Why “Ground Factor” Matters

November 17th, 2019

Minn. R. 7030.0400 is the MPCA’s noise rule, setting standards for industrial noise. It was developed to limit industrial noise, from a noise source on the ground to a “receptor” on the ground. ISO 9613-2 was also developed to measure ground based noise reaching a ground based receptor.

A primary input is the “ground factor” set to address conditions on the ground, the ground effect, between the noise source and the receptor:

While there may be some reflected sound reaching the “receptor” (that is such an obnoxious term for people!), the sound from a wind turbine with a hub height of 300 feet or more! That’s a direct path to the “receptor.” The ground, grasses, corn, trees, buildings, do not get in the way.

The ground factor to be used for wind turbines is ZERO.

Dr. Schomer stated this clearly and thoroughly in the Highland Wind docket in Wisconsin (PSC Docket 2535-CE-100).

The use 0.0 of ground factor for wind is standard practice, and that a 0.5 ground factor is NOT appropriate for wind because it’s elevated. This was inadvertently confirmed by Applicant’s Mike Hankard in the Badger Hollow solar docket, also in Wisconsin (PSC Docket 9697-CE-100):

Who cares? Well, it’s bad enough that in that WI PSC Highland Wind docket, when the applicants couldn’t comply with the state’s wind noise limit, they redid their noise “study” using the inappropriate ground factor of 0.5 to give them more compliant numbers — they moved the goal posts, garbage in, garbage out. They think they can do that in Minnesota too, and are trying oh so hard in the Freeborn Wind docket (PUC Docket 17-410).

Last September, 2018 that is, Freeborn Wind did a deal with Commerce, admitted to in its “Request for Clarification/Reconsideration” pleading:

Freeborn Wind requests the Commission clarify its Site Permit to adopt Section 7.4, as proposed by Freeborn Wind and agreed to by the Department and MPCA, in place of the current Sections 7.4.1 and 7.4.2, to both ensure consistency with the Order and avoid ambiguity in permit compliance.

Freeborn Wind’s September 19, 2018, Late-Filed proposal for Special Conditions Related to Noise outlines the agreement reached between Freeborn Wind, the Department and the MPCA on this issue. (fn. citing Late Filed—Proposed Special Conditions Related to Noise (Sept. 19, 2018) (eDocket No. 20189-146486-01).

In this deal, they put language in the permit that was a fundamental shift in noise monitoring, one for which there is no justification under the noise modeling standards, whether state or ISO 9613-2 — that of using a 0.5 ground factor.

The day before the Commission’s meeting, they filed for a “Special Condition,” and oh, was it special:

At the meeting, they presented a chart with made up numbers on it, not supported by any noise study:

This chart was shown for a few seconds at most, it was not provided in the “Late Filing” above, and there were no copies for parties or the public. Did Commissioners get a copy? Who knows…

The Commission then granted the site permit!!! There were a few rounds before we got to where we are today, with Xcel Energy acquiring the project, and with a new site plan, bigger turbines, and some specific site permit amendments. In its permit amendment application, Xcel Energy is now the owner of Freeborn Wind, and Xcel wants to use larger Vestas V120 turbines rather than the V116.

From testimony in the original Freeborn Wind hearing, and in an Affidavit submitted by Commerce-EERA’s Davis

7.         It is generally understood that turbine noise output increases with higher blade tip speeds… 
Aff. of Davis, EERA Motion[1], 20181-139379-01.[2]

In its permit amendment application, Xcel Energy is now the owner of Freeborn Wind, and Xcel wants to use larger turbines. In so doing, they have filed a noise study, Attachment E below, utilizing that 0.5 ground factor. Xcel’s claim is that they’re using a 0.5 ground factor because the permit specifies that:

THIS XCEL FILING IS THE FIRST NOISE STUDY IN THE FREEBORN WIND RECORD TO UTILIZE A 0.5 GROUND FACTOR.

THIS XCEL FILING IS THE FIRST NOISE STUDY IN THE FREEBORN WIND RECORD FOLLOWING THE ALJ’s RECOMMENDATION OF DENIAL:

There’s a 3 dB(A) margin of error – even using Hankard’s numbers, look at the yellow lines right up against the homes, and look at the blue 50 dB(A) lines and how many homes are inside of those lines:

Turbine noise at the hub for the V120s can be maximum of 110.5 dB(A), and serrated edges provide an option to reduce noise (which Xcel says it plans on using for some turbines), per the Vestas spec sheet:

Compliance? Modeling with the improper 0.5 ground factor doesn’t come close to demonstrating compliance, instead it demonstrates a high probability of non-compliance. It demonstrates that using the proper ground factor for wind, it won’t do the modeling, likely (assuredly) because the project cannot comply. Freeborn Wind could not demonstrate that it could comply with state noise standards as originally designed with the smaller wind turbines and the proper modeling ground factor, and now Xcel Energy wants to use larger turbines. Larger turbines are noisier… once more with feeling:

7.         It is generally understood that turbine noise output increases with higher blade tip speeds… 

And now we see, hot off the press, the Plum Creek wind project (PUC Docket WS-18-700), proposed by Geronimo

Vestas 150 and 162 turbines, 5.6 MW each! The noise for the V150 is a maximum of 104.9 dB(A), and for the V162 is a maximum of 104.9 dB(A), with “sound optimized modes available.” That’s in the brochure:

They have provided a noise study, BUT, much is NOT PUBLIC:

And I wonder why… well, it says that they’re not using a ground factor of 0.0. Look at p. 48 of the sound study above, deep breathe and take a peek:

THEY’RE USING A GROUND FACTOR OF 0.7!

Really…

FALSE!!!

They say it again on p. 62, elsewhere too:

HOW STUPID DO THEY THINK WE ARE?

HOW STUPID DO THEY THINK COMMERCE-EERA IS? …oh… nevermind…

Ayway, here are the sound study maps based on that bogus 0.7 ground factor – look how many homes are affected:

Geronimo gets the gong:

The applicants know exactly what they’re doing.

At least twice in the Freeborn record I have asked whether the Commissioners understand “0.5 ground factor” and “0.0 ground factor” and have been vigorously assured that yes, they do understand. And Commerce-EERA staff? You’re responsible for doing the footwork on these siting applications. Do you understand?

If they do not understand, or misunderstand, they’ve got some learnin’ and edumacation to do. If they DO understand, and are approving site permits knowing that the modeling is off, that ground factor is misused, they’re complicit. They’re knowingly afflicting those who have to live with the noise sound levels that exceed Minnesota state standards.

As we saw in Bent Tree, where the noise standard compliance is in question, it is Commerce’s job to do the noise monitoring and deal with the problem. Once a turbine is up, there aren’t many options other than “shut down the turbines” or “buy out the landowners.” How many landowner buy-outs do you think we need before it’s admitted there’s a problem? Why is it so hard to develop responsible, precautionary, and respectful siting? Why is there resistance? The costs of their failure to do so are… well… we may see exactly what those costs are.

Commissioners and Commerce staff, make sure you know how the state noise standard and ISO 9613-2 was designed, how it is to be used, and what ground factor means.

If you know what it means, and are siting turbines using 0.5 and 0.7, you are responsible.

Our solar on a cloudy day

November 15th, 2019

Is this cool or what?!?!?!

We can’t figure out what those big short spikes are, toaster was only used once. Furnace blower is the flat spikes every 20-30 minutes or so. What is it???

Later in the day, the sun came out, although this time of year, we’re below the bluff so it’s not direct:

That little spike mid-day was my little space heater here in the office, which I turned on for a minute or two to see what it looked like. I don’t know what that later spike was. And now the sun is way below the bluff, headed down. This looks pretty good considering that this is not an ideal location for solar.

PJM’s 3Q State of the Market

November 14th, 2019

Here ’tis:

And dig this, from Introduction, p. 3, seems PJM is attempting to manipulate the market, and that’s not flying with Market Analytics, the entity that does the State of the Market reports:

… and this, also p. 3, decreasing revenues is putting it mildly:

This report bears reading, I know, in spare time, but this is REAL NEWS!

Talon Nickel USA has filed with the DNR to rebore/reuse existing exploratory borings, from 2015, near Tamarack, MN.

But it looks like they’re hanging their hat, and a lot more, on this project. A recent press release:

Talon Metals Update: Strategic Importance of the Tamarack High Grade Nickel-Copper-Cobalt Project to the Future of Transportation in the U.S.A.

And an even more recent press release, within the last week:

Talon Metals – Advancing the Tamarack Project: Upcoming Work Program and Initiative to Evaluate Producing Nickel Sulphates for the Battery Market

Here’s a presentation touting this project:

“Securing 21 [st] Century U.S. Supply Chains for EVs and Energy Storage”

A friend lives nearby, we were closer than I thought, and this is on a County Road just north of the planned mine:

With all this talk of Ukraine, and tRump going on and on about Hunter Biden and natural gas in Ukraine, isn’t a bit odd that there’s no talk of tRump and his administration’s dealings in natural gas in Ukraine?

Why has this been buried? Isn’t this the main reason for the Hunter Biden flap?

Profit, not politics: Trump allies sought Ukraine gas deal

From the article:

But the effort to install a friendlier management team at the helm of the gas company, Naftogaz, would soon be taken up with Ukraine’s new president by U.S. Energy Secretary Rick Perry, whose slate of candidates included a fellow Texan who is one of Perry’s past political donors.

It’s unclear if Perry’s attempts to replace board members at Naftogaz were coordinated with the Giuliani allies pushing for a similar outcome, and no one has alleged that there is criminal activity in any of these efforts. And it’s unclear what role, if any, Giuliani had in helping his clients push to get gas sales agreements with the state-owned company.

Trump’s fast-track for LNG by rail collides with LNG projects in Ukraine

And in Forbes on September 30, 2019:

LNG Is The American Aid Ukraine Really Needs

Note tRump’s energy policy isn’t about “independence,” it’s about “DOMINANCE!” Read it here, scroll on down to the very end… LNG!

American Energy Dominance

tRump at Cameron LNG: