1. Assertions about the project’s public benefit
Noble Environmental makes assertions about the positive effects its product, wind-generated electricity, will have on reduction of emissions from other power plants (DEIS p. 4 and 1-16). These assertions are based on the stated assumption (p. 1-16) that this 102 MW windplant (68 turbines x 1.5 MW per turbine) will indeed deliver 102 MW of electric power to the power grid. This assumption is inflated and deliberately deceptive with regard to the project’s public benefits. General Electric, the turbine manufacturer, in a report to the New York State Energy Research and Development Authority (NYSERDA) on March 4, 2005, stated, “Capacity factors of inland wind sites in New York are on the order of 30% of their rated capacity. Their effective capacities, however, are about 10% [of rated capacity], due to both the seasonal and daily patterns of the wind generation being largely ‘out of phase’ with the NYISO load patterns.”2 The erratic nature of wind and the impossibility of matching supply to demand with wind-generated power make it the least preferred power source for the Independent Systems Operator (New York State power grid), which does not want the proportion of wind-generated power to approach current goals of the NYS Renewable Portfolio Standard (25% for all renewable sources) because of grid stability issues and because the NYISO’s need is for capacity (power generated at the specific time to match needs) not energy (power generated at other times) (testimony presented at the RPS Hearing of the Energy Committee of the NYS Assembly, March 7, 2006). NYSERDA further states that wind power can produce, at most, 1.7% of NY State’s electricity needs.3 Noble Environmental is aware of these limitations and writes with intent to deceive about proposed project benefits in the DEIS.
It would be possible to present actual data from existing wind turbine installations in New York State (Fenner, Wethersfield, and Tug Hill) on electricity generation and consumption and matching data on state power generation from other sources over the same and earlier time periods to see if, in fact, fossil fuel consumption is reduced by the presence of wind generation, and if so, by how much. Since wind generation is erratic, it would be useful to know which alternative sources (fossil fuel vs. nuclear vs. hydro) are dialed down when wind plants are producing. The strength of this analysis could be enhanced by similar information from the states of Vermont, Pennsylvania, and West Virginia, where there are also wind generation facilities in operation. Independent analysts have difficulty gaining access to these figures, perhaps because the data are not favorable to the wind industry.
2. General quality of the DEIS
The Noble Environmental DEIS is a document remarkably naïve of useful data. Data there is, or at least lists of information and tables of numbers which were measured in some way, but the measurements and numbers stop short of demonstrating anything meaningful, even when comparisons are made. Ecology and Environment, Inc. has created for Noble Environmental a soothing, pleasing, and mind-numbing document whose conclusions, section after section, are unsupported assertions of a most vague nature. Problems are masked by inadequate data gathering or presentation. There is no interest in realistic solutions even when problems are documented. The document relies heavily on the unspoken assumption
that our presumption is that the project has no environmental impact. If this is the case, inadequate data leads us back to the conclusion that the project has no environmental impact, because the presumption, or null hypothesis as it is called in science, has not been disproven. In reality our presumption in requiring a study of environmental impact is that the impact is significant, and the burden of proof rests with Noble Environmental and its contractor, Ecology and Environment, to demonstrate that the project’s environmental impact is sufficiently low relative to the social and economic benefits to be gained. If the data is inadequate or not pertinent to the problem at hand, then our presumption of significant environmental impact has not been disproven.
It is hardly surprising that the creators of this document lack commitment to a scientific approach or to environmental protection, however, given the website description of what Ecology and Environment offers its clients:
“The right environmental permitting strategy can mean the difference between spinning assets and a multi-million dollar write-off. E & E provides strategic environmental permitting approaches to get you the permits you need ahead of schedule and with the operational flexibility you need. From site selection and planning through construction, startup and long-term compliance, E & E's nationwide team specializes in environmental consulting services. We get the approvals you need to get your project on-line ahead of the competition.” (http://www.ene.com/services/power.asp)
This approach is not the intent of SEQRA.
The graphic of a wind turbine presented in several locations in the DEIS (Figure 1-3, for example) is deceptive because it does not represent rotor size accurately relative to the height of the tower. Hub height is marked as 80 m, while rotor diameter, marked as 77 m, is represented graphically by a diameter only 59% of what it should be to be proportional to the hub height. Thus the rotor, whose blade reaches essentially half-way down the tower (77 m being approximately equal to 80 m), is represented graphically as a little pinwheel in this diagram. Little jagged lines are added on either side of the tower base to further the illusion that the tower is even taller compared to the rotor size. This diagram is reproduced in the Avian Risk Assessment to misrepresent the rotor-swept area, a critical concept with regard to avian impacts.
3. Safety from lightning, fires, falling turbines, dislocated pieces of turbine, or ice throw.
In section 2.29.1 and 2.29.3, the DEIS fails to acknowledge that none of the fire departments it names has the capability to fight fires in turbine nacelles (generator and gear box) 265 ft. above the ground. Turbine nacelles contain significant amounts of lubricants and hydraulic fluids. Fires may be started by lightning or brake malfunction. A fire may leave wind turbine controls malfunctioning until the equipment in the nacelle is repaired or replaced, making it more susceptible to accidents.
The Altona Wind Energy Facilities Ordinance allows wind turbines to be erected 500 ft. from roads, 587 ft. (1½ times the total height) from buildings or above-ground utilities, and 1200 ft. from off-site homes. None of these distances are safe with regard to projectiles thrown from spinning 126 ft. turbine blades 390 ft. in the air, such as ice or pieces of blade, which can travel over 1600 ft. In Germany in 2003, in high storm winds, brakes on a wind turbine failed and the blades spun out of control. A blade struck the tower and the entire nacelle flew off the tower. The blades and other parts landed as far as 1650 ft (0.31 mile) from the base of the tower.4 This was an “upwind,” three-bladed, industrial-sized turbines like those in the Project; “downwind” turbines have not been built since the 1980’s. This distance is nearly identical to calculations of ice throw from turbines with 100 ft. blades rotating 20 times per minute (1680 ft) made by a Rutgers University physics professor.5
The “Health and Safety Plan” in section 2.29.2 and Appendix P is an exercise in vagueness and promise, without substance, as is “Fire Safety Planning” in 2.29.3. “Ice shed” in section 2.29.5 does not provide for adequate protection for cars driving past turbines 500 ft. away. “Generally,” this paragraph reads, “ice buildup slows a turbine’s rotation and will be sensed by the turbine’s control system, causing the turbine to shut down” (DEIS p. 2-185). “Generally” is not good enough, nor is reliance on a mechanical system without the back-up of adequate setback. There are no plans or preventive measures for lightning strikes or other significant accidents. The most important preventive measure, adequate setback, has not been taken.
Wind turbines themselves cause irregularities in the power supply as wind speed changes, including power surges as the wind gusts. Residents living near a new wind turbine installation in Meyersdale, PA, which came on line in December 2003, have had to replace stove elements and small appliances due to power surges which started at that time. Residents of Lincoln Township, WI, near a wind installation noticed an increase in lightning strikes in their area after the turbines went on-line in June 1999. Two computers protected by surge protectors and a TV set, all in different houses, were simultaneously “fried” one evening when lightning struck a nearby wind turbine tower.6
The DEIS does not discuss lightning precautions or data on lightning strikes from other installations. A search on the word “lightning” yields one hit, in Appendix P, with regard to performing a “risk analysis” and developing a safety plan sometime in the future. The time, however, is now, before permits are issued to allow construction.
4. Seismic activity
DEIS Section 2.1.3:
“According to the USGS, which maintains records extending back to 1638 [sic], two significant earthquake epicenters (magnitude 5.0 or greater) have been recorded in the region. The Project Site is located within a low to moderately active seismic region. One magnitude 5.8 quake occurred in the Massena, New York area in 1944 and one quake with magnitude between 5.0 and 5.9 occurred South of Montreal, Quebec in 1877. Both areas are located between 50 and 100 miles from the Project Site. However, no earthquake epicenters with a magnitude of 6.0 or greater have been recorded within 100 miles (U.S. Geological Survey 2006). In addition, no significant tectonic faults have been mapped in Clinton County, and there are no known active faults (i.e., younger than 1.6 million years) in this region (U.S. Geological Survey 2002)” (DEIS p. 2-2).
DEIS Section 2.2.4:
“As described in Section 2.1.3, the USGS states that one significant earthquake epicenter (magnitude 5.2) has been recorded within 50 miles of the Project Site and that the Project Site is not located within an active seismic region (U.S. Geological Survey2001). No significant tectonic faults have been mapped in Clinton County, and there are no known active faults (i.e., younger than 1.6 million years) in this region (U.S. Geological Survey2002)” (DEIS p. 2-8).
The DEIS preparers cannot even figure out what they themselves are saying in these two contradictory paragraphs and they did not do their homework.
An earthquake of magnitude 5.1 according to the USGS and 5.5 according to the Canadian Geological Survey with an epicenter 15 miles southwest of Plattsburgh occurred on April 20, 2002, at latitude 44.51 and longitude -73.66, 25 miles from the proposed project site. This earthquake was felt all over New York, New England (to Maine), and down to Maryland. Clinton and Essex Counties were declared federal disaster areas due to $4.06 million worth of damage to roads, buildings, and wells.7
Dr. Frank Revetta, professor of earth science and geophysics at SUNY Potsdam and director of the Potsdam Seismic Network, states, “There is an east-west trending gravity high north of the Adirondacks in northern New York [which] correlates with a belt of earthquakes of shallow depth (