please deny Cape Wind’s request for a composite certificate as the Public Interest cannot be met by this project that is predicted to be “lethal” according to Barnstable Municipal Airport officials.

National Air Traffic Controllers’ Cape T RACON, in their letter regarding Cape Wind to USACE, states:

“The evidence of endangerment to all who travel by air sea over and upon Nantucket Sound is compelling.”

Most Respectfully,
~~~
Barbara Durkin
48 Moore Lane
Northboro, MA 01532

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Ian A. Bowles, Chairman
Executive Office of Energy & Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Petition of Cape Wind Associates, LLC for a Certificate of Environmental Impact and Public Interest, pursuant to G.L. c. 164, § 69K, with respect to jurisdictional facilities approved by the Siting Board in EFSB 02-2. EFSB07-8.

Dear Chairman Bowles:

Whereas, the Energy Facilities Siting Board is charged with ensuring a reliable energy supply for the Commonwealth, with a minimum impact on the environment at the lowest possible cost, M.G.L. c. 164, §69H, I offer these comments for your thoughtful consideration.

Please return Cape Wind to the Cape Cod Commission by denial of their request for a composite certificate. Cape Wind should be compelled to meet the Minimum Performance Standards as a Development of Regional Impact under review by the Cape Cod Commission. Cape Wind has failed to meet the Cape Cod Commission Minimum Performance Standards. There should be no “life line” that allows Cape Wind to circumvent local authority that provides protection to citizens and the environment of Cape Cod and the islands’, where the adverse impacts of this project will be concentrated.

Cape Wind will, at minimum, produce unreliable energy at upwards of twice the current price of energy as evidenced, in part, in this summary review.

The source of the information I provide is attributable to the very industry that would be better served if wind turbine manufacturers’ remained silent. Vestas, the world’s largest turbine manufacturer CEO and President Ditlev Engle, has announced Vestas’ return to the less risky and expensive onshore market, and offered his considered professional opinion regarding Cape Wind.

Vestas’ chief’s response when asked by Boston Globe reporter, Erin Ailworth, about Cape Wind as reported in the Boston Globe on 9/21/08:

“And, therefore, I am really wondering why anybody wants to put them up offshore because it’s twice the price. So just as an outsider, I am just scratching my head saying, “Why?”

If the industry views offshore wind as too expensive and too risky—so should we. The wind industry is calling for a return to shore as offshore wind energy is cost prohibitive and high risk.

The good news is that we have advance warning about the high costs and lacking viability of problematic offshore wind energy. I ask that our Planners soberly evaluate this information that confirms that offshore wind energy does not provide a reliable or affordable source of wind energy—as confirmed by the wind industry.

I ask you to first consider providing adequate protection to the citizens and the environment. Whereas citizens are at imminent risk by Cape Wind, I urge your utmost circumspection, and considered review my contribution, ‘Cape Wind Poses a Threat to Public Safety’.

The lacking viability of offshore wind energy is secondary to the assurance to the public of our safety that the experts inform us is threatened by Cape Wind. There should be no decision made on the Cape Wind project permit review by EFSB that conflicts with NEPA assurance to the public of our safety.

To ignore navigation and air traffic experts’ testimony of record offered in the review process of Cape Wind is to fail to provide adequate protection to citizens and the environment. Compelling evidence exists that Cape Wind would present a public safety hazard. Therefore; only prudent determination, in the Public Interest, is for EFSB to deny Cape Wind ‘s permit appeal and application–as this industrial scale wind facility is predicted to imperil citizens, air travelers and ferry passengers.

I consider the following information to be moot with respect to the unacceptable threat to public safety that Cape Wind represents. However; market conditions are becoming increasingly unfavorable for offshore wind as reported by wind industry top executives. The hostile marine environment is far more challenging than industry experts had anticipated.

Cape Wind, under review by 17 agencies, over a period of 7 years, has no manufacturing source for their wind turbines. The GE 3.6 MW wind turbine that Cape Wind has represented they will use, and the Coast Guard and FAA are analyzing, specifically, is “discontinued”.

We are very fortunate to have advance warning about the lacking viability and the and the high cost of offshore wind energy. I ask that our Planners soberly evaluate this information that confirms that offshore wind energy does not provide a reliable, viable or affordable source of energy. As such, Cape Wind as proposed for Nantucket Sound would not exist in the Public Interest.

Please note that studies, Reports, and news articles cited are available in full by links provided below each.

Most Respectfully,
~~~
Barbara Durkin
48 Moore Lane
Northboro, MA 01532
Telephone: (508) 612-4133

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Ian A. Bowles, Chairman
Executive Office of Energy & Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Petition of Cape Wind Associates, LLC for a Certificate of Environmental Impact and Public Interest, pursuant to G.L. c. 164, § 69K, with respect to jurisdictional facilities approved by the Siting Board in EFSB 02-2. EFSB07-8.

Dear Chairman Bowles:

Whereas, the Energy Facilities Siting Board is charged with ensuring a reliable energy supply for the Commonwealth, with a minimum impact on the environment at the lowest possible cost, M.G.L. c. 164, §69H, I offer these comments for your thoughtful consideration.

MMS Cape Wind draft EIS consultant states:

“Given the estimated COST OF ENERGY IS $122/MWh, TWICE THAT OF THE CURRENT MARKET AND THIS IS AFTER THE FULL BENEFIT OF TAX AND RPS INCENTIVES, the prospects of entering a long-term purchase power contract would seem low.”

David G. Tuerck, executive director of the Beacon Hill Institute, addressed Cape Wind subsidies:

“What we found was quite remarkable. Cape Wind stands to receive subsidies worth $731 million, or 77 percent of the cost of installing the project and 48 percent of the revenues it would generate.”

Cape Wind cost is insufficiently addressed in this project state and federal permit review process. Citizens are exposed financially by decision makers tolerance of a “net, net, net, net cost review approach” and lacking transparency where Cape Wind’s financial model is concerned. If this economic profile of Cape Wind represented the Public Interest, it wouldn’t require repeated requests of representatives of the public to acquire.

MMS projects twice the current market price energy would be produced by Cape Wind and that’s compelling evidence that Cape Wind does not meet the Public Interest.

The public would also subsidize 77% of this project’s construction costs.

The bar is clearly too low from the Public Interest perspective with Cape Wind.

Taxpayers and ratepayers would be additionally burdened by Cape Wind added costs:

> the cost for project and performance bonding

> upgrades to existing infrastructure

> upgrades to transmission lines

> the very expensive operation and maintenance contract O&M

Public debt would be enlarged with Cape Wind predicted by BHL to:

> result in lost revenues that the Beacon Hill Institute calculated as:

> reduction in employment of 1173-2533 jobs

> reduction in tourist spending of $57 million to $123 million

> related drop in output of $94 million to $203 million and a drop in earnings of $28 million to $61 million

> loss in property values of $1.35 billion

> lost revenues by Cape Wind of up to $13 million

[“Massachusetts Fishermen’s Partnership and the University of Rhode Island estimates that the negative impact to commercial mobile gear fishermen alone would be between $8 million and $13 million depending on access to the site over the life of the project.”]

“The Massachusetts Marine Trades Association has shown that the Massachusetts recreational marine economy is one of the most vibrant marine economies in the country. It’s not difficult to see why. With nearly 1500 miles of coastline, 27,000 miles of inland waters and roughly 1260 marine trade businesses and individuals, Massachusetts recreational boaters account for almost 15% of the spending on recreational boating in the U.S. and generate nearly $1.5 billion dollars.”

The benefits of Cape Wind extend to the developer, and the adverse impacts and associated costs and risks would be borne by the citizens and the environment.

We need adequate protection of citizens and the environment by consideration and focus on the Public Interest over a private developer’s interest by EFSB. Cape Wind would produce cost prohibitive and unreliable energy, so clearly this project does not serve the Public Interest. There are no demonstrable benefits that exceed predicted adverse impacts by Cape Wind.

It is disconcerting that the ESFB appears to rest its favor for Cape Wind based on the obsolete LaCapra report. There should be no determination that Cape Wind would produce reliable energy at the lowest cost in today’s marketplace as evidenced by supporting documentation.

Cape Wind should be required to produce the complete history of the wind speed data collected by the Cape Wind data tower. This information is required to determine the cost of Cape Wind energy. Cape Wind has selected days, or cherry picked wind speed data, when full history provides a more accurate picture of project economic viability, from the taxpayers’ and ratepayers’ perspectives.

Offshore wind installations are identified by industry experts as twice as costly as onshore. Some of the evidence I provide does not distinguish offshore or contrast costs between on and offshore. The rule of thumb of the wind industry is that offshore wind energy is twice as expensive as onshore wind energy. Wind energy is then exponentially more costly and less reliable than other sources of energy.

I ask that the EFSB not take any action that would grant rights or advantage to Cape Wind that would supercede and diminish the rights of others’ who are dependent upon Nantucket Sound, in exchange for twice current, net, net, net, energy prices.

Most respectfully,
~~~
Barbara Durkin
48 Moore Lane
Northboro, MA 01532
Telephone: (508) 612-4133