Sixth Meeting Summary
Wednesday, March 12, 2003
Convenor: Massachusetts Technology Collaborative
Facilitators: Dr. Jonathan Raab, Raab Associates, Ltd. and Suzanne Orenstein
91 people attended the meeting, which began at 9:00 am and concluded at 12 pm. See the attached attendance list.
II. Introduction / Agenda Review
Jonathan Raab welcomed the attendees and reviewed the agenda for the day. The attendees then went around the room and introduced themselves. Dr. Raab then explained that the final meeting summary from Meeting #5 is posted on the website.
Dr. Raab noted that any future meeting would probably take place around the time that the draft EIS is scheduled to come out. He also informed the participants that an online feedback survey would be circulated by email to participants next week, and he asked that everyone fill out the survey and provide candid feedback.
III. Preliminary Screening of Alternative Sites
Lieutenant Colonel Brian Green of the U.S. Army Corps of Engineers opened the meeting with a few brief remarks. In addition to Colonel Green there were four other representatives of the Corps at the meeting: Karen Adams, Chris Godfrey, Larry Rosenberg, and Leo Roy.
Lt. Colonel Green extended his thanks to MTC for hosting the forum and noted that the seven-month dialogue is an endeavor that must be commended. He noted that the Corps shares this commitment to dialogue, and he encouraged attendees to get involved and stay involved while the permit applications are reviewed.
He also noted that there had been a lot of discussion regarding the Corps’ Congressionally-mandated authority. He then briefly reviewed the Corps’ responsibilities in this matter. While this situation is somewhat unique, as there has never been a wind farm of this size proposed before, the Corps’ is using a tested framework for analyzing the request, and that framework is NEPA. NEPA defines the requirements for this permitting process, not internal decisions within the Corps of Engineers. All impacts to the environment and socioeconomic resources must be considered and compared against other alternatives, including a “No Action” alternative. The impact of the proposed project on the public interest is paramount, and all factors relevant to that will be considered, including conservation, economic impacts, aesthetics, fish and wildlife, navigation, recreation, water supply, food production, and the needs and welfare of the American people, among many other concerns.
Colonel Green stated that the Corps has made no decision with regard to this permit and that they are still seeking public input.
Karen Adams then took the floor for the remainder of the morning’s presentations and discussions. She explained that her goal was to briefly review the process for the EIS and then to update everyone on where the Corps is right now in that process. She presented a PowerPoint slideshow, which outlined the screening criteria for alternative sites, proposed alternative sites, and information already available about those sites. She emphasized that the Corps was considering a decision on which alternative sites merit detailed investigation and analysis. The presentation is available here. (Please note, however, that the PPT file is approximately 14 megabytes, which would take several hours to download over a dial-up modem connection. However, it will be available on MTC’s final project CD.)
As Ms. Adams was the only presenter at the meeting, she paused at certain points in her PowerPoint slide show to take questions. She began by reviewing her presentation thru Slide 17: Screening Criteria. The questions she was asked and her responses are presented below.
Does wind really require 20 acres of land per megawatt generated?
That’s the general rule of thumb from the wind industry. This translates into a lot of acres for a project the size of Cape Wind – something like 4,000 acres or more.
Why doesn’t the Corps just define the project purpose as “renewable wind energy facilities” and confine alternatives to that rather than all kinds of renewable energy facilities?
The Corps needs to determine why attention is focused on wind as opposed to other options like solar and biomass. The Corps needs to examine why wind looks like the best way to go right now, and what factors are making other options seem less attractive.
So far the Corps has determined that wind is currently the most feasible renewable energy technology. The reason why applications are focusing on wind generation is that wind has greater potential for larger scale projects.
How does the Corps distinguish between sites with just a 4mph difference in wind speed? If power development is the cube of the available wind velocity then that small a difference might account for a 50% reduction in energy generated. Is the Corps going to look at details of economic viability based on available wind resources?
The Corps is using a wind resource classification of 4 or more as a threshold criteria, which is drawn from handbooks in the wind industry. The Corps won’t be doing strict screening on economic viability of projects at the site screening stage.
Wind and biomass appear to be the most viable technologies, but the last few slides dropped discussion of biomass. Will it be discussed in the next section of the presentation?
Biomass is the next best renewable technology right now, and there has been some discussion of a 150 MW facility, but the only existing ones are 5 MW. Biomass is not quite there yet. Wind is almost certainly the most likely technology at this scale.
I’m confused about the criteria being used to evaluate these sites. It seems that wind speed, water depth, and regulatory constraints are being discussed, but not environmental impacts. Are they not considered part of the criteria?
There is a distinction between screening criteria for alternative site identification and the more intensive review of sites that survive the screening analysis. The Corps’ initial job is to screen sites based on certain criteria to determine which sites may be considered practicable alternatives. Any sites that survive that initial screening would then be examined under a site-specific review, which would focus on birds, fish, endangered species, and the like. This initial process is to see which sites warrant spending that kind of time.
Some sites have such prominent environmental concerns that it would be a component of this initial screening. Cape Cod Bay is designated habitat area for Right whales, for example, so the Corps would take that into consideration. Primarily the Corps is just looking at what is already known about the proposed sites as opposed to doing in-depth studies at this stage.
Did you consider a comparably sized facility of small pods of turbines as an alternative?
If there were a couple of sites that could still be considered one project the Corps would look at that as an alternative. Multiple sites in combination, if they were operated as one project, might be able to meet the criteria being considered.
What is one project? What does that mean?
The standard question is, can the sites be managed as one project? Two wind farms in Maine and Massachusetts would clearly be two projects. Several small wind facilities operated by different entities would also be separate projects, even if they were near each other.
Several of the applications under consideration would add up to 150 MW if combined. When the Corps is considering larger sites, is that based on applications in progress?
Some sites, like the Winergy sites, were not on the table before the Corps when the assessment process began.
Pretty much any site that someone wanted the Corps to examine was looked at.
There have been a number of land based wind projects proposed, ranging from 5 MW to 50 MW. Are all of these projects considered non-reasonable because of the requirement that alternatives must be within 20% of the generating capacity of the primary candidate?
No, anything that is a reasonable alternative will be considered – so far no proposed projects or sites have been screened out because of the 20% guideline. By pegging the range at 200 MW to over 1000 MW we are already looking at potential projects 50% smaller than what’s proposed.
If the definition of commercial scale is 300 MW at a minimum, to get to that range a dispersed facility would have to be huge, on the order of five 60 MW facilities, ten 30 MW facilities, or twenty 15 MW facilities. The thought that one organization would be able to manage all of these many different projects stretches credibility.
It is instructive to look at things the Corps does more frequently, such as maintaining terminals for cargo ships. One of the latest projects to be approved is a distributed network of subsidiary facilities up and down a river, as opposed to upgrading one large facility. Maybe such a distributed system would work well in this situation.
We’re asking for ideas on what sites and options people want to examine as alternatives. The Corps is open to looking at any ideas people have.
At present Barnstable is looking to put up the first wind turbine on the Cape, and it appears that there is a big groundswell looking into wind turbines for other communities on the Cape and Islands. What about a network of wind turbines along the entire ridge of the Cape? Would that be a viable alternative?
Ms. Adams observed that she hadn’t heard that concept before, but that the Corps would be willing to look into it.
Ms. Adams then resumed her presentation and went through the list of sites that the Corps had examined (slides 27 through 42). She then took some questions and comments with regard to the sites.
Is the National Seashore off limits? Truro Island?
Nothing is off limits – the Corps hasn’t contacted the Seashore to see if such activity there would be prohibited.
How much attention is the Corps paying to wind speeds and economic viability?
Right now the Corps is not looking at cost. The only measure being used is the minimum category 4 wind speed, which is taken from wind industry handbooks. Using this standard will give us a sense of what sites are reasonable, and then later we can examine the sites in more detail.
What agency has the responsibility to identify all the possible sites?
The Corps is open to suggestions from anyone as to additional sites that should be examined.
Some new ideas for sites to be examined have come out today. What is the process for collecting these proposals?
Putting wind turbines along the length of the Cape ridge is a new idea. Someone also mentioned using an urban or industrialized harbor, so we can look at that as well. This is the time to submit site ideas. The Corps wants to examine multiple sites, but we need to identify them before they can be considered.
What’s the timeframe for these efforts?
Any new site proposals need to be submitted before the end of this month. The Corps is moving ahead with its analysis, so the window of opportunity is closing. The Corps will also give everyone a chance to submit written comments after the end of this meeting.
Dr. Raab suggested that attendees come up to the Corps representatives at the break to submit any additional proposed sites for examination. Ms. Adams also agreed to review the meeting summary and note the sites identified.
How does time play into the site screening selections? Is the Corps looking only at currently available technology, considering how long review process will take? By the end of the process new sites may be viable due to innovations in wind generation technology and techniques.
The question of what is “reasonably foreseeable” technology is important. The question of AC vs. DC transmission lines is significant because it affects how far offshore wind projects can be sited. As of yet the Corps has not come to any firm conclusions on that issue. We are talking to manufacturers of DC transmission technology and their feedback has not been encouraging, so we’ll take that into consideration. The Corps is not actively considering sites further offshore than current technology allows, as the time horizon for those technologies becoming viable appears to be quite a ways away.
If one of the alternative sites is identified as being the best location, how will the Corps decide who gets to develop it?
The Corps’ job is to decide on the permit for Nantucket Sound site. As part of that process we must consider alternatives to see if any of the comparable alternatives have less of an impact. The only criteria for the identifying alternatives is that someone thought they were a potentially viable site. The Corps is not looking at who will develop any of the sites under consideration. There may be other alternatives, or multiple alternatives, where wind power generation is viable.
The ridge of the Cape is not universally viewed as a promising source for wind power. The Corps might want to check with towns that have land along the ridge before making a decision as to that plan’s viability. For instance, in the town of Dennis, property owners with views of the ridge would probably not accept wind turbines.
Most of the communities considering wind turbines are looking at open space on or near transfer stations. There isn’t a great deal of open space on the Cape any longer. The Corps is definitely taking into account the availability of undeveloped land.
Will the Corps be conducting a mitigation alternatives analysis for these sites?
The Corps will be looking at mitigation alternatives, but that stage is currently so far down the line that the Corps doesn’t currently have a plan as to how the analysis will be conducted. Corps procedures require mitigation for unavoidable impacts and in some cases compensatory mitigation for certain impacts.
All or most towns on Cape have discussed siting wind turbines on or at their transfer stations. Perhaps the Corps should learn the plans of the towns and determine whether or not what towns are doing can be considered an alternative?
The Corps could check into these plans, but they may not be associated enough to be considered as a single project. It is not clear that all of those wind turbines would be connected to the ISO grid. All of those wind turbines would likely be independent, but if the power generated was enough and they were operated as one project, it could be considered a regional response.
It seems clear from your presentation that size of the project is what is driving the evaluation of appropriate sites. Is there any evaluation of the appropriateness of the proposal independent of size? For instance, if the target size was twice as large, it would eliminate even more possible sites, but that doesn’t mean the proposed project is wise or that the eliminated sites wouldn’t be beneficial.
The application received by the Corps from Cape Wind is for 420 MW. The Corps has determined that there is some flexibility in the scale of the project. Although (+/- 20%) is typical in other projects, we are already looking at a range that decreases 50%. The NEPA process requires an analysis of the alternatives that meet the purpose and need for the project under consideration. The Corps can’t change the nature of project applied for.
What role is the ISO-New England going to have in evaluating alternatives?
A separate application is made to ISO-NE and they will make an independent determination.
Will the Corps consult the ISO?
The ISO is not a formal cooperating agency, but the Corps is planning on meeting with them.
I noted that your presentation identified several brownfield sites. Could you clarify, are those sites for biomass or wind projects?
Our efforts were aimed at identifying sites which could be used for renewable energy in general, not for a specific type of project. In some sites, we have looked at wind power potential, regardless of whether the site was proposed as a wind site or biomass or solar site.
The discussion then moved from Q&A to comments from the attendees. Each of the points registered are presented below.
I’ve heard some suggestions that the Corps should back off of projects of this size, and some disagreement about what “commercial scale” means. If we are serious about addressing greenhouse gas emissions we need to make a serious effort to offset emissions at a significant level. The Renewable Portfolio Standard (RPS) creates a strong public policy rationale for sticking with the determination the Corps has made regarding “commercial scale projects” and the MW size range we’re aiming for.
Regarding mitigation, one attendee observed that a previous discussion implied that mitigation efforts were only required for aquatic resources impacted by the project. They wanted to clarify that there are a full range of mitigation requirements, including safety lighting (for aviation and vessels in the water) and avian impacts. Response: All of these areas are options for consideration for the EIS.
Public safety should be one of the key selection criteria.
Based on the presentation it seems that New Hampshire is not being considered for anything other than biomass, yet it’s common knowledge that the wind speeds in the Mount Washington area are very high. With regard to transmission lines, Monroe, NH has a transmission facility that brings significant amounts of power down into New England from Canada, so it should be a feasible site.
The participants then took a 15 minute break.
After the break, Ms. Adams completed her presentation, applying the criteria to each site under consideration and offering topographic maps and a summary of the available information. The questions put to her at the conclusion of her presentation follow.
Relative to transmission constraints, if there is a constraint due to infrastructure now, does that indicate that ISO-NE is not planning to update the infrastructure in the future?
In conversations with the Corps, ISO-NE was not optimistic that there will be any new transmission infrastructure added in the near future. It is important to note that ISO-NE is the manager of system, not an owner. The ISO manages what is built by others. We can ask them what they anticipate will come on the table in the near future, but we can’t ask the ISO to build new capacity.
On one of the site alternatives the description notes that the “Owner is not willing to sell.” Maybe the owner would be open to other arrangements, like a lease?
The Corps will examine those possibilities further.
With regard to the constraints relative to transmission lines, aren’t some European projects looking at DC transmission cables up to 18 miles offshore?
All existing offshore wind generation facilities use AC transmission. To go farther the transmission systems would need to change from AC to DC. The constraints have to do with line losses over distance and additional cost. As noted previously, there is no indication that DC transmission will be a viable technology for wind projects in the near future. There has also been some speculation about super-cooled, super-conducting cables enabling wind farms to be built in the Sahara to power Germany, but those ideas are also not yet commercially feasible.
Has there been any discussion of a wind project in the Buzzards Bay area?
This proposal has just come to the Corps fairly recently. We’re planning on looking at Buzzards Bay, and it will need to be examined in reaction to the Winergy proposal in particular.
I’m confused about criteria. It appears that the preferred site of Cape Wind Associates is the best site – it has all the check marks. If that’s the best site in all of the Northeast for wind energy then I fear for the future of wind energy. It seems these selection criteria were designed by the project proponent. How can other sites be developed when one is so clearly the best?
Advances in technology and timelines affect how these questions will be answered. We’ve already seen Cape Wind’s 170 proposed wind turbines decrease to 130. The Corps will look at all the possible sites in order to evaluate them. While it is natural for conversations to focus on the “best site” coming out of this analysis, these observations and siting criteria are very much tied to a particular project scale. Smaller projects may find other sites that the Corps has ruled out to be perfectly viable for their needs because they are employing a different set of criteria.
We want to emphasize that it is not too late to come up with new sites. The Corps has significant work ahead with no firm deadlines. The door is open for further comments, and we have some time before we decide on the final list of sites we will evaluate.
Maybe some of these criteria are premature. The presentation notes that the maximum wave height is 18 feet. Natural gas and oil platforms have long been built in wave heights higher than that. Buzzards hawn??? tower existed for decades and has survived. Perhaps those limits on wave height are based more on the developer’s economics than on actual technical limitations.
The Jim Manwell presentation from a few meetings back described where wind technology is right now in much detail, so it’s worthy of review in response to this question. Towers can be built farther offshore, but wind turbines have particular characteristics that make their construction much different than that of an oil platform. For example, a radar installation off of the Cape that was built in high waves collapsed some time back and resulted in a great loss of life.
With regard to the no build alternative, does the Corps consider the continuum of potential projects between zero and 130 MW? Can the scale of project be modified, both in the permitting process and during construction? Just because site has capacity does it need to be that big? And I want to ask Cape Wind: Is this the only site you would consider?
A representative from Cape Wind responded: There is no other site we would build on.
Karen Adams continued: The Corps is responding to the permit application for a facility in Nantucket Sound. Under NEPA, the Corps must look at alternative sites. Part of that is comparing the proposed site with other sites. The Corps can’t tell Cape Wind where to build. All the Corps can do is tell them yes or no to their proposed location
This project review is a new world for the Corps of Engineers. It is clear that the Corps is developing criteria for this project as they go along. Borrowing from previous experience makes sense, as a starting point (such as the 20% plus or minus rule of thumb), but to what extent is borrowing from prior experience not relevant in this new situation?
This project is indeed pushing the envelope further than before – there have never been renewable energy proposals for 500 MW facilities. In response, the Corps has not been treating this as a normal project. An immediate EIS was unusual, and the Corps has been providing the most extensive review it can provide, as this is an unprecedented situation.
The 420 MW number -- is that maximum output, or average output?
Power plants are compared based on their capacity, not average output. So the 420 MW number is total capacity.
How many alternative sites do you think the Corps will select for in-depth analysis? One? Three?
Well, the baseline minimum is “No Build”. Beyond that how many sites can vary tremendously – 1 to 6 is not uncommon. There are probably not going to be 8 or 10 sites that warrant detailed review.
In interagency meetings several key criteria were mentioned: the proposal’s original size, water depth, etc. If any one of those factors was not met there would be a “fatal flaw” in that site. Is the Corps still thinking about using that fatal flaw decision rule, could one site not meet a particular criteria yet still remain in the running?
That’s what the corps was looking for feedback on today. Cape Wind did not propose criteria, the Corps did that. How we decide to apply it is open for discussion.
Defining the commercial scale as 200 MW to 1500 MW means that many potential sites for renewable energy projects are eliminated. Listening to the discussion it seems obvious that there’s a great tension regarding the Corps reviewing all the alternatives against these criteria. The 20% rule of thumb is the most prominent example of these concerns.
The +/-20% rule of thumb is just for context -- typically we are looking in that range, but it’s clear that 200 MW to 1500 MW is far beyond +/- 20%. However, it does seem worthwhile to get this issue resolved before we get much further along in this analysis
How would the Corps go about changing the regulatory structure for projects like this one if it’s found to be a bad fit?
The Corps’ permitting authority comes from Section 10 of the Rivers and Harbors Act. The process comes from NEPA, which is very broad – the broadest review process in the federal government, in fact. All agencies use NEPA, and the Corps is going to use NEPA as thoroughly and effectively as we can.
Many in the room are struggling with what we’d like to debate vs. what the Corps is considering. The community would prefer to look at the alternatives in the broadest sense: scale, size, distribution systems, etc. I think the community is interested in much broader debate – there seems to be a tension between what the community wants to do vs. what the Corps is expected to do.
How would the Corps deal with two competing projects for one site?
One can’t be sure, as that has never come up before, but probably the Corps would accept both applications, review them, and then make a decision between the two.
Do Winergy’s proposals change the commercial scale?
Doesn’t matter with regard to the applications under consideration, but there is more substance to consider now that there are more proposals. The Corps now has to think about overall scale for the projects.
If the proposal does get approved, and if Cape Wind is proposing 130 wind turbines, what restrictions are there if later down the line they want to add 200 more? Can the substation on Willow Street handle the energy? Will we need another substation?
We need to look at transmission capacity for both the Cape Wind sites and Winergy sites. It may be that capacity is only there for the MW being proposed. Nothing is prohibiting the permittee from submitting an application to build more turbines, but they would have to go through a process like this one again. The Corps has been told that there is adequate capacity for these projects.
There is a new non-burning technology in California that can supply energy to half of Massachusetts. Does the Corps know about it?
There is an infinite need for renewable energy, and we are anxious to hear about any new approaches. Please send us the information you have about this technology so that we can review it. However, The Corps will move forward examining technology as it currently exists.
As an Ocean engineer, it appears that the Cape Wind specs are somewhat conservative with regard to water depth -- Light towers and oil rigs have a totally different scale and loading structure. The higher the winds are the more bending force is exerted on the monopole. Wind turbines are significantly different than other offshore structures.
How will this process affect future wind permitting processes?
A better approach may exist, but the Corps doesn’t change processes. Hopefully we have all learned from this one.
Why won’t Cape Wind build in Nantucket shoals, which is a little more and a little less than 50 feet?
Jim Gordon’s Responses: Nantucket Shoals has almost double the wave height of Horseshoe Shoal. Horseshoe Shoal is protected so waves are not as high. Those waves can put enormous loads on the wind turbine foundation and the overall turbine. It makes it unsafe to put maintenance crews out there when the wind and waves are that high. Also, there is significant whale activity and seals in that area. There’s a lot of mammal activity around there and more shipping traffic around there.
Actually doing the Cape Wind project will push innovation ahead, and probably increase the likelihood that we can solve the relevant engineering challenges and gain the ability to put wind turbines further out to sea. The Cape – with its extensive maritime legacy – should be able to leverage its expertise and history to become worldwide experts in wind technology, while at the same time getting a lot of energy from a clean, non-polluting source.
If the Corps identifies 3-4 acceptable sites through this process, could the Corps issue several permits consecutively?
Nobody has yet applied for a permit at the other sites under consideration, but they all are potentially permittable. Nothing is stopping people from applying for permits at other sites
IV. Wrap Up
Greg Watson of the Mass Tech Collaborative (MTC) ended the meeting with a few final comments. He noted that this process was not intended to reach any final conclusions, and that the MTC has compiled a final report on the process that will soon be available. The report will be distributed on a new CR-ROM compiled by the MTC with all of the information from the process (presentations, agendas, meeting summaries, etc.) available in a chronological index. Mr. Watson asked the attendees to help him distribute the CD to appropriate outlets and organizations.
He thanked the facilitators, and mentioned again the online feedback survey that will be circulated to participants on Monday and asked everyone to please fill it out so as to provide MTC and the facilitators with information they can use to improve future processes.