An Industrial-Scale Wind Turbine Facility on Laurel Mountain Will NOT Offset the Use of Coal and Will NOT Offset Carbon Dioxide Emissions
When we hear that the California-based Enron Wind Corporation has wind projects in Texas, Iowa, Minnesota, Wisconsin, and Pennsylvania, it’s difficult to erase the thought that Enron has “become a popular symbol of willful corporate fraud and corruption” (http://en.wikipedia.org/wiki/Enron provides the facts). Enron was a key player in deregulation of the energy sector. “Before deregulation, there were very few buyers and sellers of electricity. Most power plants were owned by the electric utilities and most of that power was used to serve their own customers. For Enron, then, one of the primary goals for deregulation was to make sure that the owners of the power plants would not be the same as the people who sold electricity to retail consumers… Enron worked hard to ensure that electric utilities would have to buy their power from someone else, thereby creating a market that Enron could broker.” (http://64.233.167.104/search?q=cache:GaqB_jSipGQJ:www.publicutilityhome.com/speeches/E nronPA.pdf+Enron+Wind,+PA&hl=en&ct=clnk&cd=2&gl=us).
Not surprisingly, Enron also lobbied hard to develop a carbon dioxide “cap-and-trade” market (http://www.freerepublic.com/focus/f-news/1813229/posts), which developed into the carbon credit or green energy credit market, also called the renewable energy credit (REC) and a variety of other names. Basically, certificates representing one megawatt hour of electricity produced by non-fossil fuel source such as solar, wind, or hydro, can be sold and traded and the owner of the REC can claim to have purchased renewable energy as an offset to burning fossil fuel. In the PJM service area, over 93% of the renewable energy is comprised of wind projects (https://www.pjm.com/planning/project-queues/queue-gen-active.jsp). In states which have Renewable Portfolio Standards, the electric companies must purchase a certain percentage of electricity from a renewable source or it will be fined (http://www.eere.energy.gov/states/maps/renewable_portfolio_states.cfm). In the case of RECs, government agencies, businesses, and individuals can also purchase these certificates for 1.2 cents to 5.6 cents per kilowatt hour (http://www.eere.energy.gov/greenpower/markets/certificates.shtml?page=0). AES Corporation has a thriving REC marketing program and has taken the additional step of providing a credit card: “The card allows any credit card customer to channel up to 1% of their spending into projects that reduce greenhouse gases.” (http://www.marketwatch.com/news/story/new-ge-aes-carbon-alliance/story.aspx?guid=%7BB8 A6A45A-5EA1-4B27-8A0B-9A9BFB426550%7D). This is certainly enterprising, but a review of how coal plants integrate electricity from wind projects reveals that there is no significant offset of coal usage and therefore no real offset of carbon dioxide. It is essential that the coal-fired boilers used at coal-fired electrical generation plants maintain flame stability (http://www.fwc.com/publications/tech_papers/files/AnthraciteFiring_LargestSteamGenerators.p df ). When the boilers are backed down to accommodate the variable influx of electricity from a wind plant, the flame stability must be maintained at least to 50 percent of their capacity even if the steam cannot be used for that specific period of time. The steam can simply go into the atmosphere or be diverted to another unit, if one is available. When the boilers are heated again sufficiently, this ramping up (equal to acceleration) requires even more coal to be burned than if it were just burned constantly. Therefore, there is essentially no reduction of carbon dioxide due to the introduction of electricity from a wind project. Additionally, all generating facilities are required to have a spinning reserve of electricity that is available at any moment if a power plant ceases operation or a transmission line goes down (http://www.pjm.com/contributions/news-releases/2006/20060501-dr-in-ancillary-services-market s.pdf). The spinning reserve may be compared to leaving your car running in the driveway just in case you might want to drive to the store to buy something. Wind plants are not capable of producing a spinning reserve and the operators of wind plants must therefore purchase the spinning reserve from a reliable source, such as a coal-fired generating plant. This extra spinning reserve required for the wind plant therefore constitutes a requirement for the use of coal. Additionally, wind turbines require electricity from the grid in order to operate their “parasitic loads”, which includes keeping the blades turning when the wind velocity is too low (http://www.psc.utah.gov/elec/06docs/0603542/6-21-07%20petition.pdf; and “Rebuttal Testimony of David K. Friend”, p. 15, PSC Case No. 05-1740-E-CS Liberty Gap Wind Force, LLC). Wind plants simply cannot operate without the use of coal-fired plants and cannot be accurately described as “clean” if the coal back-up is considered “dirty”. Even though the wind is renewable, the requirements for manipulating the coal-fired plant in order to integrate electricity from wind turbines overshadow any small amount of wind power that can be used by the coal-fired electrical generating plant.
Construction of Industrial-Scale Wind Turbines on Laurel Mountain Will Negatively
Impact the Water Resources of West Virginia
The West Virginia Department of Environmental Protection provided its “Final Report, Water Resources Protection Act Water Use Survey” (DEP report) in December, 2006, to the Joint Committee on Government and Finance, West Virginia Legislature. It is explained in this report that: “The Water Resources Protection Act (“Act” or “WRPA”), W.Va. Code §§22-26-1 et seq., enacted March 13, 2004, authorized the establishment of a Joint Legislative Oversight Commission on State Water Resources. The West Virginia Department of Environmental Protection (DEP), the implementing agency for the Act, was required to submit a yearly progress report to the Commission (§22-26-5(b)) and a final report to the Joint Committee on Government and Finance.” It is also stated in this report that: “without the continuation of data collection and analysis as recommended in this report, the state will not have the long term data to responsibly manage its most abundant and vital natural resource: water.”
West Virginia is heavily dependent on groundwater. Surface water and groundwater are totally integrated. The DEP report recognizes that drought is not simply the result of meteorological conditions. Drought can be categorized as hydrological drought, which can occur due to “unsustainable withdrawal and consumptive use rates”. Agricultural drought can result factors including groundwater/reservoir levels and evapotranspiration, in addition to precipitation. The Appalachian mountains are the areas which receive the greatest amounts of precipitation and therefore serve as the most important areas for groundwater recharge and for maintenance of aquatic habitats in the headwaters of streams that support trout and other species. The reduction of groundwater recharge in the Appalachian mountains will ultimately result in drought conditions throughout the watershed.
Laurel Mountain is one of the essential mountain ridges providing groundwater recharge and maintaining unique aquatic habitats in the headwaters for the Tygart Valley River watershed, which is part of the Monongahela watershed. The U.S. Geological Survey and the “World Book Encyclopedia and Learning Resources” provide internet websites showing maps of precipitation amounts throughout the state of West Virginia, stating that, “Rain is plentiful throughout the state. It is the heaviest in the mountains and lighter on the east and west borders”. The DEP report provides that, “Groundwater is extremely important to West Virginia. Because surface water recharge is dependent mostly on groundwater, an understanding of the groundwater resource is imperative. In some areas of the state, utilization of the groundwater resource assures yearround domestic and commercial supplies.” The overhead trees on the Appalachian mountain ridges, such as Laurel Mountain, intercept rainfall so that it gently penetrates the ground as groundwater rather than flowing overland as runoff. This means that 1) the rain will gently fall to the ground and recharge groundwater and 2) the surface flow of rainwater on the ground will be slower than in cleared areas, thereby reducing the velocity and quantity of stormwater drainage. Conversely, in cleared areas, such as those cleared for construction of wind turbines, increased stormwater drainage results in habitat destruction within streams and the consequent death of aquatic organisms, including trout. The watershed headwaters are so important because they create habitats where the food chain begins: the overhead trees provide shaded areas which create conditions suitable for organisms at the bottom of the food chain - primarily insects which shred organic materials to provide organic compounds for flora and fauna downstream. Not only would the AES Corporation clear-cut the forests on the ridgetop of Laurel Mountain, but also in their lease agreements, they have specified developing “water wells and pumping facilities” for the wind turbine project.
Laws were enacted in West Virginia to protect watersheds and all wildlife:
• The Water Pollution Control Act (§22-11-2) is “declared to be the public policy of the state of West Virginia to maintain reasonable standards of purity and quality of the water of the state consistent with (1) public health and public enjoyment thereof, (2) the propagation and protection of animal, bird, fish, aquatic and plant life…” and includes “setting standards of water quality applicable to both the surface waters and groundwaters of this state. The Water Pollution Control Act specifically protects against the loss of any game fish or aquatic life.
• The Groundwater Protection Act (§22-12-2) provides for the protection of groundwater because over ninety percent of the state’s rural population depends on groundwater for drinking water. This Act further recognizes that “West Virginia's groundwater resources are geologically complex, with the nature and vulnerability of groundwater aquifers and recharge areas not fully known.” Construction of the turbine towers includes excavating an area approximately 50 feet in diameter and at least as much as 50 feet deep. This excavation into bedrock requires blasting, which typically causes changes in groundwater flow. Additionally, the material excavated from these foundation areas must be placed somewhere, probably on the hillside. This results in disturbing the headwater habitats and allowing a tremendous threat of sediment entering streams. Storm drainage ditches or ponds, as well as sediment, will cause changes to groundwater flow and will harm stream habitats. Storm water drainage channels greater quantities of surface water at greater velocities to streams. This greater quantity and velocity of water destroys stream habitats.
• The Natural Streams Preservation Act (§22-13-2), which is to “secure for the citizens of West Virginia of present and future generations the benefits of an enduring resource of free-flowing streams possessing outstanding scenic, recreational, geological, fish and wildlife, botanical, historical, archeological or other scientific or cultural values.” Again, the activities associated with excavation and storm water control will negatively impact streams and thereby negatively impact geological, recreational, fish and wildlife, botanical, historical, and archeological values. This Act also provides for preservation of scenic qualities. Registered historical districts and also Civil War reenactment areas on or near Laurel Mountain would be negatively impacted by the view of an industrial-scale wind turbine facility.
• The State Natural Resources Law (§20-2-1), which assigns protection and “ownership of and title to all wild animals, wild birds, both migratory and resident, and all fish, amphibians, and all forms of aquatic life in the state of West Virginia”, such that it is illegal to “kill, destroy,… wound or injure any wildlife”. It is well known that unacceptably high numbers of birds and bats, including endangered species, are killed by industrial sized windmills.
• In 1997, the U.S. Environmental Protection Agency published the approximately 200-page “Volunteer Stream Monitoring: A Methods Manual” (http://www.epa.gov/volunteer/stream/), which emphasizes that watersheds are important because if natural land becomes impervious:
o “Less precipitation is evaporated back to the atmosphere. (Water is transported rapidly away via storm drains and is not allowed to stand in pools.)
o Less precipitation is transpired back to the atmosphere from plants. (Natural vegetation is replaced by buildings, pavement, etc.)
o Less precipitation percolates through the soil to become ground water. (This can result in a lower water table and can affect baseflow.)
o More surface runoff is generated and transported to streams. (Streamflow becomes more intense during and immediately after storms.)”