June 1, 2009

Rebuttal of NRCM’s misguided support of RHW

Mr. Voohees,
I have read with dismay your ill informed comments to the DEP regarding wind power in general and Record Hill Wind LLC in particular.  It is clear that your organization has transformed from a force for the protection of Maine’s precious natural resources to a force for the destruction of Maine’s mountains in the name of some hoped for future benefit based on the politically and industrially influenced, and poorly understood science known as Climate Change.
It would be very helpful,  I believe, if your organization was upfront about its apparent revised mission statement,  and stated in clear terms exactly what Maine has to fear from climate change,  what known forces, both natural and man made contribute to it and to what degree,  what knowledge gaps exist which prevent our understanding of the climate,   and how over 1000 wind turbines on Maine’s mountains will make a difference that is worth the sacrifice of not only the ridges, but the peaceful existence of communities below them,  the wildlife that will be killed by the turbines or forced to flee habitat nearby because of turbine noise,  the watershed and groundwater degradation that is sure to occur as a result of blasting, filling and roadbuilding in fragile mountain ecosystems, the economic loss to our tourism based economy, to name just a few.

I hope you have had a chance to review my report on the flawed noise model that RSE is using in Maine.  Perhaps you would be interested in revising your support for RHW LLC knowing that they have misrepresented the noise levels of the turbines to the same degree that was done at Mars Hill,  Stetson II and Rollins.  There is no excuse for their failure to use line source modeling and the application of the required 5 dB  penalty for the notorious “blade thump” that is the cause of so many turbine noise complaints world wide. 
The Roxbury Pond community enjoys dead quiet nighttime sound levels in the 20 dB range as stated in the Maine’s technical assistance bulletin #4 Noise, (which is an excellent document for any community interested in controlling the noise of intrusive land uses.)   Turbine noise, if properly predicted, can be expected to exceed Maine’s nighttime limits at many protected locations.  As you should be aware, nighttime noise levels 10 dB above background are found to be objectionable to almost 100% of the population, and will cause sleep disturbance and the cascade of physical and mental problems that follow in unknown numbers of citizens.  No community in Maine should be subjected to this type of abuse. 

If you read the analysis I sent you about the criteria by which Maine’s Finest lakes were identified,  as they apply to Roxbury Pond,  you will understand that Roxbury Pond has equal value to Tumbledown as an asset of statewide significance and that the visual impact of the turbines at only one mile from this magnificent body of water will be unduly adverse for the numerous recreational users of this lake, who come not to marvel at the world’s tallest industrial machines, but to revel in the pristine beauty of this place.   Certainly you are aware that the quantity of tourists visiting a pond is not a criteria by which Maine’s Finest lakes were judged.  Many of the ponds on the list are remote and see relatively minimal human activity.
Attached is an article you may have missed about Roxbury Pond, written by Michael Perry, former director of the LL Bean Outdoor.  His accurate description of the viewshed from Roxbury Pond leaves nothing more to be said about the necessity of protecting it.
Your defense of turbines, that they will not cause genocide among species (except perhaps bats),  ignores the threat they pose to loons and eagles at Roxbury Pond.   Giant Cuisinearts in the sky over Flathead Mountain will most certainly emperil the bald eagles of French Island,  a threatened species that has maintained a rookery here for 25 years.  Their use of the thermals on Flathead Mt,  and their frequent foraging trips over the ridge to the Swift River  when the pond is frozen will put them in harms ways countless times.  One of those times will be the last.  The Record Hill Wind DEP application is silent about loons, as you were in your proclamation of support.   Loons need long distances across the water to achieve flight.  It is entirely possible that the loons of Roxbury Pond will not reach a safe altitude when they migrate or fly to other nearby ponds to fish,  nor will they be conditioned to avoid the spinning blades of the turbines and know to avoid them.

To summarize your mathmatical justification for wind turbines,  2000 MW of installed capacity will have a capacity factor, at 25%, of only 500 MW.  The ISO NE grid operates at a daily demand of about 20,000 MW and has total generation capacity of about 33,000 MW.   So Maine’s turbines will contribute,  erratically and unreliably,  about 4% of the daily demand of the grid.  During periods of high demand during hot summer days,  wind power will typically be unavailable and will contribute nothing.  How can you make any statement about significant reductions in GHG emissions or coal consumption when Maine’s windplants will contribute such an insignificant amount of the grid’s demand. 
Please don’t insult our intelligence with your “wind power will supply the electricity needs of all the homes in Oxford County” wind industry propaganda.  Without a wholesale buyer for their electricity,  a fossil fuel generator forced to buy Renewable Energy Credits, and the giant net of subsidies and now stimulus fund loan guarantees that prop up the wind industry,  this industry could not, and would not exist.  If any homes in Oxford County or elsewhere depended on the electricity from Record Hill Wind they would be in the dark 75% of the time and the rest of the time they would be experiencing constant voltage fluctuation.
2000 MW of 2 MW wind turbines spaced approximately 1000 feet apart will require nearly 200 miles of ridge line, not including the roads to the ridge tops.  Who is going to enforce your call for strict standards of compliance?  You know what happened at Kibby last fall.  The state is ill prepared to monitor compliance,  monitor the work of 3rd party compliance people,  or see that stop work orders are issued when called for, or obeyed when issued.  There is already a huge compliance problem in Maine from poorly enforced forrestry standards.  Your call for responsible construction and maintenance practices will have no teeth even if such conditions are included in permits.
Finally your support for this project,  without knowledge of when or if the necessary transmission infrastructure will be available,  and without knowledge of the environmental and community impacts associated with wider rights of way,  or taller towers,  is irresponsible. Without transmission capacity this project does not have title, right, and interest to proceed.  The cost associated with any transmission line work must be calculated in the cost of the project.  By my estimates Record Hill Wind LLC will spend over $100 per MW to generate electricity over the 20 year life of the project.   The cost of transmission lines could add $10 per MW to this cost.  Electricity sells for less than $40 per MW in the day ahead ISO NE market,  and less in the longer term markets.  How can you possibly justify $60 to $70 per MW in subsidized costs during a recession when rate payers and tax payers are already suffering from job losses and reduced business activity?
Your support for the project, as you were quoted by Terry Karkos in the Sun Journal article, extends to the support for the free electricity offer which has yet to be negotiated.  Offering free electricity to Roxbury only encourages more energy consumption, not less.  Offering long term employment to Roxbury and surrounding towns in weatherization programs, or offering “Kill a Watt” electricity monitoring devices would be far more cost effective and beneficial to the community than merely encouraging the use of free electricty,   which will no doubt lead to the purchase of inefficient 110 volt space heaters, etc.   The free electricity deal was nothing more than a bribe to get Roxbury voters to agree to change their zoning ordinance to the language required by King and Gardiner.  Ironically, the change they required was only a slight change in the definitions in the ordinance.  Since rural Roxbury does not permit industrial uses, the ordinance was merely footnoted to say that 400 foot tall, 120 ton, noisy, animal killing, people sickening wind turbines,  the largest machines currently manufactured on this planet,  are simply not considered to be “an industrial use.”

I would appreciate a more timely response than the last time.  We are planning a statewide media campaign urging a boycott of NRCM.  Your group no longer represents the interests of those of us who appreciate the value of Maine’s revered mountains, or common sense approaches to fossil fuel reductions.

Sincerely,
Steve Thurston

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