SF763 Mandating 40% renewable energy is premature without: 1. Environmental impact study 2.
MISO and utility feasibility study including economic impact 3. Analysis of the results of upcoming bat and avian fatality study at wind projects in Minnesota (RFP let by Commerce closed Feb 4, 2013) The Minnesota Renewable Energy Standards focus solely on electricity. Carbon dioxide from electrical generation accounts for around 3% of all man-made carbon worldwide. This means MN’s RES starts by focusing on a tiny portion of atmospheric carbon. The RES then attempts to reduce that 3% primarily by mandating the installation and use of industrial wind turbines as the cornerstone of MN’s energy policy. This State RES mandate as a means to reduce carbon is the equivalent of focusing on a speck on the butt of the flea on the collar of the dog. No scientific studies show industrial wind has, or can, produce the desired outcome. At a public EQB forum last fall, citizens asked former Senator, now Governor Dayton’s special energy advisor, Ellen Anderson, ―What scientific studies or experiential data from existing wind turbines was used to create the Minnesota’s wind mandate?‖ Ms. Anderson said, ―There weren’t any.‖ Bill Grant is the head of the Department of Commerce’s Energy Facilities Permitting Division. Citizen’s asked Mr. Grant the same question at the same forum, and elsewhere, and got the same answer. There were and are no scientific studies and no real life data showing that wind energy has a benefit to the environment, will reduce CO2 or replace a coal plant. There are only marketing models created by those getting paid to convince you that wind turbines will save the planet. Coal plant emissions are down dramatically – and not due to the RES The 2012 Minnesota Environment and Energy Report Card states in part, ―Most air pollution in Minnesota today comes from mobile sources, like cars and trucks, trains and buses, tractors and bulldozers, and from fuel combustion for things like home heating. Large, stationary sources of air pollution…such as …coal-fired power plants…[were] once seen as the prime contributors to air pollution, [today] they bear far less responsibility. Over the past two decades, air pollution from [coal plants] has decreased significantly, largely due to government and industry efforts to reduce smokestack emissions.‖ Since 2005, ―Dramatic reductions in mercury emissions from coal-fired power plants in Minnesota have reduced overall mercury levels considerably statewide.‖ This same report contradicts itself by stating that the State’s RES ―reduces emissions of mercury, ozone, carbon dioxide and other pollutants from coal-fired power plants.‖ The report provides no evidence that has happened since 2007 and no explanation as to how industrial wind turbine usage could possibly cause these reductions.
Industrial wind is costly and causes no reduction in CO2 Denmark is the only country in the world that has statistically (on paper) achieved the mark of 20% of electrical generation from wind. With 6000 turbines, it has become dependent on wind power. Even so, in 2000, it still had to export 70% of its wind power at a discounted rate because it was produced at times when it was not needed. There were times when the wind did not blow and Denmark had to import electricity. With wind producing the equivalent of 19% of Denmark’s energy needs, it actually only met about 1.7% of the demand.
Eric Rosenbloom's analysis: http://www.aweo.org/problemwithwind.html The study & wind lobby's rebuttal: http://www.documbase.com/THE-CASE-OF-DENMARK-CEPOS%3A-CEPOS.pdf
Denmark’s experience matches Minnesota’s experience almost exactly. According to the Minnesota Rural Electric Association in 2011, rural rate payers lost 70 million dollars JUST on the portion of wind electricity being generated when utilities cannot use it and it is dumped at a loss on the MISO market. MREA estimates the 2012 loss between $70 and $90 million. Fresh Energy employee J. Drake Hamilton has been travelling around Minnesota explaining that wind is a benefit to rural economies because in 2011 between 6 and 7 million dollars went to rural landowners, counties and townships. This sounds to me like a 64 million dollar loss to rural Minnesota rate payers and the rural economy in 2011. This multi-million dollar rate loss does not count the $1 million per turbine in federal stimulus cash spent on each turbine built between 2008 and 2011. It also does not count the $2 billion being spent on CapX2020 transmission lines largely needed to keep from curtailing wind and to keep the grid from crashing when wind energy is forced onto the grid at times when Minnesotans can’t use it. CapX promises to carry wind electricity to the East Coast who neither needs it, nor wants it. There are no scientific, technological or economic feasibility studies and MISO has not been consulted. It is premature to be talking about a 40% standard 20 years away when we haven’t even started to deal with the problems identified by Denmark in a standard half that size. The leap between 2025 and 2030 represents a jump of 37% of the total goal for wind to be attained immediately after the 20% milestone that proved disastrous for Denmark. Denmark has the highest electrical rates in Europe. Minnesota created a renewable energy information exchange with Germany. German industrial electrical rates have gone up 40% in the past 5 years. German manufacturing businesses are fleeing the country. Germany dumps its wind electricity produced when they can’t use it onto the grids of neighboring countries – mainly Czechoslovakia and Latvia. (Sounds like Denmark) Germany opened a new 2,200 MW coal plant last fall, and there are over 35 more coal plants looking for permits to build. Germany buys nuclear energy produced in France and Czechoslovakia.
German grid operator EON, who is also a member of the American Wind Energy Association, says that Germany’s in-country renewable energy consumption will never top 10% of total electricity. Anything higher is technically infeasible. Germany learned that placing large industrial wind turbines close to homes causes health problems. The minimum setback between a home and a wind turbine in Germany is 3,281 feet. The Minnesota minimum setback, written by Enron, is 500 feet. Don’t eliminate the requirement for utilities to estimate rate impacts SF763 eliminates the requirement for utilities to estimate rate impacts right before the draconian increase in the mandate for variable generation—right when it is needed the most. Don’t alter the Renewable Energy Credit system. Renewable credit banking helps utilities meet their scientifically baseless obligations in the inevitable trouble shooting process ahead. This bill demands that utilities tackle all of the unknowns without any options for flexibility. Just like with Denmark, there are some very real problems that need to be dealt with. Keep the Certificate of Need process; rename it the RES project disclosure process. Most of the wind developed in Minnesota is sold by Independent Power Providers. This bill exempts wind and solar from the certificate of need process. Independent Power Providers are already exempt from most requirements in the Certificate of Need process. By removing IPPs from the CoN process altogether, this bill prohibits utilities from finding out what they need to know to safely integrate unpredictable wind onto the grid. Independent Power Providers follow the business model that Benito Mussolini called ―corporatism‖. Most of the time, they are an organization of LLCs that exist purely as a market response to government intervention. They do not satisfy any legitimate need, nor does anyone willingly pay them for their services. They flirt with regulated entities; they are actually called ―utilities‖ in MN statute; they exploit regulatory accounting and grab all of the incentives available, but they sidestep any meaningful regulation because they are not real utilities. Evaluate industrial wind’s track record before expanding the mandate. What do the public records of Minnesota Wind Projects show? Prairie Rose in Rock County – completed last year; the public record shows a landowner chasing the wind developer off their land with a brick; on other property, the wind developer broke their promise by permanently using parts of a landowner’s property where they ―promised‖ they would never go - cutting their fence lines, ruining their hay crop, and then refusing to reimburse the land owner for the full cost; JP Morgan and GE get the tax shelter and Italian owned Enel was lined up for the federal $1 million per turbine 1603 cash (which they may have missed due to its expiration). Grand Meadow in Mower County – Owned by Xcel and completed in 2009; in the first 6 months of operation they had burning underground electrical lines and exploding T-
junctions; last fall Xcel replaced 6 of the 67 gearboxes at a reported cost of $360,000 each; French owned enXco (now EDF) got the $1 million per turbine federal 1603 cash. Nobles in Nobles County – Owned by Xcel and completed in 2011; this project operated for 12 weeks before burning electrical cables and the replacement of all 134 brand new pad mounted transformers; Xcel requested a rate increase, telling the Public Utilities Commission that they learned from Grand Meadow and Nobles that wind turbines produce less electricity and cost more to maintain than anticipated; Xcel claims that they called around to other wind facilities and found out this is common – produces less and cost more to maintain; French owned enXco (EDF) got the $134 million in federal 1603 cash; rate payers get stuck with higher rates on high maintenance low-output turbines. Elm Creek II in Lincoln County – Four households started complaining of turbine noise immediately after the project began operation in 2011; their only recourse is to complain to Portuguese owned Iberdrola’s US headquarters in Portland Oregon; each household was given a white noise machine that did not fix the low frequency noise problem; Iberdrola then failed to provide the monthly reports ―required‖ by their State permit for 21 months; when prompted by Commerce to do what the permit says, Iberdrola reported the noise complaints were resolved. I doubt the homeowners agree. Bent Tree in Freeborn County – Owned by Wisconsin Power and Light so it does not count towards the Minnesota RES; Bernie Hagen’s health has deteriorated from the turbine’s low frequency noise and he has been advised by his VA doctors to abandon his home; Bernie’s wife, Cheryl Hagen is also sick from living near turbines; permanent loss of TV signal to a large portion of homes the project area which Commerce EFP staff insisted would not happen; Bent Tree’s own noise testing shows it violates even the nonapplicable MN industrial noise standard; the MPUC and MPCA took no corrective action. Jeffers in Cottonwood County – State site permit specified they could only build 4 of the 20 turbines until MISO determined that there was sufficient transmission space on the grid – Jeffers built all 20 turbines without permission and without notifying the MPUC; 810 corporate shells owners in the first three years; current majority owner and permit holder is California Edison (located in California); this is a CBED project with about 30% Minnesota ownership. There were no consequences for failing to follow their State site permit. Buffalo Ridge II in Pipestone County – knocked out phone service whenever the turbines operated – required replacement of all copper phone lines with fiber-optic cable. This is not the only MN wind project that has knocked out phone service. Eco Harmony in Fillmore County (proposed) – Spanish owned Gamesa proposed siting 28 turbines on sink holes; turbines are sited in and around caves were bats hibernate which ensures maximum bat kill; the wildlife study showed no eagles or eagle nests – but citizens reports and photographs continue pouring into the public docket just like the Goodhue project. Industrial wind does not protect rate payers, human health, and the environment.
The most common reason given for the exempting wind from regulatory laws was that, ―we assumed wind didn’t have negative health consequences; we assumed there were no negative environmental effects; and, we assumed wind could replace coal plants.‖ These assumptions turned out to be both baseless and wrong. The law does not hold wind developers accountable for their actions and neither does and government entity. No one represents citizen living in industrial wind projects. There is no local control. Community Based Energy Development is meaningless since it no longer requires MN ownership; majority of revenue flowing to Minnesotans. Commerce rates analysts have stated that there is virtually no difference between CBED and non-CBED financial or ownership structure. ―Certified wildlife biologists‖ hired to ―study‖ the Goodhue Wind project area testified verbally and in writing to the Minnesota Public Utilities that in 2010 there were zero eagles in the project footprint. Now, through the efforts of citizens working with the conservation agencies, USFWS estimates the eagle population at 418, with 9 confirmed eagle nests in the study area. Either the wind company was lying to get their permit, or we should contact the Vatican to have this sudden dramatic appearance of over 400 eagles certified as a miracle. This kind of misinformation appears to be normal in ―environmental evaluations‖ at wind projects. Goodhue is the first project in the nation to apply for an incidental take permit to allow it to kill American Bald Eagles without any danger of federal prosecution. US Fish and Wildlife Service estimates 8-14 eagles per year will die if the project is built according to its State permitted design. A study on Minnesota’s Buffalo Ridge showed a 47% loss of raptors at a wind facility. The loss was immediate, and had persisted 10 years later. A 47% loss of raptors is not sustainable. Bat slaughter is even higher than birds. Legislature should address negative human health effects of turbine noise Minnesota does not have a noise standard that measures turbine noise. And yet faulty noise models using the non-applicable MN noise standard is the sole factor used to determine the distance between a turbine and my house. The Minnesota Department of Health recognized the link between wind turbine noise and human health problems in their award-winning 2009 study, Public Health Impacts of Wind Turbines. The MN Public Utilities Commission took public testimony, agreed there was strong evidence that wind turbine noise poses a public health threat and needed more study, and the Commission committed to doing more. That was three years ago. Other than gathering more similar studies and information, the MPUC has done nothing.
MPUC Commissioner David Boyd facilitated, ―Renewable Energy and Rural Economic Development - A Minnesota-Germany Dialogue on Best Practices‖, in Rochester, MN on December 11, 2012. Werner Frohwitter, one of the German delegates, stated that the minimum distance between a large wind turbine and a home in Germany is 1000 meters (about 3,300 feet); and, that in some locations Germany requires up to 6000 meters. The Germans learned that shorter set backs led to human health problems caused by noise and shadow flicker. The distances Mr. Frohwitter stated are also reflected in the October 19, 2011, ―International Review of Policies and Recommendations for Wind Turbine Setbacks from Residences: Setbacks, Noise, Shadow Flicker, and Other Concerns‖, Minnesota Department of Commerce: Energy Facility Permitting. Since the publication of this document, at least two of the Australian States increased their minimum setback between a home and a turbine to 2 kilometers (6,560 feet) due to human health problems from noise at closer distances. September 21, 2011, Kristi Rosenquist had a conversation about wind turbine noise with Paul Aasen, then Commissioner of the Minnesota Pollution Control Agency. Commissioner Aasen stated, "We don't have a noise standard that's designed to work for turbines". The October 13, 2011 report prepared for the MPUC by David M. Hessler, ―Best Practices Guidelines for Assessing Sound Emissions from Proposed Wind Farms and Measuring the Performance of Completed Project‖, states in part:
The noise produced by wind turbines differs fundamentally from the noise emitted by other power generation facilities in terms of how it is created, how it propagates, how it is perceived by neighbors and how it needs to be measured. Essentially everything about it is unique and specialized techniques need to be employed in order to rationally assess potential impacts from proposed projects and to accurately measure the sound emissions from newly operational projects.
Bernie Hagen, living in the Bent Tree Wind Project in southern MN, has been advised by his VA doctors to abandon his home. The severe negative health effects of having numerous turbines near his home is ruining his health and the health of his wife Cheryl. Other Minnesotans sleep only in their basements for the same reasons. There are numerous unresolved noise complaints on the MPUC dockets from various wind projects including Bent Tree and Elm Creek II. Wisconsin’s Shirley Wind has only 8 turbines has lead to 3 home abandonments so far. Here is a partial finding from a very recent study:
"The four investigating firms are of the opinion that enough evidence and hypotheses have been given herein to classify LFN and infrasound as a serious issue, possibly affecting the future of the industry. It should be addressed beyond the present practice of showing that wind turbine levels are magnitudes below the threshold of hearing at low frequencies."
Audiologist Jerry Punch, retired from Michigan State University, provided this testimony:
What we do know…from the existing peer-reviewed literature is there is undeniable evidence that significant adverse health effects do occur for a significant percentage of people who live near wind turbines. My co-authors and I cited a large amount of such evidence in our Audiology Today article, and a more recent summary is available in a presentation by Carmen Krogh and her colleagues. There is a great deal of information in the scientific literature on these effects. I visited a wind project in Ubly, Michigan, where I interviewed a family who had just moved from their home because they could not tolerate the noise from the turbines. …[I] have since visited and interviewed another family in Michigan that has had to abandon their home because of wind turbine noise. The WHO, which has been concerned mostly with noise exposure during nighttime hours, has concluded that noise levels in the 30-40 dBA range lead to sleep disturbance and other adverse health effects, and reduce quality of life. It has said that noise levels between 40-55 dBA cause adverse health effects that increase with increased noise levels, vulnerable persons experience even greater effects….
Conclusion The 2007 RES mandated industrial wind to reduce CO2. SF763 increases the mandate, while looking at selective, skewed data to support the illusion that the RES brings benefit to Minnesotans as a whole. There is no scientific or experiential data demonstrating ANY benefit to human health, or the natural environment, or to society as a whole from industrial wind turbines. Politicians who crafted Minnesota’s renewable energy law made baseless assumptions of significant benefits and no harm. Those assumptions have been proven wrong. From the likes of T. Boone Pickens to GE, to Morgan Stanley, the wind industry has been manipulating legislatures and statutes to help them abscond with obscene amounts of money. They peddle lies and use government to force inappropriately sized payments from a helpless public. Wind developers dash for cash unhindered by regulation, oversight or accountability. Utilities need freedom to figure out ways to safely meet the obligations already before them. Citizens need the legislature to rein in the rogue element that is the driving force behind this. Sunshine and wind are free. Making electricity from sun and wind is not.