Comments to Maine DEP 

Please accept my appreciation or your decision to deny the Bowers Mountain Industrial Wind Project. I would like to offer my comments and concerns, however, on some of the other conclusions stated in the report, not only for Bowers Mountain but also in the hopes that they may be germane to the analysis of other industrial wind projects now be considered for Maine.

This week’s statement by FERC Commissioner Phillip Moeller that wind project subsidies should be discontinued (http://www.power-eng.com/articles/2013/07/ferc-commissioner-wind-subsidies-must-go.html) is particularly relevant for Maine, where capricious wind patterns, long transmission distances, high construction costs and other factors make industrial wind even more of a failure than elsewhere. But if even some of these projects are approved they will turn their regions of Maine into industrial zones.

As we all know, industrial wind projects in Maine will not lower greenhouse gases and fossil fuel use, and may even increase them. However they will have catastrophic and irreversible impacts on many Maine resources including tourism, community stability and fiscal health, birds, bats and many other wildlife types, water quality, human health, property values and local tax revenues.

An additional problem is that people don’t want to live anywhere near or even visit areas with wind turbines. In a recently failed industrial wind project in Hawaii, the landowner backed out when their appraisers told them they would suffer a 75% property value loss in lands even several miles away. Tourism in the UK is down 43% in areas with industrial turbines.

The following comments are meant as summaries only of my concerns about some of the report:

Pursuant to 38 M.R.S.A.:

B. I am not sure what you mean by “unreasonable” erosion. The body of the report does not substantiate this. Many industrial wind projects show enormous and irreversible soil erosion problems due to their construction and sometimes their operation. In the steep, erosive topography of Bowers Mountain, how could this be possible? What is “unreasonable erosion”?

D. It has been proven that turbine curtailment does not reduce bird collision deaths. Because most turbines are sited on uplands to benefit from updrafts and ridgetop winds, bird deaths will continue until the species involved are locally eradicated or significantly diminished. Estimates of bird and bat deaths are substantially understated because:

1. Many dead birds and bats are taken by predators
2. Many dead birds and bats are missed in counting, which may be inconsistent in timing and location.
3. In nesting season, the death of one mate usually means the death of the nestling, as one parent cannot keep them alive.

What type of “final mortality monitoring methodology”? Shouldn’t these parameters be decided before embarking on this or any project?

Pursuant to 35 M.R.S.A.:

A. Financial capacity: I believe the financial capacity of First Wind is quite limited. If federal subsidies are removed this year, the company could have serious problems. According to The Financial Times, their former Italian Mafia partners are in jail and the wind projects confiscated in what is considered the largest Mafia bust in history. First Wind’s new Kahuku project in Hawaii has been shut down for over a year and may never run again, but First Wind refuses to repay the state and federal subsidies it received for the project. The fact that the developer is a LLC means simply that they can walk from the project whenever they want, and the parent company or investors cannot be touched.

C. What, again, is “unreasonable” soil erosion?

H. The finding on shadow flicker appears unreasonable based on current research.

I. The greatest safety hazard of the project on adjacent properties and property users would be its many significant noise impacts. The likelihood of forest fires resulting from turbine fires must also be more carefully and objectively analyzed.

J. The decommissioning plan is totally inadequate and misleading. The costs and difficulties will be much greater than those proposed. A recent report on Falmouth, Massachusetts being faced with a $14 million estimate to dismantle two 400-foot turbines provides a better guide to costs (http://m.npr.org/programs/all/3/184700636). And there will be additional environmental impacts involved in a project dismantling. But by this time the developer may well be long gone (a virtue of an LLC). Moreover, many bonds taken out by developers do not do well because the underlying assets are not reliable, and therefore the amount they provide may fall very short of decommissioning costs. It is for this reason and others that 14,000 abandoned turbine towers litter America’s landscape, as they soon will in Maine.

K. Tangible benefits are very poor, when compared with the eventual total cost of such a project on the local and regional economies. Hardest hit are tourism, property values, tax revenues, and even higher business costs due to the rate increases required to bring such projects onto the grid.

Based on my own years of experience in the energy business, and specifically in facility siting, electricity production, and social and environmental impacts, I feel that all of the presently proposed wind projects in Maine, and those underway or already completed, will be a permanent and useless blight, a financial drain, and a social and environmental nightmare for Maine.

Very best wishes. I hope you always will do what is best for Maine.

Sincerely,
~~~
Michael Bond
Winthrop

TO:  Commissioners and Department Members, Maine Department of Environmental Protection, Bureau of Land & Water Quality, Division of Land Resource Regulation; Attn: Jessica Damon, BowersWindProject.DEP@maine.gov