January 3, 2010
To: The Honorable Barry Ormsby
8141 Swan Road
Adams, NY 13605
Re: Proposed Galloo Island Wind Turbine Project - Environmental Impact
Dear Barry:
I have read Mr. Burgdorf’s comments on Mr. Ashodian’s recent letter to the DEC. I have reviewed environmental impact statements in my professional career going back to what I believe to be the original one in the early 1970s for the Alaska Pipeline. My own review of the DEIS/FEIS for Galloo causes me to agree completely with Mr. Ashodian’s insightful comments. It is unprofessional in the extreme for Mr. Burgdorf, who does not seem to have any engineering or scientific qualifications, to trumpet that “The DEC has been deeply zealous and has required 2 years, and many millions of dollars worth of rigorous testing and studies on every imaginable potential environmental impact.”
My colleagues in The Coalition for the Preservation of the Golden Crescent and the Thousand Islands and I still have serious reservations about the document and the studies performed in support of it. Mr. Ashodian’s comments illustrate my own general impression of the studies undertaken by the DEC – that they have simply catalogued the more obvious aspects of the environmental destruction that will be accomplished in pursuing this project.
Mr. Burgdorf criticizes Mr. Ashodian for not backing up his assertions. I would suggest that is not Mr. Ashodian’s job. If a layman can find so many major deficiencies in the DEIS/FEIS, that is clear evidence that the document is inadequate and does not support its own presumptive conclusion – that the project should move forward.
Mr. Burgdorf cites the acoustical studies that were done as an example of the thoroughness of the DEC’s approach. I have, on several occasions, during the review of this project expressed my concerns about noise impacts on shoreline residents, particularly on Point Peninsula (this is also obviously a concern for similarly close areas of Henderson, Brownville, and Cape Vincent.),which is part of the Town of Lyme, where I serve on the Planning Board.
DEC produced a study by Tech Environmental that “proves” that the sound will not be a problem by the simple and unsupported expedient of assuming an ambient sound level of 50.7 decibels in this quiet rural area! This ignores the common nighttime condition of a stable atmosphere that produces a quiet windless condition on the surface while there is a steady wind powering the turbines at the level of the turbine blades. The likely ambient nighttime sound level under these conditions is in the range of 18 – 25 dB and the turbines will be noticeable under these conditions.
I also asked Clif Schneider and Chuck Ebbing to review this acoustical study by Tech Environmental. Clif has done considerable investigative work on the effects of the stable atmospheric condition I refer to above. Mr. Ebbing is are tired acoustical engineer who has taught acoustics at RPI. His succinct comment on the study was that if a student at RPI had submitted the study “he would have flunked Acoustics and English.”
The most glaring omission in the DEIS/FEIS is the absence of any proof that the turbines will accomplish their stated reason for being – that is that they will actually reduce consumption of fossil fuels and the resulting emissions of greenhouse gases. A substantial reduction in pollution would be required to justify the wholesale destruction of the pristine environment of Galloo Island and the potential environmental damage inflicted by the transmission lines that will carry the electricity produced. The report is strangely silent on this vital portion of the environmental impact. We are being asked to accept the notion that these wind machines will be the answer to our environmental problems, an assumption that is not supported by any available evidence.
Wind power has not, in this case or in general, been proven to reduce overall use of fossil fuels or reduction of greenhouse gases. Wind developers claim that WTG installations are “clean and green,” but do not supply any analyses to demonstrate that wind power actually reduces the use of fossil fuels or the emission of greenhouse gases The poor efficiency of wind power is not a result of deficiencies in the design of the turbines, but is simply a result of the natural variability in the wind’s velocity. We are asked to accept that all of the environmental problems created by the construction and operation of this proposed facility are acceptable or are in some way mitigated in order for the development to proceed.
We are asked to accept all of these negative effects based on the unsupported assumption that the electricity produced by the turbines will enable utility companies to significantly reduce their use of fossil fuels and the consequent emission of greenhouse gases.
This assumption that the WTG fulfill their intended purpose is questionable because of the extreme variability of the wind. The operation of the WTG effectively magnifies the variability of wind, as the kinetic energy in wind is a function of the cube of the wind speed. Thus a doubling of wind speed will cause the WTG to produce eight times the energy or conversely if the wind speed drops by half, the electricity will be merely one-eighth.
The only types of existing generators capable of accommodating the extreme variability of the wind are hydro-power and simple gas turbine powered generators. These are the generators that will need to be used to “fill-in” the approximately 70 % of the WTG rated capacity that is not produced by the wind turbines due to the natural variability and unpredictability of wind.
Obviously, to the extent that hydro-power is used to balance the variability of the wind, there will be no reduction in fuel usage or emissions as we will simply be substituting one form of non-polluting power for another.
If the balancing is done with simple gas turbines, it will require them to be operated in a very inefficient manner. This mode of operation is similar to a car being operated in a manner that includes sudden stops and jackrabbit starts. The fuel economy will be poor and a high ratio of unburned hydrocarbons will be emitted. There are a number of available studies that indicate that the provision of more efficient, combined-cycle gas turbines alone would be more efficient and reduce both the emissions and investment than the case of simple gas turbines combined with WTG installations. All we see from the wind energy proponents are the meaningless slogans they promote such as “Clean, Green and Free.”
Sincerely,Albert H. Bowers III,
Co-Chair The Coalition for the Preservation of the Golden Crescent and the Thousand Islands
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