PPSA Rebuttal time – due 1/28

December 27th, 2019

An odd notice came out today — an extension of the Power Plant Siting Act Annual Hearing comment period, “due to late-filed materials…”

Late filed materials??? Whatever could that be… SNORT!

Naaaah, more likely than not it’s the Comments I’ve filed in all the related wind dockets, plus the PPSA dockets, regarding “ground factor” an inappropriate use of anything but 0.0 as a ground factor:

That’s all about the many wind projects that are improperly using 0.5 and 0.7 ground factor. 0.0 is the only ground factor because the turbine is elevated, and from the source to the “receptor” it is a DIRECT hit! It’s really not hard to understand.

There are so many projects, ALL of the wind projects listed in this year’s Commerce-EERA handout for the PPSA:

These projects were all permitted using bogus noise modeling with GIGO input assumption of 0.5 or even 0.7 for ground factor!!! REALLY! These:

And these:

Guess somebody is wanting time to rebut! May it means we need a contested case, eh?!?! SNORT!

But then, even developer’s expert Mike Hankard agrees that 0.5 is not appropriate for an elevated source like a wind turbine:

It’ll be interesting to see what they have to say.

To look at the PPSA Annual Hearing docket go HERE and enter docket 19-18, using 19 (year number)- 18 (docket number).


This is really important! I learned, after perusing the PPSA handout from Commerce, that none of the wind projects permitted in 2019, and none of the wind projects currently in the permitting process, are using the proper ground factor of 0.0 for noise modeling. WHAT?

So I put this comment together and filed it:

Needless to say, the PUC had something to say about that… they extended the comment period for the PPSA Annual Hearing!