Memo from the Massachusetts Department of Public Utilities Chairman, Paul Hibbard, to the ISO New England. Chairman Hibbard expresses his concerns over the push to regionalize costs for building expensive transmission lines to service renewable projects (wind) built far from load centers. Current FERC rules are unclear on how to justify distribution of the costs across all ratepayers within the region unless it can be shown such transmission is needed to ensure the reliability and integrity of the grid.

In July 2007, the New Hampshire Site Evaluation Committee (SEC) permitted, with conditions, the Lempster Wind LLC project owned by Iberdrola. The project will consist of twelve 2 MW Gamesa turbines along five miles of access roads. Iberdrola is now shopping around its neighbor agreement to non-participating landowners asking them to waive noise protections the SEC conditioned in the permit, among other protections. Iberdrola's agreement can be downloaded from the link below.

These public comments were filed with the New Hampshire Site Evaluation Committee in reference to the Lempster Wind proposal (NH SEC Docket 2006-01 - Lempster, NH). Ms. Martin's comments were prepared following interviews she had with residents living near the Mars Hill, Maine commerical wind project. The Mars Hill wind project went on line in early 2007; problems of noise were reported as early as December 2006.

This document includes studies in Maine, Maryland, Minnesota, New Hampshire, New York, Pennsylvania, Vermont, Virginia and West Virginia.

Why did you petition to become an intervenor in this matter before the NH SEC?

With New Hampshire’s recent reinstatement of PILOT agreements and legislative efforts to a Renewable Portfolio Standard, the regulatory groundwork is being laid for more wind facilities to enter the state. Yet, New Hampshire, like many states, has no consistent regulatory process in place for reviewing these projects to ensure our environmental, societal, and economic interests are protected. The work the NH SEC has agreed to undertake in reviewing this application is precedent setting. How the committee approaches its review and the weight it places on arguments presented by all sides will impact other developments in the State as pertains to renewable energy projects.

There are a multitude of conflicting issues at play when considering any wind project. My commitment to this process is to help provide, to the best of my ability, valuable and timely information that will assist the Committee in making an informed decision on this application.

Below are two Phase I Avian Risk Assessments reports, prepared by Paul Kerlinger, for Vermont's East Haven Wind Farm (July 2003) and New Hampshire's Lempster Mountain Wind Power Project (June 2005). Phase I assessments have proven inadequate in assessing mortality at several sites in the U.S. including Mountaineer in West Virginia and Meyersdale in Pennsylvania. The US Fish and Wildlife Interim Wind/Wildlife Guidelines calls for multi-year evaluation of avian and bat activity using remote sensing.

Starting with our first interagency meeting on April 8, 2005, we have generally discussed three broad categories of activities that pose a potential concern for fish and wildlife resources. These include the potential for bird and bat collisions with turbines, habitat fragmentation effects on wildlife and impacts to waters/wetlands. At the April 8, 2005 interagency meeting, we recommended that CEI collect three (3) years of radar data on spring and fall bird/bat migrations to document the spatial and temporal use of the airspace by these flying vertebrates. Three years of radar data should be sufficient to gather information on the spatial and temporal distribution of birds in the airspace, including the year-to-year variability in migration patterns at this site, and represent our normal request for these data at wind projects. We have consistently requested that this data be collected at our meetings and field visits and continue to make this request for radar information.

Renewable energy sources have disadvantages as well as advantages, however. Although their costs have decreased in recent years, many renewables are still more costly than traditional sources. Some are also available only intermittently; for example, wind can be variable and hydroelectric is seasonal. And while many people are in favor of renewables in principle, many are also unhappy when faced with the prospect of a windmill or a trash-burning power plant in their neighborhood. These facilities face the same siting and investment difficulties that any electrical facility would, as the developers of a proposed wind farm off the coast of Cape Cod have discovered in recent years.