OAH Docket No. 12-2500-20615-2

PUC Docket No. ET-6657/CN-07-1425

PUC Docket No. ET-6675/WS-08-573

 

STATE OF MINNESOTA

OFFICE OF ADMINISTRATIVE HEARINGS

 

FOR PUBLIC UTILITIES COMMISION

 

In the Matter of the Application of Wisconsin

Power and Light Company for a

Certificate of Need for a Large Energy Facility,

A 200 Megawatt Wind Farm

                                                                                       SUMMARY OF PUBLIC TESTIMONY

In the Matter of the Application of Wisconsin

Power and Light Company for a

Site Permit for the 400MW Bent Tree Wind

Project in Freeborn County

 

 

This matter began on August 27, 2008, when the Minnesota Public Utilities Commission (MPUC or Commission) issued an Order accepting Wisconsin Power and Light Company’s (WPL or Company) application for a Certificate of Need (CON) for 200 Megawatts of the proposed phased 400 MW Bent Tree Wind Project and approved the use of an informal review and requested the Office of Administrative Hearings (OAH) to coordinate the processes associated with the project with MPUC staff and to hold at least one public hearing on the project.

On September 16, 2008, the MPUC issued an Order accepting WPL’s application for a site permit application for the proposed 400 megawatt Bent Tree Large Wind Energy Conversion System (LWECS) Project in Freeborn County.  By Order issued on March 24, 2009, the Commission denied a request for a contested case hearing in that proceeding and ordered a public hearing to be held in conjunction with the public hearing that the Commission had previously ordered in connection with WPL’s CON application

Administrative Law Judge Steve M. Mihalchick conducted a public hearing on the project on June 29, 2009, at 2:00 p.m. and continuing at 9:00 p.m. at the Freeborn County Government Center, 411 South Broadway, Albert Lea, Minnesota.  Approximately thirty members of the public attended the hearing, twenty of whom offered testimony.  Additionally, approximately ten WPL employees attended the public hearing.  The ALJ was present at the hearing and provided those members of the public an opportunity to present their views regarding the need for and proposed routing for the project.  The period for written comment closed on July 14, 2009.


NOTICE

            This report contains a summary of public testimony.  It is not a final decision. Pursuant to Minn. R. 7849.5720, the Commission will make the final determination of the matter within 60 days after the receipt of the record from the administrative law judge.

Description of the Project

 

The Project is being proposed by WPL, a Wisconsin public utility and wholly owned subsidiary of Alliant Energy Corporation.  WPL’s Integrated Resource Plan demonstrates a need for 300 MW of new wind resources between 2008 and 2010.  The Company will obtain the first 100 MW of new wind resources from a 27.5 MW Purchased Power Agreement with Forward Energy and by constructing the 68 MW Cedar Ridge Windfarm in Fond du Lac County Wisconsin.  WPL proposes to obtain the remaining 200 MW of new wind resources from the first 200 MW phase of the proposed 400 MW Bent Tree Wind Project in Freeborn County Minnesota for which a site permit is now being requested.

The Project’s first phase will be a large wind energy conversion system, as defined in Minn. Stat. §§ 216F.01 — 216F.07, of up to 200 MW, consisting of up to 121 1.65 MW wind turbine generators.  The towers will be 262.5 feet high, and the rotor diameter will be 269 feet.  The maximum overall height will therefore be 388.8 feet when one rotor is in a vertical position at the top of the rotation.  If the second phase is constructed in the future, the entire project could involve 242 1.65 MW turbines with a nameplate capacity of approximately 400 MW.

The electrical collector system will consist of underground 34.5 kV collection lines feeding into a collector substation with two 34.5/161kV transformers and a 161kV switch station with two terminals.  One of the terminals will connect to the new 18-mile long 161 kV high voltage transmission line going to the Hayward ITC-Midwest substation, located east of Albert Lea; the other terminal will be reserved for connecting the second, north phase of the Bent Tree wind farm at a later date.

Assuming an estimated net capacity of approximately 38%, projected average annual output will be 666,000 megawatt hours (MWh), although the actual annual capacity will depend on a number of variables, including weather conditions, operational and maintenance issues, final design, site-specific features, and equipment.

The Project will be located within a 50 square mile area northwest of the City of Albert Lea in northwestern Freeborn County, in four townships (Hartland, Manchester, Bath, and Bancroft).  Those townships are zoned agricultural, except for incorporated towns in Hartland and Manchester Townships.  Towers will not be located in incorporated areas.


Procedural History

1.                  On November 6, 2007, WPL filed a request with the MPUC for an exemption from certain data requirements in connection with a CON application that the Company intended to file.[1]  The Department of Commerce’s Office of Energy Security (OES) recommended that the Commission grant the exemption in part and deny it in part,[2] and on January 17, 2008, the Commission issued an Order granting WPL’s request for an exemption to the extent recommended by the OES.[3]

2.                  On June 27, 2008, WPL filed a CON application for Phase I of the Bent Tree Wind Project, consisting of a 200 MW wind generation facility and an 18-mile 161kV radial line to connect the Project to the transmission grid.[4]

3.                  On August 22, 2008, WPL filed a revised site permit application with the Commission for a proposed 400 megawatt Bent Tree Large Energy Conversion System project in Freeborn County.[5]

4.                  On August 27, 2008, the Commission issued an Order accepting WPL’s CON application as complete, contingent upon compliance filing, and also approving an informal review process.  That Order also requested the Office of Administrative Hearings to conduct a public hearing to take public testimony concerning the CON application.[6]

5.                  On September 16, 2008, the Commission accepted WPL’s site permit application as complete and made a preliminary determination that a draft permit could be issued for the Project.[7]

6.                  Thereafter the Commission received requests for contested case hearings in connection with both WPL’s CON application and its site permit application.  By an Order issued on March 24, 2009, the Commission denied the request for a contested case hearing on WPL’s site permit application; that Order also ordered a public hearing on issues relating to siting and permitting to be held in conjunction with the public hearing that it had previously ordered for WPL’s CON application.[8]

7.                  By an Order issued on April 9, 2009, the Commission also issued an Order denying the request for a contested case hearing in connection with WPL’s CON application.[9]

8.                  On July 30, 3009, the Public Service Commission of Wisconsin issued a Final Decision approving WPL’s application to construct, own, and operate the 200 MW first phase of the Bent Tree Wind Farm.[10]

Hearing Notice and Public Comment Process

9.                  On June 22, 2009, WPL served a Notice of Public Hearing giving advance notice of the public hearing to parties on the service list, interested persons, landowners, and governmental units.[11]  On June 26, 2009, WPL filed an Affidavit of Publication of the Notice of Public Hearing.[12]

10.             The undersigned ALJ conducted the public hearing on June 29, 2009, at 2:00 p.m. and continuing at 9:00 p.m. at the Freeborn County Government Center, 411 South Broadway, Albert Lea, Minnesota.  Approximately 30 members of the public appeared at the public hearing.  21 members of the public offered testimony about the proposed transmission line and related issues.  After the hearing, the record remained open for fifteen days to allow all interested persons to submit written comments.  Thirteen written comments were filed by members of the public.  The record was closed on July 14, 2009.

11.             The Commission will issue an order on WPL’s applications for a site permit and a Certificate of Need after examining this Summary, the hearing transcripts, all written filings submitted by the public, and all filings and argument submitted by WPL, the Minnesota Departments of Commerce, Natural Resources, and Health, and other persons and entities interested in this matter.


Summary of Public Testimony

Tricia DeBleeckere, a staff representative from the MPUC, explained that the Commission is the final authority in determining whether to issue both the site permit and the CON.  She indicated that the MPUC had ordered an informal review of the Certificate of Need in August, 2008, that this public hearing was part of that review, and that its purpose was to obtain the public views on WPL’s applications.  Ms. DeBleeckere stated that the PUC will make a decision on the WPL’s applications after receiving the ALJ’s report summarizing testimony at the public hearing.[13]

Larry Hartman, the Project Manager assigned to the Project by the OES, discussed the OES’s responsibility for conducting and processing WPL’s site permit application and for conducting an environmental review on the Company’s CON application.  Mr. Hartman indicated that the OES had previously held two informational meetings on the Project, as well as “scoping meetings,” to obtain public comments on the issues to be addressed in the environmental report.  During the course of those meetings, the OES had received 28 public comments. Mr. Hartman also noted that a white paper prepared by the Minnesota Department of Health (MDH) had been included in the OES’s environmental report.[14]

The environmental review performed by the Department is summarized in a document entitled Environmental Report: Bent Tree Wind Project.[15]  The Environmental Assessment is a general document discussing the potential human and environmental impacts of the Project, as proposed, as well as any alternatives to the Project.  The Department also assessed possible mitigation of potential adverse impacts of the Project.

Arshia Javaherian, a regulatory attorney with Alliant Energy Corporate Services, Inc., offered a brief history of the application process and provided background on the need for the Project.  Mr. Javaherian indicated that the Project is a response to a State of Wisconsin’s renewable energy mandate requiring WPL to produce 10% of its energy from renewable energy sources by 2015.  The entire Project site is large enough to accommodate 400 megawatts generated by over 200 turbines.  WPL is proposing the wind farm in two phases.  The first phase will involve constructing about 120 wind turbines and infrastructure with a capacity of about 200 MW.  The site permit application allows for the possibility of a 400 MW wind farm with over 200 wind turbines in the event that WPL decides to proceed with a second 200 MW phase.  Since the current CON only contemplates a 200 MW wind farm, it would be necessary for WPL to submit a second CON application in order to develop the second 200 MW phase.  Mr. Javaherian indicated that although the wind farm will be located in Minnesota, it will be owned and operated by a Wisconsin utility and will be “paid for and created by Wisconsin customers.”  Moreover, the energy will be sold into the Midwest Independent Transmission System Operator (MISO) grid and used within the “footprint” area. [16]

Dick Swanson asked why WPL had not sought a CON for the full 400 megawatts in the current application process.  Mr. Javaherian explained that the difficulty in applying now for a CON for a 400 MW Project was that it would have involved trying to establish a need for an amount of energy that exceeded WPL’s current needs.  To avoid that difficulty, WPL only filed an application for half of the site’s potential capacity.  Mr. Javaherian also noted that there are time limits on a CON and that WPL needed to ensure that it would be able to proceed with the first phase in the event that there were problems during construction.  Mr. Swanson also inquired about how the Project would be financed and whether WPL would have to seek funding in the capital markets.  Mr. Javaherian replied that WPL’s parent company, Alliant Energy, sufficient the financial resources to develop the Project, and that there were no plans to sell bonds to fund the Project. Jana Grimm from WPL stated that Alliant remains in a good credit position and does not expect any problems in obtaining financing.[17]  Later during the public hearing, Mr. Swanson expressed his support for the Project and emphasized the favorable economic impact the wind farm will have in the Albert Lea area.  While acknowledging the right of those opposing the project to express their disapproval, he also pointed out that there were a number of individuals who supported the Project who were not present at the public hearing.[18]

Francis Pfefser expressed concern about whether the Bent Tree wind farm would tie up Minnesota wind rights for a Wisconsin company and customers and therefore whether it would impact the ability of Minnesota utilities to meet this state’s renewable energy requirements.[19] In response, David Engels of WPL indicated that WPL had already built and was operating wind farm in Fond du Lac County, Wisconsin, and that the Company was evaluating other Wisconsin sites.  However, WPL has concluded that there are insufficient wind resources in Wisconsin to allow it to meet that state’s requirements for renewable energy generation.[20]  Mr. Hartman added that Minnesota will likely need at least another seven to eight thousand megawatts in renewable energy to meet Minnesota’s standards, depending on future growth assumptions.  He indicated that improvements in technology are likely to improve Minnesota’s capacity to produce wind energy.  Additionally, Minnesota utilities are also building wind farms in North and South Dakota in order to serve their customers and meet Minnesota requirements because the Dakotas have even better wind resources than Minnesota does.  In this context, Mr. Hartman indicated that Minnesota was not “giving away” wind energy resources that it will need to meet its own requirements.  He also believed that it was “probably more economical for WPL to develop wind [energy resources] in Minnesota than in Wisconsin.”[21]

Carol Overland, an attorney for Safe Wind Freeborn County, questioned the MPUC’s use of the informal review process in connection with WPL’s applications.[22] Ms. DeBleeckere replied that the PUC has been using the informal review process for other wind projects, including 100 MW projects and larger ones.[23]

Ms. Overland also sought clarification of the business relationships between the various entities involved in the Project.[24]  In response, Mr. Javaherian explained that Alliant owns both WPL and Interstate Power and Light (IPL), and that WPL’s service area is exclusively within Wisconsin, and that IPL’s service area is in both Iowa and Wisconsin.  There is no relationship between Alliant and its subsidiaries and ITC Holdings, which is a Michigan corporation that owns the transmission lines in Southern Minnesota.[25]  Ms. Overland also asked about the extent of Wind Capital Group’s (Wind Capital) involvement in the financing of the Bent Tree project.[26]  Mr. Javaherian and Mr. Engels responded that Wind Capital had previously been involved in the Project, but that it was a development agency that WPL had hired to represent its development interests with landowners in the area, and that Wind Capital was no longer involved with the Project.[27]

Dean Otterson talked about his interactions with a Wind Capital representative, stating that the representative assured him that there would be compliance with setback requirements. Mr. Javaherian confirmed WPL’s compliance with the state requirements. Mr. Otterson expressed his dissatisfaction with the manner in which the Wind Capital representative had informed him about the setback requirements and how it would impact his home and farm property.[28]

Mark Anderson asked when the appropriate governing body would approve one of the three transmission line options.  Mr. Javaherian responded that the Freeborn County Planning Commission favored the two more southerly routes, but that the Freeborn County Board of Commissioners would make a decision on the route after the MPUC made a decision on the CON.  He also indicated that the County Board would be providing additional opportunities for landowners to express their opinions on the route.[29]  Mr. Anderson also asked about the precautions WPL would be taking to avoid disrupting underground field draining tiling.  Mr. Engels responded that WPL uses the open trench method of excavation in order to determine whether or not the construction crew might hit drainage tiles.  Mr. Engels also stated WPL also had engaged a reputable local tile contractor to accompany WPL’s construction crews.  He added that the company’s crews would also take GPS coordinates of tile breaks and would repair the tile before the crew backfilled the trench.[30]  Finally, Mr. Anderson inquired about the structure of the power line.  Mr. Javerhian replied that WPL will use single pole structures, and that there would be negotiations about whether the power line would be located on private property or on public easements.[31]

Bernard Hagen asked whether WPL had engaged in eminent domain proceedings or had obtained other permission to use the last three miles on the ITC line.  Mr. Javaherian reported that WPL was still negotiating with landowners, but that negotiations could not be completed until after WPL’s applications were approved.  However, Mr. Javaherian indicated that WPL felt confident about being able to reach agreement with property owners.[32] Mr. Hagen also asked how he personally would benefit from WPL building a wind farm in Freeborn County to meet Wisconsin renewable energy requirements.  Mr. Javaherian replied that Minnesota has a good wind resource and that Freeborn County would benefit from tax incentives related to the wind farm.[33]

Mr. Hagen then asked how the production tax worked. Mr. Javaherian explained that the tax is a credit per kilowatt of energy produced, with the money flowing from WPL to Minnesota state government.  After it was collected, the state would then redistribute the money to the county.  The county would receive 80% of what the state collected, and townships would receive the other 20%.  Mr. Hartman indicated that a project like this could pay an annual production tax of approximately $1.2 million per year, assuming a 38, 39 percent capacity factor.[34]

Finally, Mr. Hagen indicated that he had developed tinnitus, or ringing in the ears, while in the Army.  He indicated that he had met with his doctor to learn whether the wind turbines would affect his condition.  Mr. Hagen stated that his doctor told him that living in close proximity to a wind turbine would aggravate his tinnitus and adversely affect his health; he then submitted a letter from his doctor for inclusion in the public hearing record.[35]

Ms. Overland questioned WPL’s data relating to Wisconsin’s Renewable Portfolio Standard (RPS) requirements.  She noted what she believed was a discrepancy between a statement on page twelve of the Certificate of Need indicating that WPL’s demand for power was increasing and information on the 10-K form indicating that demand is currently below 2004 levels and has been declining after an upward trend ended in 2005.  Mr. Javaherian responded that the data on the 10-K represented all of WPL’s power sales in 2004, including wholesale and bulk power sales.  Since Mr. Javaherian was not personally involved in the calculations, he was also uncertain whether wholesale power sales have increased in recent years.[36]   Mr. Javaherian went on to explain that WPL was calculating demand by forecasting sales going forward. He indicated that it was necessary to use forecast numbers because of the incremental and extended construction process.  He stated that WPL uses the forecast to determine what the future demand is likely to be, with the RPS then constituting a percentage of that figure.  Mr. Javaherian also clarified that the calculation process includes both subtracting fossil fuels and adding other types of energy generation, including other types of renewable energy sources.  WPL uses an Electric Generation Expansion Analysis System (EGEAS) program to assess future needs.  The Company updates its EGEAS analysis at least yearly and uses it to determine its energy generation needs and its renewable portfolio.[37]

            Ms. Overland also questioned WPL officials about “shadow flicker” from the turbines and sought assurances that if residences are in the “zone of impact” for flicker, that the company will consider alternative turbine locations.[38]  Siting standards for wind turbines indicate that shadow flicker is generally not noticeable beyond about ten rotor diameters from a turbine, and Mr. Engels expressed his belief that that was a “very safe statement.”[39]  Mr. Engels also indicated that WPL had already done a lot of work on shadow flicker mitigation, including traveling throughout the proposed site, assessing the effect of the flicker on specific residences, and in some cases moving turbine locations.[40]  

Ms. Overland then offered for the public hearing record a partial transcript of testimony in a prior proceeding before the Environmental Quality Board concerning the annoying nature of low frequency noise as evidence to support an objection to any variance of setback requirements.[41]  Mr. Javaherian responded that the Company had removed its request for a variance from its application in a prior proceeding before the MPUC.[42]  Mr. Rovino of WPL assured Ms. Overland that WPL is following all state and local standards for setbacks—namely, at least 500 feet from residences and 250 feet from township roads.[43]

Ms. Overland then outlined a number of conditions that Speaking for Safe Wind Freeborn County (Safe Wind) was asking the MPUC to impose on the Bent Tree project as conditions of approval.  Safe Wind is seeking setbacks from residences of at least 1,500 feet and a sufficient setback from roads to lessen the chance the turbines might fall and block the roads.  Safe Wind is also seeking sound mitigation through setbacks and other measures.  The organization also desires flicker mitigation by requiring a ten-rotor diameter setback.  Finally, because Safe Sound believes that sound from turbines particularly resonates inside homes, it was also requesting that the site permit require regular sound testing at property lines and inside the homes.[44]  In response, Mr. Javaherian stated that WPL would meet or exceed all state and local requirements and rules and would be working with the PUC, the OES, and landowners to ensure that WPL was complying with all applicable standards.”[45]

            Cheryl Hagen stated that she and her husband live on acreage in northwestern Hartland Township and that a turbine will be located within 1,000 feet of their acreage on one side, as well as others across the street. She expressed concern that after 30 years and as they were about to retire, she and her husband would have to leave their home.  They were frustrated about their apparent lack of control over what has been happening since 2003.[46]

            Katie Troe, another representative of Safe Wind, expressed concern about the Bent Tree Project and offered a packet of documents dealing with the adverse effects of wind turbines for inclusion in the public hearing record[47]  Ms. Troe suggested that in the past, the PUC had not adequately considered the effects of having a large wind farm in close proximity to dwellings and building sites.  She was pleased that the Minnesota Department of Health (MDH) appeared to have taken Safe Wind’s concerns about the potential health effect of wind turbines seriously, and she expressed the hope that during the approval process for the Bent Tree Project, the PUC would begin to address concerns over the effects of noise and shadow flicker in permit conditions.[48]  She remarked that her “hope for Minnesota is that we will be at the forefront of science and innovation, while at the same time moving forward with respect and consideration for those living next to wind projects.”[49]

Ms. Troe summarized the results of her own research on the effects of wind turbines on nearby human and animal populations.  She concluded that research showed the wind turbine blades displace air and thereby produce a low frequency noise that “contributes to the overall audible noise, but also produces a seismic character which is one of the common complaints from neighbors when they say that not only can they hear the noise, but they can feel it.”[50]  Ms. Troe also cited studies that found that the percentage of people annoyed by noise from a wind farm increases more rapidly than with stationary noises once the noise levels exceed 35 decibels.[51]  She indicated that one study found that the reaction of individuals exposed to wind turbine noise represented an “intrusion into [the] private domain,”[52] and she quoted another study that reported that while people can adjust to certain noises, wind turbine noise is different because of its “pulsating nature, varying harmonic[s], and low frequency components,” all of which continue long term without abatement.[53]

            Ms. Troe went on to cite a report from the United States Air Force Institute for National Security Studies that found the “transmission of long-wavelength sound creates biophysical effects” and a National Research Council study indicating that the “effects of low frequency vibration and noise less than 20 hertz on humans are not well understood, but have been asserted to disturb some people.”[54]  Finally, Ms. Troe also referred to the conclusion in MDH’s White Paper[55] indicating “aerodynamic noise” from wind turbines may be “underestimated” in the project planning stages because developers measure wind speed at ten meters above ground level, whereas in some areas the wind speed near the top may be much faster than the ground level measurement.[56]  The White Paper also noted that low frequency noise is generally not heard well beyond a half mile.[57]  On the other hand, the terrain, buildings, and varying wind conditions may cause “aerodynamic modulation” and thus cause wind turbine noise to be heard at greater distances.[58]

Additionally, Ms. Troe cited a World Health Organization recommendation that nighttime and late evening hour sound levels should be under 30 decibels to safeguard children’s health.[59]  Ms. Troe also cited a report that noted that low frequency noise does not decrease with distance, is not mitigated by common building designs, may resonate inside a room’s loud points, may be picked up better by the elderly, and may cause lightweight elements of a building to vibrate.[60]  In one study that Ms. Troe cited, students expressed the same annoyance level with wind turbine noise at low A-weighted sound pressure levels as other sources of noise, such as motor vehicle traffic noise.[61]  Based on the studies that she had read, Ms. Troe expressed the belief that low-frequency noise is significantly strong to warrant immediate concern and that low frequency noise may be more severe than other types of community noise.  Ms. Troe believed that the studies that warned of problems with new turbine technology and those that recommended considering wind turbine noise emissions as environmental noise pollution had not been considered in the past., despite the data on the physical, mental, and behavioral effects of wind turbine noise.[62]

            Finally, Ms. Troe proposed measures in siting wind turbines that could minimize noise impacts.  Those measures could include instituting a moratorium on the installation of large wind turbines until test trials assess the noise produced.[63]   They could also include a wind turbine setback of 1.5 kilometers (or about one mile) from residences, an “immediate and mandatory minimum buffer of two kilometers” between a human dwelling and a large wind turbine, and “greater separation from a dwelling for a wind turbine with greater than two megawatts installed capacity.”[64]  Ms. Troe advocated establishing “a multi-disciplinary team of experts independent of the wind industry to…investigate the health impacts on people where industrial wind turbines have been located too close to their dwelling.”[65]  Ms. Troe also advocated the use of a method used by other countries for establishing sound level limits.[66]

In response to Ms. Troe’s comments, Mr. Javaherian indicated that WPL was obliged to comply with the siting rules adopted by the MPUC, and he further indicated that all of the turbines that are currently being designed for the Project and being arrayed meet or exceed the siting requirements in Minn. R. 7836.[67]

Dr. Carl Herbrandson of the Department of Health clarified aspects of the Department’s White Paper.[68]  He indicated that MDH was not recommending that additional noise testing should be done for the Project because at this point noise testing would occur too late in the process for this Project to be effective.[69]  Rather, he expressed the opinion that modeling would be the more appropriate approach because it would “come up with the information on what to expect your exposures to be” after which the state and local authorities and citizens could make decisions on the acceptable levels.[70]  Dr. Herbrandson also clarified that MDH had not made any specific evaluation of the Bent Tree Project, and that the White Paper had not been directed at that particular project but rather at developing a general process and at setting the framework for future processes.[71]

Stan Stocker asked the OES how many wind turbines had already been sited and how many complaints the OES had received about them.  Mr. Hartman responded that Minnesota already has about 1,900 MW of wind energy, the fourth highest amount in the country, and about 2,000 turbines in the OES database.  Mr. Hartman also indicated that the OES permitting process does include a complaint report procedure, but that the agency had only received a handful of complaints in 14 years, and none of those complaints had involved turbine noise.[72]

Gene Smith understood that Iowa landowners who had wind turbines on their land had to sign an agreement not to discuss any problems they encountered, and he wondered if that was the reason why the OES had not received any complaints.  Mr. Hartman reiterated that there was a complaint process in Minnesota that had produced no complaints about wind turbines. He also said that in the course of his many informal contacts with landowners, he had never heard any verbal complaints.[73]

Helen McNamara stated that her husband had talked to a town supervisor in Grand Meadow Township near Dexter where a wind farm had been developed.  That supervisor had indicated that truck traffic during construction had obstructed traffic on town roads.  Mr. Hartman replied that he was familiar with what had happened in Grand Meadow Township, and that one of the problems had been that the project developer had had to resurface the roads because the township had not adequately maintained them.  He also stated that the Company would be liable for any damage that it caused to the roads.[74]  Thereafter, Ms. Overland recommended that OES and the Company make a greater effort to ensure that township officials be given the opportunity to attend preconstruction meetings with the contractors.[75]

Dick Swanson re-emphasized the favorable economic impact that the Project on Freeborn County and its residents.  He estimated hundreds of millions of dollars in payments would flow into the community over a 40-year period, and with the multiplier effect, the economic impact on the area would be very large.[76]

Marie McNamara expressed her concern about the apparent secrecy surrounding the development of wind projects in southeastern Minnesota.  She was also concerned about the possible effect of stray voltage on farm animals[77]  Mr. Rovino responded that he was unaware of any studies indicating that stray voltage from wind generators had an adverse effect on animals.[78]  Mr. Hartman indicated that when Minnesota began developing wind resources, a four- or five-year study was done on the impact of wind turbine on birds and a two-year study of the impact on bats.  The study on birds indicated only a minimal number of bird fatalities that could be definitively attributed to wind turbines.  However, the study on bats documented about 80 to 150 bat fatalities in the two-year period that were attributable to wind turbines.[79]  Mr. Hartman also indicated that early wind turbines were constructed in a way that allowed eagles to perch on them, and that there was some eagle mortality.  However, that problem has been rectified by current wind turbine design.[80]

It was the opinion of Kristine Johnson that the low incidence of eagle mortality resulted from eagles avoiding wind turbines by relocating to more hospitable habitat, and that the studies of bat may have understated actual mortality.  More generally, Ms. Johnson expressed concern that current setback requirements do not allow people to be a safe distance away from the noise that wind turbines produce.[81]  She also expressed concern about blade flicker.[82]  In response, Messrs. Javaherian and Rovino provided Ms. Johnson with a detailed explanation of how WPL had used acoustic modeling studies to establish its minimum setback requirements for residences.[83]  Finally, Ms. Johnson later submitted a copy of a newspaper advertisement in which a Wisconsin landowner discussed problems that he had encountered in allowing a wind turbine to be located on his land.[84]

In response to a question from Mr. Hartman, Mr. Engels indicated that WPL was planning to start Phase 1 at the southern half of the site and then build to the north until it had 122 confirmed turbine locations.  The northern portion of the site would then be reserved for future development in a Phase 2.[85]  Mr. Engels also estimated that there were between 300 and 325 landowners within the Project boundaries and that 226 of them were participating in the Project.[86]

In response to a question from Jason Jacobusse, Ms. DeBleeckere stated that MDH’s white paper, which was incorporated into the Environmental Statement as Appendix D, would be among the document reviewed by the Commission in making its decision on the permit application and on any conditions imposed on the applicant.[87]  Mr. Jacobusse later asked about WPL’s response to the results of MDH’s white Paper.  Mr. Javaherian responded that WPL had already responded by establishing 1,000-foot minimum setback requirements for residences in comparison with the 500-foot minimum in current standards.[88]  Mr. Hartman further indicated that a number of variables would be involved in determining the siting of each wind turbine, but in every case the setback would have to meet MPCA standards.[89]

Allan Raynan inquired where the transmission line would be located with reference to property that his wife owned.  Mr. Javaherian reiterated that three routes were being considered, and that the Freeborn County Planning Board had recommended that one of the two southern routes be selected, but that the County Board had not yet made a final decision.[90]

Citing a number of examples, it was the opinion of Peter Reinarts that the Environmental Report for the Project and the data on which it was based were inadequate.[91]  Mr. Reinarts also expressed concern that the report did not address all of the possible alternatives.  In response, Mr. Hartman indicated that the Environmental Report was intended to be a general document, and not a detailed one.[92]  Mr. Reinarts later asked whether WPL would act on MDH’s recommendation to upgrade the PCA’s rule on setback standards.  Mr. Javaherian indicated that no decision had been made.[93]

Scott Ryan expressed a number of the concerns about the Project that other speakers had raised.  Specifically, Mr. Ryan stated that he and his wife had been given agreements by other wind resource developers that contained nondisclosure agreements.  Mr. Hartman advised Mr. Ryan to get satisfactory answers to all of his questions from a wind developer before signing an easement agreement.[94]  Mr. Ryan also expressed concern that the existing setback requirements would be inadequate to prevent noise problems.  Additionally, he was concerned that stray voltage carried by ground wires would interfere with the milk production of his dairy cows.  Mr. Hartman explained that stray voltages are normally a problem with local distribution systems that have grounding issues.  It was his belief that stray voltages should not occur with a wind farm.  For the most part, wind farms are grounded properly and only interconnect to a high voltage distribution grid.[95]

Dana Christiansen commented that he had been close to operating wind turbines and had not detected a noise problem.  He also believed that there were not many dairy cattle in Freeborn County.  Mr. Christiansen does raise horses and believed that his horses might initially be scared by the sight of a rotating wind turbine, but that they would eventually get used to it.[96]

It was Marvin Christiansen’s opinion that the Project would be good for Freeborn County because of the tax revenues it would generate.[97]

Finally, Katie Troe asked Dr. Herbrandson why wind turbines are noisier at night.  In response, Dr. Herbrandson indicated that unstable atmospheric conditions during the day tend to result in the same wind speed at the top of the turbine blade rotation as at the bottom, which minimizes noise. However, at nighttime, the relative calm tends to cause a high speed at the top of the rotation and a low speed at the bottom, which produces noise.  Whether that phenomenon causes a noise problem depends on what the setback is.[98] 

Summary of Written Comment

After the public hearing, Dr. Herbrandson submitted a written comment responding to a question from Mr. Hartman about whether the noise analysis in the noise assessment for the Blue Sky & Green Field Wind Project was the type of analysis that MDH was recommending in its White Paper.  Dr. Herbrandson stated that he found the noise estimates in that report to be reasonable, but that he would want to validate the calculations that were made before relying on them.  He continued by stating that one way to quantitatively evaluate wind turbine noise is to use the current Minnesota dB(A) standard.  However, MDH believes that this may underestimate the potential impacts of wind turbine noise when compared to application of that standard to other noise sources.  It was Dr. Herbrandson’s further opinion that monitoring of potential dB(C) exposures would provide another measure of wind turbine noise that could be used to help determine appropriate wind turbine project setbacks.  MDH is recommending that dB(C) models include sound contour mapping in order to provide information for communities and regulatory agencies that can be used to guide siting decisions.[99]

Melvin Hobbiebrunken commented that the Project was a valid one and that permits should be issued to allow construction.[100]

Francis and Becky Pfeffer are homeowners along the Project’s boundary and expressed concerns about its need, safety, and other factors that would affect the community.  They believe that open land for wind production should be reserved for Minnesota’s energy needs, and that WPL should find ways of meeting its needs in Wisconsin.  They also believed that a minimum setback of 1500 feet was necessary to preserve safety and health.  Additionally, they are concerned that construction of the Project would have a negative effect on the market value of their home.  It is their position that the CON should be denied unless there are conditions requiring wind turbines to e setback at least 1500 feet from residences and requiring WPL to compensate homeowners for home upgrades necessary to mitigate noise, light flicker, and television and radio reception problems.[101]

Jason Jacobusse also submitted a comment urging the Commission to require a minimum half mile setback from human dwelling and from the property lines of non-participating property owners.[102]

Peter Reinarts submitted a written version of the testimony he gave at the public hearing.[103]

Amy Wasson is an attorney for Safe Wind and submitted written comments on behalf of that organization.  It is Safe Wind’s recommendation that the Commission deny WPL’s requests for a CON and site permit unless certain specified changes are made to the Conditions currently set forth in Section III of the Draft Permit.[104]

Ann Buck’s family farm is in the footprint for projects being proposed by two other industrial wind companies.  She is concerned that wind farms generally case families to relocate from communities because of health concerns, lower property values, and their visual impact.[105]

Bruce and Marie McNamara submitted written comments that amplified Mrs. McNamara’s testimony at the public hearing.  Although they are residents of Goodhue County and therefore outside the Project boundaries, they are concerned that the accelerating development of wind energy in Minnesota is compromising public health and safety.  They are also concerned about the neutrality of the information that the Commission is receiving about wind project.  Mr. and Mrs. McNamara also submitted a copy of testimony about wind resources that New York’s Deputy Secretary of Energy submitted to the United States Senate Committee on Energy and Natural Resources in March 26, 2009.[106]

Helen McNamara also submitted written comments to supplement her public hearing testimony.  In Ms. McNamara’s view, the problem is not a lack of adequate energy supplies, but our country’s appetite for energy.  She urges the Commission to consider a “no-build” option and deny certification because she believes that the demand for electricity can be met more cost effectively though energy conservation and load management measures.  Ms. McNamara also submitted a copy of an article titled “Living better, but wasting less” for the Commission’s consideration.[107]

Kristine Johnson also supplemented her public hearing testimony with written comments.  She stated that she remains concerned about prolonged exposure to noise from wind turbines, and she believes that models need to be developed for analyzing potential dB(C) exposures before proceeding with the Bent Tree Project or any other wind farm.  Ms. Johnson is also concerned that turbulence caused by wind turbines will limit her potential access to the Mayo Clinic’s helicopter.  Another major concern for her is the possible adverse impact on the U. S. economy of job loss resulting from government subsidization of wind energy, and she included in her written comments excerpts from a report prepared by U. S. Senator Kit Bond.[108]

Katie Troe of Safe Wind also submitted supplementary written remarks.  She specifically requested that the MPUC prohibit the inclusion of nondisclosure agreements in landowner agreements as a siting permit condition, and she included copies of Bent Tree Wind Farm’s “Wind Farm Cooperation Agreements” that Safe Wind had obtained, as well as a copy of “Landowner Guidelines for Evaluating Wind Energy Production Leases” prepared by Michigan State’ University’s Department of Agricultural, Food and Resource Economics.[109]

Adam M. Sokolski, a Business Developer with Iberdola Renewables (IBR), submitted a letter dated and received by email on July 14, 2009.  IBR has approximately 400 MW of wind turbines operating in Minnesota.  Mr. Sokolski expressed his opinion that applying Minnesota’s existing 50dBA standard has worked to limit wind turbine noise emissions in residences in and around wind farms.  He stated that IBR has complied with that standard and has not received any complaints about wind turbine noise from landowners in the vicinity of its projects.[110]

On July 14, 2009, WPL efiled written Post Hearing Comments.[111]  Attached to its submission was data on the Project’s total parcel count, including participating landowners and non-participating landowners, which the OES had requested during the public hearing.  Also attached were non-redacted versions of WPL’s Certificate of Need Application and Site Permit Application.  In its comments, WPL emphasized that it has developed the Bent Tree Project in strict compliance with the MPCA’s Noise Standard rule (Minn. R. 7030.0040), and that is has been running a noise model and has graphically analyzed the results on a sound contour map with the turbines to determine if any residences would experience noise above the MPCA standards.  WPL has also voluntarily designed the wind farm so that there are no turbines closer than 1000 feet to any occupied residence, which in all cases is above the level required by the rule.[112]

 

No other written comments from the public were received.

 

Dated: August 25th, 2009.

 

 

                                                                        _/s/ Steve M. Mihalchick                       _

                                                                        STEVE M. MIHALCHICK

                                                                        Administrative Law Judge

 

 

Reported:       Janet Shaddix Elling, R.P.R.

                        Shaddix & Associates

                        Two Volumes



[10] Ex. 29.

[13] Transcript (Tr.) Vol. I, pp. 7-9.

[14] Tr. Vol. I, pp. 9-10; Exhibits 3-6.

[15] Exhibit 4.

[16] Tr. Vol. I, pp. 12-20. 

[17] Tr. Vol. I, pp. 22-24.

[18] Tr. Vol. I, pp. 128-130.

[19] Tr. Vol. I, p. 25.

[20] Tr. Vol. I, pp. 25-26.

[21] Tr. Vol. I, pp. 27-29.

[22] Tr. Vol. I, p. 29.

[23] Tr. Vol. I, pp. 30-31.

[24] Tr. Vol. I, p. 31.

[25] Tr. Vol. I, pp. 31-32.

[26] Tr. Vol. I, p. 32.

[27] Tr. Vol. I, p. 33.

[28] Tr. Vol. I, pp. 34-37.

[29] Tr. Vol. I, pp. 39-40.

[30] Tr. Vol. I, p. 41.

[31] Tr. Vol. I, p. 42.

[32] Tr. Vol. I, pp. 43-44.

[33] Tr. Vol. I, pp. 46-47.

[34] Tr. Vol. I, pp. 47-51.

[35] Tr. Vol. I, pp. 51-52; Exhibit 8.

[36] Tr. Vol. I, pp. 54-59.

[37] Tr. Vol. I, pp. 61-64

[38] Tr. Vol. I, p. 65.

[39] Tr. Vol. I, p. 70.

[40] Tr. Vol. I, pp. 66-70.

[41] Tr. Vol. I, pp. 70-74; Exhibit 10.

[42] Tr. Vol. I, p. 74.

[43] Tr. Vol. I, pp. 77-78.

[44] Tr. Vol. I, pp. 79-80.

[45] Tr. Vol. I, pp. 81-82.

[46] Tr. Vol. I, pp. 82-83.

[47] Exhibit 11.

[48] Tr. Vol. I, pp. 83-84.

[49] Tr. Vol. I, p. 85.

[50] Tr. Vol. I, pp. 85-86; Exhibit 11.

[51] Tr. Vol. I, p. 86; Exhibit 11.

[52] Tr. Vol. I, p. 86; Exhibit 11.

[53] Tr. Vol. I, p. 87; Exhibit 11.

[54] Tr. Vol. I, p. 89; Exhibit 11; see also Exhibit 4, Appendix D.

[55] Exhibit 4, Appendix D.

[56] Tr. Vol. I, pp. 89-90; Exhibit 11; Exhibit 4, Appendix D.

[57] Tr. Vol. I, p. 91; Exhibit 11; Exhibit 4, Appendix D.

[58] Id.

[59] Tr. Vol. I, p. 92; Exhibit 11.

[60] Tr. Vol. I, p. 93; Exhibit 11.

[61] Tr. Vol. I, p. 94.          

[62] Tr. Vol. I, pp. 95-97.

[63] Tr. Vol. I, pp. 98-99.

[64] Tr. Vol. I, p. 99.

[65] Tr. Vol. I, p. 100; Exhibit 11.

[66] Tr. Vol. I, p. 103; Exhibit 11.

[67] Tr. Vol. I, p. 108.

[68] Tr. Vol. I, pp. 110-113.

[69] Id.

[70] Tr. Vol. I, pp. 110-111.

[71] Tr. Vol. I, pp. 112-113.

[72] Tr. Vol. I, pp. 114-115.

[73] Tr. Vol. I, pp. 116-119.

[74] Tr. Vol. I, pp. 119-125.

[75] Tr. Vol. I, pp. 126-128.

[76] Tr. Vol. I, pp. 120-130.

[77] Tr. Vol. I, pp. 133-140.

[78] Tr. Vol. I, p. 140.

[79] Tr. Vol. I, pp. 142-144

[80] Tr. Vol. I, pp.145-146.

[81] Tr. Vol. I, pp. 157-159.

[82] Tr. Vol. I, pp. 159-160; Exhibits 12 and 13.

[83] Tr. Vol. II, pp. 3-12.

[84] Exhibit 13.

[85] Tr. Vol. II, pp. 12-14.

[86] Tr. Vol. II, p. 18.

[87] Tr. Vol. II, p. 20.

[88] Tr. Vol. II, pp. 56.

[89] Tr. Vol. II, pp. 61-65.

[90] Tr. Vol. I, pp. 22-23.

[91] Tr. Vol. II, pp. 24-32.

[92] Tr. Vol. II, pp. 32-33.

[93] Tr. Vol. II, pp. 66-68.

[94] Tr. Vol. II, pp. 35-47

[95] Tr. Vol. II, p. 51.

[96] Tr. Vol. II, pp. 52-53.

[97] Tr. Vol. II, p. 55.

[98]  Tr. Vol. II, pp. 70-72.

[99] Exhibit 16.

[100] Exhibit 17.

[101] Exhibit 18.

[102] Exhibit 19.

[103] Exhibit 20; see also Tr. Vol. II, pp. 24-35.

[104] Exhibit 21.

[105] Exhibit 22.

[106] Exhibit 23.

[107] Exhibit 24.

[108] Exhibit 25.

[109] Exhibit 26.

[110] Exhibit 27.

[112] Id.