Presentation to Cape Cod National Seashore Advisory Commision Nov 16 2009
Mr. George E. Price, Jr.
Superintendent
Cape Cod National Seashore
Headquarters
99 Marconi Site Road
Wellfleet, MA 02667
Statement to the Cape Cod National Seashore Advisory Commission Regarding The Proposed Construction of One or More 400 Foot Industrial Wind Turbines on Land Bounded by the National Seashore Near White Crest Beach, Wellfleet, MA
Dear Mr. Price:
At your suggestion, I am writing to provide you with a written statement for incorporation into the proceedings at the upcoming meeting of the Cape Cod National Seashore Advisory Commission to be held on Monday November 16th. I will make every effort to attend in person but in the event this proves impossible, I appreciate your offer to read my statement into the minutes for me.
I am also sending some additional materials in the form of Appendices to my statement for distribution to the Advisory Committee members and for incorporation in the formal minutes, perhaps through reference via a weblink to some appropriate area on the CCNS website.
These Appendices include, but are not limited to:
1) Several Letters to the Editor of the New York Times expressing dismay regarding various proposals to erect such massive wind turbines in treasured community spaces, specifically including the Cape Cod National Seashore;
2) Testimonials from homeowners in three different states describing how the installation of wind turbines near their homes proved so disruptive – and ultimately unbearable -- that at least one family abandoned their home because no one else would buy it. I could have included other similar stories from many other regions inside the United States and Canada where zoning regulations are particularly weak – there are many; and
3) Articles by two qualified noise control engineers who argue convincingly that existing standards for measuring the degree of disruptive noise from wind turbines are completely inadequate because of the nature of the noise produced (lower than normal sound spectrum, repetition, change with weather conditions, persistence, etc) and because of the unusual nature of rural sites where wind turbines are often erected. As you can imagine, “ambient noise” in rural sites– the baseline from which incremental noise from huge mechanical devices such as turbines is measured – is often low to begin with and of such a quality – say, frogs and crickets – or wind and waves at Wellfleet -- that it does little to mask the rhythmic throbbing or whooshing of a large mechanical device like a rotating fan that has a rotor diameter that is about the size of a football field.
I am also sending several additional documents, most of which have been produced, over time, directly or indirectly, through the efforts of the Wellfleet Energy Committee (or by the Town of Wellfleet), and all of which are vitally important to understanding the proposed project. These include:
1) Wellfleet Wind Turbine Feasibility Study (August 2008)
2) Wellfleet Wind Turbine Preliminary Site Analysis
3) Wellfleet Wind Turbine Flicker Analysis
4) Wellfleet Wind Turbine Acoustic Study
5) Wellfleet Energy Committee Minutes
6) Wellfleet Zoning By-Law Changes to Accommodate 400 Ft Wind Turbines
7) Correspondence from CCNS to Wellfleet concerning zoning issues and potential conflicts with the proposed building site bounded by CCNS
None of these documents -- with the exception of the WEC Minutes and the Zoning By-Laws, as recently amended, to permit the construction of 400 foot Wind Turbines in Wellfleet with minimal setbacks -- are easily obtainable, hence my interest in providing them to you to stimulate wider circulation.
Lest I be accused of exaggerating, let me hasten to say that some of these studies -- on projected feasibility, wind studies, sound studies, and the like have been available – IF you happen to make a practice of trolling through the websites of certain quasi-government agencies that remain somewhat obscure for the large majority of us. But it can hardly be said that the documents were “disseminated” to interested parties, or that they were placed in the “public domain.”
The Wellfleet Energy Committee (WEC) itself has made zero effort to put these documents – or any other relevant documents – in the public domain until quite recently – even though their project is potentially of national interest since it does, in fact, propose to erect a 400 foot tower in the middle of the Cape Cod National Seashore, one of our most treasured National Parks.
I did notice, however, that on last Thursday or Friday (one or two business day ago) the WEC finally uploaded – published is too strong a word – most of these documents within the bowels of the official website for the Town of Wellfleet.
To put this in perspective, please recall that it was actually three weeks ago, on October 26th, 2009, at a Special Meeting of the Town, that the WEC sought – and obtained – an authorization to spend $290,000 of the Town’s money to move forward with this project, to circulate a formal Request for Proposal to potential contractors and to obtain necessary permits. NONE of the material I am sending to you -- all of which was unearthed only by persistent direct inquiry on the part of a handful of tenacious Wellfleet citizens -- was made available to voters. Not even the core document, a 243 page feasibility study prepared by Black & Veatch, which, incidentally, the WEC received in August of 2008, a full year prior to the Special Meeting.
At least one citizen spoke up in protest at the Special Meeting, saying that there was no basis for a vote because no substantive information was provided for voters to consider! He was swiftly silenced, however, when proponents of the Wind Turbine moved to end discussion and proceed with the vote despite this minor omission. “Green is good,” they said. “And we’ll turn a profit, too!”
I forgot to mention one more thing about the informational “website” put up by the WEC on the Town webpage. For all intents and purposes, it doesn’t exist.
You cannot find it through any indexing mechanism at the site. Nor is it listed, or even alluded to, on the Wellfleet Energy Commission home page. The only way I know of that you can find it is to type the words “wind turbine” in the Search box and sift through the results.
I’m sure that this Advisory Commission has little interest in the political machinations of a small town like Wellfleet, but it most decidedly has an interest in taking good care of a precious and economically important shared resource and in achieving a proper balance between the needs of the National Park and the surrounding communities in a fair and reasonable manner.
My point is that it’s impossible to have a fair and open debate, or a credible democratic process, or intelligent decision making in an administrative capacity, if information critical to evaluating the merits of a proposal is withheld. This applies equally to the voters of Wellfleet; to the Superintendent of the Park, who is, in effect, responsible for protecting this national resource; and to citizens from all over the country, all of who have a stake in this issue.
Let me take a minute to tell you why I feel that I, personally, have a stake in this thing.
I grew up not on Cape Cod but in Indiana and Wisconsin and visited various places along the Outer Cape for the first time during a family vacation when I was fourteen years old. It was an experience I never got over.
When I was 20 years old, during college, I headed back to the Cape where I landed a summer job as a waiter at the Orleans Inn. It was during that summer, over 30 years ago, that I met my wife and spent virtually every day on the very beach in Wellfleet that proponents of the wind turbine seem to value so lightly. To this day, I still think that this stretch of land offers some of the most breathtakingly beautiful, and peaceful, vistas in the entire seashore. I can’t imagine I would feel the same way after the Town of Wellfleet planted a 400 foot Wind Turbine – so grossly out of scale – right in the heart of it.
My wife’s family has been coming to the Cape – to South Wellfleet, in fact – every summer since 1960 – 50 years next year -- and has no interest in going anywhere else. My wife’s parents purchased a residence there in 1978 and my mother-in-law has been a full time resident for over 15 years, having realized her dream to retire peacefully, one day, to her favorite spot on earth, South Wellfleet. I’m sure that her four children (and perhaps her grandchildren) in this extended family all harbor similar dreams.
I only just learned about the proposed Wind Turbine exactly one week ago, during a visit to my mother-in-law, when she asked me to help her understand what’s going on. Her residence is one of the closest to the proposed construction site. She had only just recently attended the Special Town Meeting to vote in favor of the proposed Wind Turbine, partially on the advice of one of her neighbors – the father of the Turbine – who told her it would be no big deal and who had given her to understand (as most residents still believe) that the Turbine would be located “out of the way” behind White Crest Beach.
In fact, life at her residence – and her entire environment nestled within the Cape Cod National Seashore -- will be dramatically altered if the construction of the Turbine is allowed.
To judge from comments made by Wellfleet’s own delegate to the Advisory Committee at a recent meeting (12/11/2007), there are some full-time residents who might scornfully consider my mother-in-law, or her children, to be “cash cows” – i.e. non-residents, or retirees, who pay a lot of taxes and don’t demand much from the Town in the way of services. And it is interesting to note in the minutes from the same meeting that when potential sites for the Wind Turbine were being evaluated, the West side of Route 6 was very quickly disqualified and all attention focused on the East side of the road – which is to say where many of the summer residents live and where the Cape Cod National Seashore owns most of the land.
It seems apparent that the Town, essentially, thought they might encounter less friction from CCNS, and from the more sparsely populated areas East of Route 6 -- where many property owners are non-resident, and therefore not entitled to vote on local matters -- than from people in densely populated areas who also didn’t want to live next to Wind Turbines with all of their attendant side effects.
Or to judge from some intemperate comments offered recently by one of the members of the Wellfleet Energy Committee to another long-time summer resident, perhaps my mother-in-law and her neighbors in or close to the seashore are basically just a bunch of whining NIMBY (“not-in-my-backyard”) types who can’t appreciate the virtues of clean energy and who are selfishly unwilling to endure, or to condone, a great personal, and national, sacrifice so that the Town of Wellfleet might help us to achieve a relatively miniscule, incremental reduction in our collective carbon footprint -- at a profit to the Town – from the operation of their One Unit Windmill Farm sprouting out of the Seashore. What’s wrong with those NIMBY’s anyway? Why can’t they be team players?
The more I researched this question, the more appalled I became – and not just because I’m a NIMBY, one step removed. I realized that there was a point of view on this issue that has gone almost entirely unrepresented here because, to date, the field has been left to the proponents of the project as they grind through the approval process within Town Government, or the State, or in contacts with the Seashore. They are the only informed parties to the debate because they’ve got all the information. In fact, it seems quite clear that their goal has been to move the process along with as little scrutiny as possible until a certain sense of inevitability attaches to the project. And there’s nothing like getting taxpayers to pony up hundreds of thousands of dollars in preliminary funding to get them a little bit pregnant – even though they really have no basis to understand what it is they’re really voting for.
I am unalterably opposed to this project for several fundamental reasons:
First, the Town of Wellfleet has no business asking for permission to construct a 400 foot Wind Turbine to power a commercial electric utility in the heart of the Cape Cod National Seashore.
For one thing, the legislation which created, and which governs the administration of, this unique National Park expressly forbids the development and running of such businesses within CCNS boundaries – and for good reason, too, since this is contrary to the whole reason the Park was created in the first place: to protect some last, wild scenic areas from the ravages of development.
The Town of Wellfleet, which proposes to construct their Wind Turbine on a lot that is bounded on all sides by CCNS property, is trying to slide past this restriction by suggesting they are allowed an exemption for use of property “for municipal purposes.” They claim that they are going to have a minimal impact on the environment – it’s mostly vertical, after all. But, in fact, they are going to run a business within the boundaries of the Park – and, oh, what a visible, disruptive business it will be, too.
Note that their plan – as expressed in their comprehensive 12 page large-type power point presentation to voters on October 26th and also, in some more detail in the feasibility report prepared for them by Black & Veatch – anticipates meeting their own municipal needs for power AND selling incremental power back into the grid, at the full retail price, to generate additional “net revenues” and cash flow to pay back their bonds and net a profit.
It’s a business.
It’s unusual for a modest town the size of Wellfleet to have such large ambitions as owning and operating their very own electric utility, but the feasibility study gives two concrete reasons why they might:
a) because private companies definitely are NOT allowed to run “commercial enterprises” within National Park boundaries; and
b) as Black and Veatch note, no private company in the business of generating wind power would ever entertain such a ridiculously small project as a three wind turbine “farm” (or one) because such a project in general – and this project specifically – would be completely uneconomic, bordering on absurd.
So if Wellfleet wants to have a wind turbine, they’ll have to build it and operate it themselves. Private owners can’t run businesses within the Seashore, but Wellfleet figures that they can HIRE people to run a private business for them – one that would be considered non-economic with their own money – and pass the benefits along to them.
Wellfleet did consider two other sites for wind turbines on the West side of Route 6, OUTSIDE the boundaries of the Seashore, but these sites were considered too densely populated to tolerate the adverse effects of the turbines (and moderately less windy but not dramatically so). Not surprisingly, the reason that there are so many fewer people on the East side of Route 6 – the deciding factor really – is that much more of this land is owned by CCNS.
So, ironically, all of those years of prohibiting development within the Seashore, and protecting the pristine environment there, have made it an enticing location for…..industrial development!
Or “municipal use,” depending upon how you define it. But you know what they say: “If it looks like a duck, walks like a duck and quacks like a duck – it’s a duck!”
I can’t leave this topic without addressing the whole dubious concept that the proposed 400 foot Wind Turbine – with a spinning rotor diameter approximating the length of a football field – won’t be disruptive to the natural beauty of this particularly varied and uniquely beautiful landscape because it won’t obstruct views of the ocean, for most people, and those are the views that we all really care about. Right?
Why can’t it be argued – contrary to the pages of lengthy discussion captured in the Advisory Committee Minutes of 12/11/2007 -- that the view of the ocean is NOT the only “money shot” in the “view shed” for some people who appreciate the totality of the experience of immersing themselves in a rare and unspoiled environment?
Would we consider erecting a Wind Turbine in Yosemite National Park so long as it didn’t block our view of the famous waterfall? Or in Yellowstone National Park as long as we could still see Old Faithful? And why don’t we put a few dozen – or a few hundred -- Wind Turbines in Grand Canyon National Park? Really, it’s so vast and so empty, and they would hardly take up any space at all.
As the minutes say, there are “money shots” and there are other views that people value somewhat less. Says who? That’s the type of methodology that might work when you are compelled to build something in the least bad place, but not in the heart of a National Park. As the minutes also say, the “value” that any particular person places on any particular “view shed” is inherently subjective – which is why we have National Parks, so that people can roam around in them and enjoy one view after another.
And finally, after all is said and done, what is so compelling about this “green” energy project? And could we please stop referring to the Wellfleet Wind Turbine as a 1.5MW Turbine? It has a rated capacity of 1.5MW and a projected “capacity factor,” if all goes well, of perhaps a third of that, which means that, maybe, it will produce 500 KW of power.
Is that such a dramatic reduction in our carbon footprint that it justifies sacrificing a National Park to get it? Would you take a chainsaw to your couch because you had a hunch you might find a few nickels in there?
I know that it is vitally necessary to take aggressive steps to reduce our carbon footprint. I’m a tree hugger. I’m a member of The Nature Conservancy, The National Resources Defense Fund, The Audubon Society and The Sierra Club. I drive a Prius – one of the old ones – that we bought in 2003. I would even be in favor of a substantial tax on carbon emissions.
The bottom line, to paraphrase a young senator, is that I’m not against all sacrifices and all alternative energy projects; I’m just against stupid ones.
Second, the financial and operational aspects of this project are fraught with risks that I’m sure (as a former commercial bank lender and bond trader) that none of us, not me, nor the Town nor CCNS can even begin to understand based upon available (or not available) information and lack of experience.
That may seem like more of an issue for the taxpayers of Wellfleet than the CCNS Advisory Commission but not when you recall that a) the operation of a commercial business within the boundaries of a National Park is strictly prohibited; and b) Black & Veatch have flatly stated – and the projected returns make it obvious – that no private operator would touch this thing.
So what happens if Wellfleet stumbles? What if running a marginal, single turbine wind farm proves to be more challenging than they anticipated for both financial and operational reasons? What if it turns out to be a big money loser and taxpayers don’t want to fund it anymore?
I can say categorically, with complete confidence, that there is not a single person in this room who truly understands the viability of this venture. How can I say that?
For starters, there is nowhere near enough information available in the public domain to make a reasonable judgment. Here a few examples:
· The feasibility study was written in 2008, prior to the finalization of legislation pertaining to the all-important “net metering” that will drive the profitability of the project (which is already marginal on what appear to be somewhat rosy assumptions). As the WEC minutes state in more than one place: no net metering, no profit.
· Even though the feasibility study provides some projections, they don’t provide all of their assumptions. What the authors do provide, however, is a blunt statement that their projections do not incorporate all of the costs of the project. Precisely what other costs might attend the construction and operation of the plant remains a mystery and, in any event, time has passed and some aspects of the design are now significantly different from the original proposal.
· The B&V proposal provides a table that shows the price of electricity at wholesale and net metering rates over the past several years. Naturally, the “net metering” rate – retail, to you and me – is a LOT higher than the wholesale rate. This project is DOA at wholesale rates. But what I also noticed is that B&V seemed to project revenues based upon extrapolating the price of electricity in 2008. Remember August 2008? That was when the oil sold for $147 a barrel, rather than $77 a barrel where it trades today. Energy – even electricity -- is a volatile commodity whose price can fluctuate wildly with demand. It can fluctuate up or it can fluctuate down – but the latter scenario is the most troublesome when most of your costs (like debt service) are fixed.
· You could turn to other sources for information regarding the projected financial viability of the enterprise but your only other source – Page 5 of the power point presentation that ushered in the $290,000 authorization for permitting of the project – basically just says it’s all going to be good. The Town’s going to make money. And it’s green. Unfortunately, there are no other sources.
· Two areas where you might want to tread lightly in both of these sources, however – one of them crucial and the other quite significant – are the assumptions regarding “net metering” and the advantageous financing that will be realized via the Clean Renewable Energy Bonds program.
First of all, no one knows the net metering rate because the tariff hasn’t been set yet. And, as I alluded to above, no one really knows this rate for future years because the future price of electricity is unknowable (which is another reason not to embark on a one unit, stand alone, electric wind turbine adventure – your first ever -- with very low projected ROI and little room for error).
Second, Wellfleet doesn’t even know if they will qualify for the net metering program because there is a statewide cap on the program and a queue. At the writing of the last minutes, there was even some confusion as to whether one entered the queue upon the submission of one’s application to the program or whether the clock really starts once your facility is permitted and/or completed.
At this time, there are projects going up all over the Commonwealth of Massachusetts racing to beat the deadline. Suffice it to say, “It ain’t over ‘til it’s over” (my apologies for quoting a famous Yankee. Go Sox!). And it ain’t over! It ain’t even started yet. No one knows whether the Wind Turbine By the Sea will be one of net metering’s chosen few.
Third, there is a problem with the CREB program that the WEC highlighted in their presentation to the voters three weeks ago, as a source of funds -- the one which allows Wellfleet to borrow money at 2%. They don’t have any funds; they’re out of money. Apparently, the WEC just found out recently – must have been VERY recently – and are “re-working” their projections – i.e, the ones which only they have access to.
· There is more that could be said here, but I think we all get the point. In fact, it’s kind of useless to talk about it anymore because there really are no numbers to talk about. Suffice it to say, this is no slam dunk.
My third reason for opposing the proposed Wind Turbine Project at White Crest Beach is that I believe – I know -- that the construction of a 400 foot industrial Wind Turbine will forever alter the landscape and will adversely affect the Seashore, the many users of the Park, and the nearby residents in certain predictable ways – and, doubtless, many unpredictable ways, as well.
For one thing, the “flicker effect” from these huge structures is no joke, no matter how benign it sounds in the objective recitation of the data in the B&V feasibility report or in other stand-alone analyses. It literally drives people crazy. Its effects are most pronounced in the morning and late afternoon / early evening when the days are long and sunny – June through September – especially when you’re outside. The flicker pattern in the B&V pattern covers an extensive range, as you might imagine. And don’t let anyone tell you that the trees in this part of the Cape are going to “mitigate” the effect – especially if you’re riding your bike or walking under the shadow of the behemoth. So, if you like having a beer on your deck, or watching the sunset, in the summer, you might have to give that up.
Second, the sound studies that are routinely performed – by the installers, naturally – are inherently flawed and do not predict the actual experience of those who have the misfortune to live near commercial wind turbines. Ironically, this is especially true of residents in rural areas where the ambient noise (against which the disturbance from the Wind Turbine is measured) is relatively low and totally distinct from the rhythmic sounds emanating from Wind Turbines. In other words, the ambient noise doesn’t mask anything. Imagine yourself listening to the sounds of nature – or straining with the effort NOT to be listening – with the constant, low, deadening whoosh/whoosh/whoosh in the background like a metronome that never quits. It’s an unnatural sound that stands out and, according to some, gets under your skin and “into your bones.”
Third, virtually all noise statutes are written to deal with a different part of the noise spectrum than the sounds produced by Wind Turbines – which are lower in frequency, and pulse relatively slowly, but which travel relatively far. Which is why all of the installers gleefully proclaim (like WEC) that there projects “meet or exceed all applicable noise statutes.” Right. Because the existing noise statutes haven’t caught up to this problem and they’re not really applicable.
Fourth, the noise emanating from commercial Wind Turbines changes with conditions (weather, humidity, wind speed) and has a rhythmic, pulsating quality. To paraphrase one of the testimonials I included here, they say it’s no louder than a refrigerator inside – which may be true if the windows are closed. Now imagine gardening with your refrigerator. Or walking the dog. Or washing your car. Or looking at the sunset. It never goes away.
Please read the testimonials. These people aren’t crackpots. Their lives changed drastically with the turbines. So did their property values – VERY drastically.
But perhaps the most troubling assertion from the proponents of the 400 Foot Wind Turbine about it’s “acceptable” or “minimal” environmental impacts – once I get past the outright desecration of our National Park – and the discussion about how the Tower won’t really affect the “money shots” in the “view shed” – and the reassurances that the sound will be “nothing” – and the promises that I’ll hardly notice the “flicker” – once I get past all of that, the assertion that really bothers me for being so transparently false is the insistence that the “footprint” of the project is “really quite small – 5 acres or less” for the service area around the Wellfleet Power Company and for all the service roads and the like.
First of all, they will have to build a service road from Ocean View Drive to access the Solo Turbine. It seems reasonable to assume that the road, to be reliable, will have to be paved with something other than sand.
Second, they will have to build an enclosure around the Turbine – the so called “Fall Zone” – which will presumably be bounded by some sort of durable material such as a galvanized cyclone fence. The “Fall Zone” itself will be pretty extensive since the rotors – those whirling blades -- reach 400 feet in the air.
But the main thing is that the visual effect, the noise and the flicker effect will ALL emanate out over a vast area, affecting everything within the area where these things can be perceived. There are numerous trails in the woods in the vicinity of the Turbine, running back and forth between the ponds, along fire trails, and simply just to and fro throughout this unspoiled area. I walk them every chance I get, because there’s nothing so peaceful as the solitude and the elemental beauty of these wind-tortured woods. And when I do, I almost always encounter someone else somewhere along the line who is doing the same thing – and looking as if he or she feels equally blessed.
I know for a fact that the “footprint” of the damn Wind Turbine isn’t going to be limited to a mere “5 acres – perhaps less.” It’s just common sense. And I don’t want to take a refrigerator (or two) with me when I go out for a walk in the woods in my favorite National Park.
Thank you for your time and for your indulgence. I’ve gone on much longer than I intended and I hope that you don’t feel that I’ve wasted your time.
Sincerely,
Eric Bibler
