The following comments were submitted to the Department of Planning and Land Use in San Diego County California in opposition to Iberdrola-Tule Wind LLC's request for amendments to the County's General Plan, the local Community Plan, and to the existing and draft revised Wind Energy Ordinance. The comment letter was prepared by Attorney Stephan Walker on behalf of several grass-roots non-profit groups.

Rube Goldberg would admire the utter purity of the pretensions of wind technology in pursuit of a safer modern world, claiming to be saving the environment while wreaking havoc upon it. But even he might be astonished by the spin of wind industry spokesmen. Consider the comments made by the American Wind Industry Association.s Christina Real de Azua in the wake of the virtual nonperformance of California.s more than 13,000 wind turbines in mitigating the electricity crisis precipitated by last July.s .heat storm.. .You really don.t count on wind energy as capacity,. she said. .It is different from other technologies because it can.t be dispatched.. (84) The press reported her comments solemnly without question, without even a risible chortle. Because they perceive time to be running out on fossil fuels, and the lure of non-polluting wind power is so seductive, otherwise sensible people are promoting it at any cost, without investigating potential negative consequences-- and with no apparent knowledge of even recent environmental history or grid operations.

Eventually, the pedal of wishful thinking and political demagoguery will meet the renitent metal of reality in the form of the Second Law of Thermodynamics (85) and public resistance, as it has in Denmark and Germany. Ironically, support for industrial wind energy because of a desire for reductions in fossil-fueled power and their polluting emissions leads ineluctably to nuclear power, particularly under pressure of relentlessly increasing demand for reliable electricity. Environmentalists who demand dependable power generation at minimum environmental risk should take care about what they wish for, more aware that, with Rube Goldberg machines, the desired outcome is unlikely to be achieved. Subsidies given to industrial wind technology divert resources that could otherwise support effective measures, while uninformed rhetoric on its behalf distracts from the discourse.and political action-- necessary for achieving more enlightened policy.

The California Wind Energy Collaborative was tasked to look at barriers to new wind energy development in the state. Planning commissions in the state have developed setback standards to reduce the risk of damage or injury from fragments resulting from wind turbine rotor failures. These standards are usually based on overall turbine height. With the trend toward larger capacity, taller towers and longer blades, modern wind turbines can be "squeezed out" of parcels thus reducing the economic viability of new wind developments.

Current setback standards and their development are reviewed. The rotor failure probability is discussed and public domain statistics are reviewed. The available documentation shows rotor failure probability in the 1-in-1000 per turbine per year range. The analysis of the rotor fragment throw event is discussed in simplified terms. The range of the throw is highly dependent on the release velocity, which is a function of the turbine tip speed. The tip speed of wind turbines does not tend to increase with turbine size, thus offering possible relief to setback standards. Six analyses of rotor fragment risks were reviewed. The analyses do not particularly provide guidance for setbacks. Recommendations are made to use models from previous analyses for developing setbacks with an acceptable hazard probability.

Appendix B: Sample Local Government Requirements for Wind Energy Conversion Systems

Appendix B of The National Wind Coordinating Committees' handbook contains summaries of nine California County ordinances dealing with wind facilities.