Tom Hewson's Testimony re. East Haven

I was asked to review the prefiled testimony and exhibits of Matthew Rubin for the East Haven Windfarm and to provide an independent opinion regarding the claimed environmental benefits, estimated benefit values, project footprint and noise impacts and general wind project economic issues.

Prefiled Testimony Opposing East Haven Windfarm

Thomas A. Hewson
1. Q. Please state your name, current occupation and work address.

A. My name is Thomas A Hewson Jr. Since its inception in 1981, I have been a principal at Energy Ventures Analysis Inc (EVA), an energy consulting firm located at 1901 North Moore Street in Arlington Virginia. At EVA, I am responsible for electric utility modeling and environmental analysis for electric utilities, fuel suppliers, transporters, financial investors, governmental regulators and industrial trade organizations. I closely track electric generation options, their performance, costs and applicable governmental regulations (existing and proposed). I have authored numerous electric utility studies and provided testimony on the power industry to state legislatures, Congress and public utility commission hearings.

2. Q. Please state your qualifications.

A. I received a BSE in Civil Engineering from Princeton University in 1976.

While renewable energy has only a small share of current US electric generation, it has accounted for a growing share of my consulting work. My projects cover the full range of renewable power technology options—hydroelectric, biomass, geothermal, wind and solar. Some selected renewable projects include:

· Provide periodic biomass price forecasts and analysis for the Vermont Department of Public Service (EVA also provides DPS forecasts for fossil fuels as well).

· Project future renewable energy capacity and energy generation as part of the semi-annual Fuelcast forecasts for subscribers that include major electric utilities, fuel suppliers and transporters.

· Developed listings of existing and likely new wind projects for the Department of Energy’s Energy Information Administration.

· Provided evaluations of proposed impacts of renewable energy portfolio standard legislation/regulation for several states— California, Colorado, Illinois, Maryland, Michigan, Minnesota, Montana, New York, Texas and Washington.

· Evaluated cost and issues associated with several Congressional proposals to establish a National renewable portfolio standard for 2 major electric utilities.

· Panelist for open public forums dealing with wind energy issues in Michigan, Vermont and Ontario.

· Assessed economic and environmental issues of individual wind power projects proposed in the states of Maine, Massachusetts, Michigan, New York, Vermont and Wisconsin for public interest groups. These evaluations looked into issues such as wind resource quality, power production costs, transmission, noise aesthetics and environmental impacts.

· Examined the cost, performance and permitting issues of renewable power options (including wind) for the National Rural Electric Cooperative Association.

· I have done some noise modeling of both wind projects and other industrial projects for private clients. Between 1976 and 1981 I was employed as a project manager at Energy and Environmental Analysis where I was responsible for environmental and regulatory analysis. Examined, for governmental and industrial clients, the requirements and associated impacts on current industrial practices of the Clean Water Act, Clean Air Act, Resource Conservation and Recovery Act, Toxic Substances Control Act, Safe Drinking Water Act, Fuel Use Act, Natural Gas Act, Natural Gas Policy Act, Surface Mining and Reclamation Act and Occupational Safety and Health Act. Results of these policy, economic and technical analyses have been used for Congressional hearings, EPA rulemaking, court testimony, industrial policies, administrative hearings and permit negotiations. I also developed Federal and state regulatory compliance strategies for the Department of Energy and several industrial clients. Please see Exhibit KCG TAH-4.

3. Q. Please describe the assignment you were given by the Kingdom Commons Group.

A. I was asked to review the prefiled testimony and exhibits of Matthew Rubin for the East Haven Windfarm and to provide an independent opinion regarding the claimed environmental benefits, estimated benefit values, project footprint and noise impacts and general wind project economic issues.

4. Q. How did you complete this task?

A. I first reviewed the prefiled testimony and exhibits submitted by the applicants. I also used public information from the Department of Energy, American Wind Association, Evolution Markets, Cantor Fitzgerald, vendor literature, Vermont Agency of Natural Resources Wind Power Working Group, and other wind project websites.
5. Q. What does your testimony cover?

A. Based upon my analysis and research and using my expertise and experience I reached the following conclusions:

· Environmental benefit claims are directly proportional to the net power output—the greater the project output, the greater the potential net displaced power from conventional sources and the greater the avoided emissions. My analysis compares the East Haven Windfarm’s projected power output to the performance of 137 existing windfarms operating in the US. This comparison found that the projected East Haven output performance (36.7%) is far above the national average wind project capacity factor (26.9% in 2003), new wind project capacity factors (26.7% in 2003) and the Searsburg project capacity factor (20.3% in 2003). It is also much greater than published performance of the two New England municipal wind projects in Hull (26.2% average lifetime capacity factor through November 2004) and Princeton (21.4% capacity factor in 2004). East Haven’s claim of performance which will be 70% superior to Searsburg is not supportable even taking account of differences in wind resources or improved turbine technology. It is my conclusion that East Haven’s power output (and claimed environmental benefits) are not supported and are likely too optimistic and overstated.

· Matthew Rubin’s prefiled testimony claims that the project would avoid air emissions from a large gas combined cycle plant and would have a net environmental externality value of $7.86/MWh or $152,000 per year (pg 30). Of this calculated benefit, $7.39/MWh or 94% was associated with the avoided CO2 emissions. My testimony discusses Mr. Rubin’s inappropriate use of outdated externality values to calculate the project’s environmental benefits. Using Mr. Rubin’s avoided emission rates but applying current emission market trading values, the East Haven Windfarm’s avoided emissions benefit is much smaller and would likely be only $0.07/MWh (without CO2) and $0.71/MWh (w/CO2). In total, the avoided emissions benefit would likely be roughly $10,000/year or less.

· Wind projects create a land use challenge because of their large effected area and their high visibility for a small net energy output. My testimony compares the relative land requirements for wind and other generation technology alternatives to show that wind is the most land intensive power generating option. For example in 2003 the Millstone nuclear plant had a nearly 40 percent greater power output than the entire 2003 US wind energy generation even though it occupies less than 600 acres of land. The total U.S. wind energy capacity generation requires the use of more than 300 square miles.

· Wind supplies only 0.3 percent of the nation’s electric power. This is primarily due to its high production costs and its dependence upon tax incentives, renewable power portfolio standards and public funding subsidies.

· The noise from the wind turbine operation will likely be perceptible above the background noise for 1.6 to 3.2 miles away from the project site.

In summary, the alleged environmental benefits from the operation of four wind turbines on East Haven Mountain are marginal and would provide no public health benefit.

Project Power Output Assessment

6. Q. Why is power output important in calculating a project’s environmental benefits?

A. Since a wind turbine has no air emissions, any energy it can displace from conventional fossil powerplant sources can reduce air emissions. Environmental benefits from avoided emissions would therefore be related to the net power output and the particular power plant whose output was curtailed when the wind power was available.Hypothetically, the greater the wind project output, the greater the amount of power is displaced from conventional generating sources and the greater the amount of emissions that can be avoided from this power displacement. Therefore, the project power output is one of the most important elements in calculating a project’s environmental benefit.

7. Q. What was the claimed power output from the proposed East Haven Windfarm?

A. On page 7 of Matthew Rubin’s November 2003 prefiled testimony, the East Haven Windfarm’s net output from its four proposed turbines was estimated to be 19,300 MWh per year. This net amount is reported to be after accounting for energy losses from blade icing/fouling (8%), cold temperature shutdowns (1%), turbine availability (3%), array losses (3.7%) and high wind factors (1%) and additional adjustments for electrical losses (3%) and uncertainty (5%). Given these deductions, the project’s gross generation projection before losses must have been calculated to be roughly 24,600 MWh.

Given the proposed East Haven Windfarm has a capacity of 6 MW, the developer’s 19,300 MWh estimate translates to a net average capacity factor of 36.7 percent. The gross project capacity factor before losses was equivalent to 46.8percent.

8. Q. Were you able to re-create this power output estimate from the information contained in the February 19, 2004 East Haven Windfarm Discovery Response?

A. No, I was not. Neither the over 15,000 hours of raw wind monitoring data nor the model used to convert the wind measurements into gross power output were contained in the materials I was provided and I was advised that East Haven Windfarm refused to provide such information. The Discovery Response did contain some preliminary AWS model runs (MR04, MR27, MR28, MR29), some limited mean wind speed data (MR05) and a September 19, 2003 draft report entitled, “Estimation of the Long Term Average Wind Speed and Energy Production at the Proposed East Mountain Wind Project Site” (MR30). The draft report, with its hand written corrections, did not differ in any material way from the final report (EHWF-MR-4). These documents contained some preliminary output estimates that did not match Matthew Rubin’s subsequent pre-filed testimony.

9. Q. Without the wind monitoring data, how did you evaluate the project’s 19,300 MWh output claim?

A. Average capacity factor can be used to measure the relative operating performance between wind projects. My first step was to compare their projected 36.7 percent annual capacity factor to actual capacity factors reported by 137 existing windfarms to the US Department of Energy.

10. Q. How does the East Haven projected performance compare to the national average?

A. KCG-TAH-1 contains the annual reported generation output for 137 US windfarms that submit data to the US Department of Energy. Of these projects, 64 reported only partial year generation due to start-up, equipment problems or lost data so adjustments were made to calculate their performance only for months that they provided generation data. The remaining 73 projects had data for the full year of operation.As is shown inKCG-TAH-1, the East Haven Windfarm’s predicted net average capacity factor (36.7 percent) is far above the national average wind project capacity factor (26.9 percent in 2003), post 2001 wind project capacity factor (26.7 percent in 2003) and Vermont’s Searsburg project capacity factor (20.3 percent in 2003). It is also above the web-posted capacity factors of the two municipal wind projects at Hull MA (26.2 percent lifetime capacity factor through November 2004) and Princeton MA (21.4 percent for 2002).

Only six of the reporting 137 projects were able to achieve a 36.7 percent capacity factor or more over a full year. Another six projects reported only partial year data that showed a better than 36.7 percent capacity factor for the months they reported. Not one of these high performing projects was located in the Eastern US.
Based upon this comparison, the East Haven proposed project performance claim would place it among the top 10 percent of all US wind projects and a 70 percent better performance than the Searsburg project in Vermont achieved in 2003.

11. Q. Do you see any evidence to support the claim that the East Haven Windfarm could achieve a 70 percent better performance than Searsburg did in 2003?

A. No, I did not. To have such an improved performance, a project must have superior site wind conditions and/or a vastly improved turbine design. Neither of these factors are sufficiently present in the East Haven Windfarm proposal to support a 70 percent improvement. The data suggest that East Haven may achieve performance a little better than Searsburg attributable to its later turbine design but that their shared icing and harsh weather conditions would likely adversely affect the project’s overall performance.

First, my comparison of site wind conditions was unable to support the large differential performance between Searsburg at 20.3 percent and the claimed 36.7 percent for East Haven Windfarm. Both Searsburg and the proposed East Haven projects would be located along the Green Mountain Range. According to the New England Wind Map (http:/, the Searsburg area appears to have average annual wind speeds of between 8.5 to 9.8 m/s at heights of 50 meters (KCG-TAH-2). These average wind conditions near Searsburg exceed the 8.36 m/s annual average wind speed at East Mountain at a height of 65 meters reported in Matthew Rubin’s testimony (pg 6). These data suggest that the wind resources at East Haven are not superior to Searsburg’s and cannot justify the assumption that East Haven would peform substantially better than Searsburg based uponaverage wind speed.

Second I compared the turbine designs. Searsburg has an earlier turbine design with a somewhat different power output profile (% rated capacity vs. wind speed) than the proposed GE 1.5 MW turbine at East Haven. However, these power profile differences from improved blade design and materials cannot support a 70 percent better performance. As my earlier comparison found, the newer wind farms, which would tend to use the more advanced designs proposed for East Haven Windfarm, actually had a lower average capacity factor than the earlier wind projects. While some of this difference may simply reflect that the newer projects were placed in poorer windqualityareas than the older projects, it does demonstrate that turbine design changes between Searsburg and East Haven Windfarm are unable to justify a substantial 70 percent improved performance claim.

12. Q. Are the reasons contributing to Searsburg’s sub-par performance (vs national averages) also applicable to the East Haven project?

A. Yes. Searsburg was a demonstration project to evaluate wind turbine performance at higher elevations where problems such as icing and equipment failures attributable to harsh colder temperatures are more prevalent. These problems still remain with the newer turbine designs and are also applicable to the East Haven Windfarm site that is located at an even higher elevation (summit at 3,400 feet) where icing problems would be an even greater problem than Searsburg. The current East Haven Windfarm calculation reduces output by 9 percent for icing and cold temperature problems. However, the AWS Scientific report “Estimation of the Long Term Average Wind Speed and Energy Production at the Proposed East Mountain Wind Project Site” (EHWF- MR-4) containing the loss estimates state that “Precise site specific losses due to icing are difficult to estimate at this time.” One of the test towers used by AWS for its study of the local wind conditions in the East Haven area was reported to have lost 25 percent of the data during its 6 month operation (January-June 2003) due mostly to ice accumulation. EHWF-MR-4. Based upon the observed overall performance at Searsburg and the East Haven’s location at an even higher elevation where icing would be even more prevalent, assuming greater losses from harsh weather conditions are likely justified in the AWS capacity factor calculations for the East Haven Windfarm.
There may be other factors that ultimately affect the capacity factor for East Haven Windfarm that have not yet been considered by Mr. Rubin. For example, because the immediately adjacent property is subject to an extensive conservation easement with broad rights for unrestricted public access (KCG-WJ-22), restrictions could be imposed by law on the time when the East Haven turbines are allowed to operate in order to protect users of the adjacent land from the danger of ice throws. In responding to discovery requests (EHWF Response to KCG Document Production Request 25 (MR23) Mr. Rubin admits that ice thrown from the turbines could travel as far as 650 feet. That extends beyond the property line of the East Haven Windfarm (see EHWF-MR-2). Any additional operation restrictions would further reduce the annual turbine output.

13. Q. Based upon the data that you have reviewed, what will be a likely range in the East Haven capacity factor?

A. Although with the newer GE 1.5 MW design East Haven could likely exceed the Searsburg 2003 capacity factor (20.3 percent) I see no support for the assumption that it could reach anywhere close to the claimed 36.7 percent. Even though I have been denied access to the monitoring data to build my own alternative estimate, I find no basis to support the assumption that East Haven Windfarm would perform better in the harsh climate of East Haven mountain than the average for similar turbines most of which operate in a less harsh environment. It is my judgment that it is highly unlikely that the East Haven Windfarm would have a capacity factor any greater than the mid to upper 20’s, comparable to the national average for all wind projects and newer wind projects. If Mr. Rubin’s estimate of emission benefits is only corrected to reduce his overstated capacity factor to a defensible number, it would reduce the claimed environmental benefit by 20-25 percent.

Avoided Emissions Benefit

14. Q. Will one megawatt hour from a wind turbine displace one megawatt hour from a conventional fossil power plant?

A. Highly unlikely. A complex network system dispatch model is required to correctly calculate the differential generation impact and to account for the differences in transmission losses and ancillary support services. Neither myself nor Mr Rubin have done this work but I suspect that one megawatt hour from the wind turbine will backout slightly less than one megawatt hour from a conventional power plant. If my suspicions are correct, this would further reduce both the projected avoided emissions and environmental benefits.

15. Q. Matthew Rubin’s prefiled testimony claims that his wind project would displace air emissions from a large gas combined cycle plant. Do you agree?

A. A complex network system dispatch model is required to correctly calculate the type of generation that would be displaced by a wind project. Neither Mr Rubin Nor myself have done this analysis. However, based upon my work on New England powerpool and prior studies done by the New England Independent System Operator, I believe the assumed new gas combined cycle plant emission rates used by East Haven Windfarm is within a reasonable range.

16. Q. Matthew Rubin’s prefiled testimony (pg 30) claims that the project’s avoided air emissions would have a net environmental benefit value of $7.86/MWh. Do you agree with his estimate?

A. Definitely not. I believe that he has vastly overestimated the avoided emissions value by using outdated environmental externality values instead of current emission allowance market trading values. One could purchase emission credits and avoid the same level of emissions for between $0.07 and $0.71/MWh, a fraction of the East Haven claimed value of $7.86/MWh. These values were calculated applying Mr. Rubin’s gas combined cycle emission rates and the posted December 1,2004 emission trading values from United Power Incorporated (SO2, NOx) and the Chicago Climate Exchange (CO2). These values are shown in KCG-TAH-3.

EHWF-MR-20 calculations show that their avoided emissions benefit is dominated by the avoided carbon dioxide emission value of $7.39/MWh or 94 percent of the East Haven’s total claimed environmental benefit. To develop this value, East Haven applies an environmental externality value of $19/ton CO2. This approach to carbon dioxide emission avoidance value has several serious flaws. First, carbon dioxide is currently not considered a pollutant and is not regulated under either Federal or Vermont State law. Until either Vermont or the Federal government pass new legislation, there will be no economic value assigned to reducing carbon dioxide emission levels and its true market value would be zero. Under current Vermont law, the value of CO2 emission reductions is zero and the EHWF claimed emission value would be lowered by $7.39/MWh to just $0.47/MWh.

However, some states and industries believe that CO2 should be regulated. States such as New Hampshire and Massachusetts have adopted regulations to control CO2 emissions from existing powerplants and many have placed an externality value on CO2 on evaluating their new resource decisions. In Massachusetts, the state requires a new power generators to obtain CO2 offsets or pay the state $1/ton CO2 to fund carbon control projects for their projected emissions. In other cases, utilities have elected to voluntarily support carbon sink projects (forestation, ocean fertilization) or energy efficiency improvement projects at costs less than $2.00/ton CO2 reduced. Finally, several major industries have formed the Chicago Climate Exchange that sets carbon reduction requirements for members and established the first domestic CO2 trading system. As of November 2004, the posted trading values in the Chicago Climate Exchange program were $1.64/ton CO2. In short, the current domestic trading program CO2 values generally range from $1.00-$1.64/ton. Assuming the Chicago Climate Exchange value of $1.64/ton, utilities could purchase CO2 offsets for $0.63/MWh that is far less than the assumed East Haven CO2 avoided emission value of $7.37/MWh.

The remaining pollutant values are far less but also tend to overstate market values. Any person or organization can purchase the NOx and SO2 emission reduction credits today on the open emissions trading market that are equivalent to the displaced power emissions at a cost of $0.07/MWh. This is less than half of East Haven’s assumed value using outdated externality values for SO2 and NOx of $0.17/MWh.

Rubin assigned a value of $0.29/MWh for the other pollutants (CO, PM-10, and UHC). Since these pollutants require sources to meet strict emission limitations without trading, there is no emission trading market or values for them. Given that most areas are in attainment with PM-10 and CO, further reducing these emissions would have no measurable public health benefit or value. As such, their externality value should be near zero.

In summary, I believe that using current market trading values to quantify emission values is far more accurate than using the externality values adopted by Mr. Rubin. One could purchase the equivalent CO2, NOx and SO2 emission reduction credits in the open market for only $0.07-0.71/MWh. Using these differences alone would reduce Mr Rubin’s claimed emission value by 91 to 99 percent.

17. Q. Matthew Rubin’s prefiled testimony (pg 30) claims that the project’s avoided air emissions would have a total environmental benefit value of $152,000/year. Do you agree with his estimate?

A. No. As I mentioned earlier, Mr Rubin’s estimate of $152,000/year is calculated using an overly optimistic generation level (19,300 MWh) and an outdated avoided emission value ($7.86/MWh).

As shown in KCG-TAH-3, my estimate using a more reasonable estimated generation level (14,200 MWh) and emission market trading values ($0.07-0.71/MWh) would range from $1,000 (no CO2 value) to $10,000/year (with CO2 value).

Land Use

18. Q. How does East Haven Windfarm affect land use for Vermont as compared to alternative means for generating 6MW of power approximately 25% of the time?

A. First, East Haven creates a land use challenge because of its location atop the East Mountain ridgeline, that makes it highly visible across a large area. Vermont enacted Act 250 to specifically control land development along the ridgelines and protect its mountain vistas. Given the height and location of the turbines, the project will change the horizon profile and local mountain vistas that Act 250 was passed to protect. State regulators must weigh the project’s visual impact against the unit’s minimal power contribution.Second, wind projects can be highly controversial since they effect a large area in order to access higher quality winds, to maintain a sufficient cleared spacing between turbines to avoid downwind turbulence that diminishes performance and to be located sufficiently far away from local residents to avoid adverse health and safety impacts (noise, turbine failures, ice throws, shadow flicker, etc¼). This large “footprint” for wind projects is far greater per unit capacity and per unit output than more conventional power generation alternatives. In summary, the wind turbine effects will extend far beyond the project’s 17 acres of land that it owns at the summit.

Finally, the high quality wind resources are generally located in remote areas that require additional transmission linesto hook into the existing transmission network. For East Haven, more than 12 miles of new 34.5 kV electric transmission lines will be required to interconnect with the existing Burke Mountain substation.

19. Q. What minimum spacing is recommended to avoid inter-turbine turbulence effects?

A. The actual spacing depends upon the wind characteristics. The American Wind Energy Association has a general rule of thumb that a wind developer will need 40 acres of cleared space for each 1.5 MW turbine. This spacing requirement will increase to as much as 75 acres per turbine with the much larger turbine designs underdevelopment. By placing a turbine near the summit, this spacing rule of thumb would translate into a minimum of 750 feet spacing between turbines. For the East Haven project, the turbines will be spaced at 900 feet apart (pg 8 Matthew Rubin profile testimony).

This “affected” area is much greater than solar power where in the Southwest a solar project requires roughly 4 acres per MW of capacity. It is also far greater than conventional alternatives. For example, the Millstone nuclear plant in Connecticut had a nearly 40 percent greater power output than the entire 2003 US wind industry combined but used less than 600 acres. To displace the energy from New England’s smallest utility coal unit (Somerset) wouldrequire167 turbines (of the size proposed for East Haven) and would cover 22 miles of mountain ridgeline.

Wind Powers Contribution

20. Q. How many commercial wind projects are currently in operation in Vermont?

A. I am aware of only one existing operating commercial wind project in Vermont—the 6 MW project in Searsburg Vermont. I understand that some limited smaller wind turbines also exist for personal use within the state.

21. Q. What proportion of Vermont’s current energy is supplied by wind projects?A. The Searsburgproject supplied 10,829 MWh in 2003. Given Vermont’s 2003 estimated retail power sales of 5,665,000 MWh (DOE Electric Power Monthly- March 2004), the Searsburg project would represent 0.2 percent of the state power sales. Nationally, wind generation’s 2003 market share of generation was about 0.3 percent.

22. Q. Why does wind have such a small existing power market share?

A. The single greatest reason has been its historic high cost. Simply put, wind projects are very expensive to build, provide only an intermittent and highly variable power and operate at relatively low capacity factors (20-35%). For example, the East Haven project costs were estimated to be $10 million or $1,667/kW. These capital costs aremuch greater than the cost of building a new gas combined cycle plant ($500-600/kW) or a new clean coal plant ($1,100-1,500/kW) that can supply power at up to its rated capacity whenever required.

Since wind supplies only intermittent power, its power purchasers have been unable to credit any of the wind project’s rated capacity towards their minimum reserve capacity requirements needed to assure a reliable power supply. As a result, wind purchases did not avoid or delay the buyers need to build or purchase new power capacity to meet their growing load requirements. Wind projects supplied only energy not capacity. Wind could not saveanycapital or other fixed costs for new generating capacity. Wind could avoid only a displaced unit’s variable cost.

Finally, wind’s transmission costs were much higher. Its remote location required new transmission facilities to be built and its variability led to poor utilization of transmission capacity and the need for more ancillary services.

Vermont’s small wind market share reflects that Vermont has pursued its lowest cost alternatives first. In fact, the Searsburg project was built as a demonstration project with significant outside funding by the US government and the Electric Power Research Institute. If not for it being a heavily subsidized demonstration project, it may not have been built at all.

23. Q. Is there any economic justification to build the East Haven Wind Farm?

A. Not to society as a whole. However, Mr. Rubin can take advantage of several governmental programs that heavily subsidize wind projects to help offset their high cost by shifting some cost burden and risks from the investor to the taxpayer and ratepayer. For example, the US Congress recently extended the Federal Production tax credit. This federal tax credit is set at $18/MWh (escalated for inflation) for the first 10 years of power production from a wind project placed online prior to December 31, 2005. This tax credit is greater than the energy costs for nuclear, hydro and some coal-fired facilities. In addition, other incentives are provided such as the accelerated depreciation (5 years vs. 30 years for most conventional alternatives) and renewable portfolio standards that dictate a minimum percentage of power supplies must come from qualifying renewable resources. Massachusetts has a renewable portfolio standard that requires a percentage of power sales comes from new renewable facilities. According to Evolution Markets’ November publication, the Massachusetts Renewable Energy Credits are selling for $46/MWh for 2005 production and $39.50/MWh for 2006 production. Once certified by Massachusetts as a qualifying new renewable energy project, Mr. Rubin will be able to sell renewable credits for the entire East Haven Windfarm outputto Massachusetts utility ratepayers. The combined state and federal subsidies are often greater than the wholesale cost of power in New England.

The bottom line is that while the wind production costs are not competitive versus conventional power sources, heavy subsidies by the US taxpayer and Massachusetts ratepayer will allow Mr. Rubin to pursue a high cost power alternative.


24. Q. Have you looked at the issue of potential noise from the proposed East Haven Windfarm?

A. Yes.

25. Q. What work did you undertake?

A. I reviewed Mr. Rubin’s prefiled testimony regarding the level of noise expected to be created by operation of the East Haven Windfarm and his calculation of the noise levels, measured in dBA, at various points. I also examined testimony prepared by Mr. Kenneth Kaliski who conducted noise measurements in a rural area near Sheffield, Vermont, which is located in the Northeast Kingdom about 10 miles west and south of East Haven. Thistestimony is reported in the Environmental Board decision entitled In Re: Barre Granite Quarries, LLC, L.U.P. 7C1079 (Revised)-EB (December 8, 2000.) I have assumed that rural area, where several people live and a quarry was in operation, is no less quiet than I would expect to find in the conservation area adjacent to and down mountain from the proposed East Haven Windfarm.

26. Q. How did you use the information which you reviewed?

A. I chose to rely on Mr. Rubin’s calculations of the level of noise expected to be generated by the Windfarm turbines during operation and accepted his calculation of the level of noise, measured in dBA. I also accepted the background noise levels found by Mr. Kaliski in his analysis in Sheffield, Vermont. Anthony Roger’s paper entitled, “Wind Turbine Noise Issues” provided some wind turbine noise characterization data. I then used my own experience with noise generated by wind turbines and with analyses of the quantity and quality of that noise to reach conclusions regarding the likely impact the noise from the proposed Windfarm will have on persons using the adjacent conserved land.

27. Q. What did you conclude about the difference in noise level which persons using the conserved landswill experience if the Windfarm is in operation?

A. First, one must define the background noise level in the East Haven area. I am unaware of any noise studies conducted by Mr. Rubin that measured the current background noise levels and therefore relied on an earlier study by Mr. Kaliski in nearby Sheffield Vermont. Mr Kaliski reports that the ambient background level in Sheffield Vermont range from 20.5 to 27 dB(A). This level is characteristic of many remote rural areas.

Next, one must determine at what level the wind farm turbine would become noticeable to people in the nearby area. According to Dr Anthony Rogers paper, a 3 dB change in sound level is considered a barely discernable differenceto the human ear. However, a change of 5 dB will result in a noticeable community response. This threshold would suggest that people located in areas in which the East Haven wind turbine noise levels exceeded 25.5 to 32 dB(A) could hear the turbines.

According to Mr. Rubin’s prefiled testimony, these perceptible project noise levels would occur up to 1.6 to 3.2 miles away from the turbine site under his modeling assumptions. This affected area extends far into the adjacent conserved lands that are open to the public. The public within this area would likely hear the turbine operations. The level would increase as one goes closer to the turbine site. At roughly 500 feet from the turbines, the levels wouldreach 55 dBA and begin to interfere with conversational speech.

Animals with their keener hearing would be aware of the wind project from much further away.

28. Q. What did you conclude about the difference in the quality of the noise which these persons will experience if the Windfarm is in operation?

A. Noise has been an issue in the siting of wind turbines. Four types of noise are generated by wind turbines—tonal (meshing gears), broadband (swishing), low frequency and impulsive (thumping). The wind turbine noise will be both mechanical (from the gearbox and generator being transmitted along the turbine structure) and aerodynamic noise (from the air flow over the blades). This noise, coming from the elevated turbines and blades, will be distinctly different from the background noise and will occur continuously during turbine operation. Many communities have setback requirements for wind turbines that are set to minimize noise problems.

29. Q. Does this conclude your testimony?
A. Yes.


JAN 1 2005
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