Acciona Deception 08/JUL/2010 ~ Letters To Cape Vincent Planning Board & Acciona Energy RE: Noise Impacts Expected From Acciona's ~ St. Lawrence Wind Complex $ Acciona's Response Letter

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Clif Schneider questions wind company ~ Acciona's Project Development Manager Tim Conboy's suggested sound power levels for wind speeds below 6 m/s, which I requested, were available, but that reliable data were unavailable . How can turbine sound power levels be unreliable for wind speeds of 5 m/s, yet the data for 6 m/s is reliable enough to use in the design their entire wind project?
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  July 8, 2010Mr. Richard Edsall – Planning Board ChairmanMs. Karen Bourcy – Planning Board MemberMr. Andrew Binsley – Planning Board MemberMr. George Mingle – Planning Board MemberMr. Thomas Rienbeck – Planning Board MemberTown of Cape Vincent1964 NYS Rte 12ECape Vincent, NYDear Rich and other Planning Board members:During the April meeting of the Planning Board Acciona and BP's noise consultant DavidHessler gave a presentation on wind turbine noise impacts expected from Acciona's St.Lawrence Wind Farm. This was a special request from developers outside the normalSEQRA process that I presume was in response to previous presentations from theTown's acoustic consultant. I am not writing to criticize the Planning Board's decision toallow Acciona/Hessler's presentation. Rather, I am writing because Acciona/Hessleromitted important information from their presentation, they then ignored subsequentrequests from me and Supervisor Hirschey for that information, and recently admittedthey are withholding the information because they considered the data “unreliable.”In my June 29 letter to Acciona's Blayne Gunderman (see attached) I outlined the issueasserting that Acciona/Hessler omitted important information and misrepresented theirown protocol for estimating background sound levels. As a result, Acciona/Hessler verylikely used an elevated background sound level to design their wind farm. As youshould be aware from Bill Elliot's presentation on May 1, an elevated background soundlevel would allow Acciona to place turbines much closer to non-participants. In addition,if Acciona continues its misrepresentaton many non-participants may be subjected towind turbine noise levels that exceed NYSDEC guidelines.Acciona's Project Development Manager Tim Conboy's suggested sound power levels forwind speeds below 6 m/s, which I requested, were available, but that reliable data wereunavailable (see attached). How can turbine sound power levels be unreliable for windspeeds of 5 m/s, yet the data for 6 m/s is reliable enough to use in the design their entirewind project? Good science dictates the data should have been included and discussedas to why it may have been unreliable, but it should not have been arbitrarily dismissedand hidden. As I noted in my letter to Gunderman, if the appropriate background level islower than Acciona/Hessler maintains, then up to 100 or more residents may have windturbine noise levels that exceed NYSDEC guidelines.  I have a few suggestions about how the Planning Board might proceed: ● Notify Acciona that their FEIS will not be accepted until they havereleased the sound power levels for the AW 82/1500 at wind speeds 3-5m/s. ● Request Bernier Carr and Cavanaugh Tocci to examine the sound powerlevels to determine if low wind speed data are unreliable. ● If low wind speed data are deemed unreliable, then request Accionaconduct additional testing until they can provide data that will permitmore reliable forecasts of wind turbine noise impacts during low tomoderate wind speeds. ● If, on the other hand, sound power levels are considered reliable, thenthe town's engineering consultants should re-examine the analysis todetermine if Acciona/Hessler selected the appropriate backgroundsound levels, i.e., finding the maximum differential between soundpower level and background sound level. The siting of wind turbines in Cape Vincent will be the biggest health and safety issue toface our community, ever. It is absolutely required that noise impacts be properlyassessed prior to construction and installation, and the recent revelation that the windturbine sound levels at low wind speeds are unreliable should be a red flag to boardmembers that you cannot proceed without Acciona addressing the issue.Finally, this letter and request is not submitted through the normal SEQRA process.Acciona/Hessler's presentation was not part of the SEQRA process, nor was JimMadden's recent letter urging the Planning and Town Boards to adopt a 50 dBA noiserestriction. I expect this letter and my request will receive the same courtesy andattention as you gave these wind developers. I look forward to discussing this at yourupcoming board meeting on July 14.Thank you.Sincerely yours,Clif Schneider  St. Lawrence Windpower, LLC P.O. Box 660 ã 122 South Point StreetCape Vincent, New York 13618Tel: 315.654.2210info@stlawrencewind.com   July 1, 2010Clifford P. SchneiderTransmittal by E-Mail OnlyDear Mr. Schneider:In Blayne Gunderman’s absence, I am responding to your letter dated June 28, 2010that was transmitted in an e-mail dated June 29, 2010.The following information, provided to the project by its sound consultant, HesslerAssociates, Inc., addresses your inquiry and expands upon Ms. Gunderman’s e-mail toyou dated May 17, 2010 that responded to your srcinal inquiry:Turbine sound power levels are measured in accordance with IEC 61400-11Wind turbine generator systems – Part II: Acoustic noise measurementtechniques. This standard only requires the reporting of sound levels in the 6 to10 m/s wind speed range, inclusive. The principal reason for this is that turbinesound levels at lower wind speeds, 5 m/s and below, are often difficult to discernand clearly separate from the background level. Nevertheless, they aresometimes voluntarily reported by the test engineer if satisfactory low wind speedmeasurements were obtained during the test. An inquiry has been made to theengineering firm, WINDTEST, that tested the Acciona AW82 to see if they havedata for wind speeds below the required range; however, there is no reliable databelow 6 m/s that can be obtained from WINDTEST for the Acciona 82 m rotorturbine.We have gone to great measures to study the potential noise impacts of the St.Lawrence Wind Farm Project and minimize the probability of a significant adversereaction to the project’s sounds. We have received numerous comments and questionsfrom interested parties and have addressed them, to the extent possible, in ourenvironmental impact statements and project plans. With this in mind and due to thefalse accusations made in your letter, we will not respond to future inquiries from you ifwe feel the issues raised in them have already been satisfactorily addressed.Sincerely,St. Lawrence Windpower, LLCTim ConboyProject Development Manager  C.P.SchneiderJune 28, 2010PO Box 165cpschneid@yahoo.comCape Vincent, NY 13618 June 28, 2010Ms. Blayne GundermanAcciona Energy NA165 Jordan RoadTroy, NY 12180Dear Ms. Gunderman:In a recent conversation with Cape Vincent Town Supervisor Urban Hirschey he indicatedthat Acciona has not yet responded to our requests for information on the sound powerlevels for Acciona's AW 82/1500 wind turbine. It has been six weeks since my initialrequest. By ignoring these appeals it is apparent that Acciona concealed information,mislead our community and proposed a potentially noisy, annoying wind project. Accionaneeds to change its behavior and become more forthright and honest.Earlier this year Acciona made a special request to make a public presentation on the windturbine noise impacts for its proposed St. Lawrence Wind Farm. In that presentationDavid Hessler, Acciona's noise consultant, told us that the design criteria for Acciona'swind project was determined first by choosing a background sound level that has thegreatest differential between the turbines sound power level. Hessler stated the greatestdifferential between background sound and turbine sound power levels occurs at a windspeed of 6 m/s, where background sound levels are 37 dBA. Hessler then added 5 dBA fora project-only sound level of 42 dBA. This predicted project noise added to the 37 dBAbackground sound equals 43 dBA, resulting in a 6 dBA increase in sound level allowed inthe NYSDEC noise guideline. The 42 dBA project-only design criteria is the foundation foryour 53-turbine layout of the St. Lawrence Wind Farm and it is used to establish setbacksfrom non-participating residents that comply with the NYSDEC guideline. In my view thisis the single, most important number for your entire project proposal.In his presentation, Hessler also made a statement that made me question the validity of this single number. Hessler stated AW 82/1500 model turbine is unusual because it is soconsistent in its sound power level, hardly any variation. Hessler's regression of winter-time noise levels on wind speed show quieter background sound levels at wind speedsbelow 6 m/s. That being the case, then it suggests wind speeds below 6 m/s may have thegreatest differential between background sound and turbine sound power levels.Furthermore, it suggests Hessler may not have followed his stated protocol he describedat our public meeting and in your SDEIS. More importantly, it may indicate many morenon-participants will be subjected to wind turbine noise that exceeds NYSDECPage 1
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