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Pamela C. Dodds, Ph.D. Registered Professional Geologist Montrose, WV 26283 THERE IS NO NEED for INDUSTRIAL-SCALE WIND TURBINE F

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Pamela C. Dodds, Ph.D. Registered Professional Geologist Montrose, WV 26283 THERE IS NO NEED for INDUSTRIAL-SCALE WIND TURBINE F Pamela C. Dodds, Ph.D. Registered Professional Geologist P.O. Box 217 Montrose, WV 26283 January 19,2009 Ms. Sandra Squire, Executive Secretary Public Service Commission of West Virginia P.O. Box 812 Charleston, WV 25323 Subject: Case Number 08-2105-E-CS AES New Creek, LLC, Application for a Siting Certificate to Authorize the Construction and Operation of an Electric Wholesale Generating Facility and Related Interconnection Facilities in Grant County, West Virginia I strongly oppose construction of wind turbines on New Creek Mountain in Grant County, West Virginia and I request that you deny the siting certificate for which AES has applied. I oppose this project because: 1) there is no need for the very minimal amount of electricity produced by wind turbines; 2) there are local negative environmental impacts which result from construction and operation of the wind turbines; 3) there are cumulative negative environmental impacts on a regional or ecosystem scale with the construction and operation of industrial-scale wind turbines on numerous mountain ridges along the Allegheny Front in West Virginia; and 4) there are no benefits to the citizens of West Virginia, but rather a tremendous amount of profit for the AES Corporation, including our federal tax dollars which provide the Federal Production Tax Credit to the company. THERE IS NO NEED FOR INDUSTRIAL-SCALE WIND TURBINE FACILITIES Concerning the lack of need for the very minimal amount of electricity produced by industrial-sized wind turbines, we know that over 70 percent of the electricity produced by the coal-fired plants in West Virginia is already transmitted out of the state to neighboring states. Grant County is within the Allegheny Power System (APS) region of the PJM Interconnection regional transmission organization. The APS region covers slightly more than half of West Virginia, two portions of Pennsylvania (the southwest corner, including Pittsburgh, and a northern middle portion), Garrett County and Frederick County (which includes the Frederick and Baltimore areas), Maryland, and portions of north central Virginia. However, the usage of summer peak load provided in the PJM Load Forecast Report provides that this entire APS area constitutes only approximately 6% of the total amount of electricity demand in the PJM zone. Even if industrial-scale wind turbines could provide any useful electricity, there is minimal demand in our region, especially in Grant County, and therefore there is no need for the industrial-scale wind turbine facility proposed by AES in Grant County. In response to my question submitted on March 4,2008, to APS concerning whether there are any plans to retire generating plants, I received an e-mail stating, "No, Allegheny doesn't plan to retire any generating facilities or construct new generating facilities." 1 In the public hearing for PSC Case Number 08-0109-E-CS (AES Laurel Mountain, LLC), expert testimony by Charles Simmons provided updated information by PJM: “The Application indicates the PJM forecasted summer peak for 2017 is 159,822 megawatts (MW). On May 5, 2008, a PJM press release stated that PJM has 159,780 MW of committed capacity for the summer of 2008, which essentially is equal to the 2017 projection if no new capacity became available to PJM during the next nine years. Ten days later, another PJM press release announced the results of the capacity auction for the planning year June 201 1 thru May 2012, which added 4,238 MW of new generation and demand response, with a 37% reduction in price. PJM explained that the ‘auction price was lower because growth in the available capacity was greater than the growth in demand - supply exceeded demand.’ PJM also stated that the total results of the auction include 176,055 MW of generation and 2035 MW of demand response.’] Additionally, on November 21 2008, an article in the Wall Street Journal, “Surprise Drop in Power Use Delivers Jolt to Utilities”, includes a quote from Michael Morris, the chief executive of Allegheny Electric Power, who says he thinks the industry should to be wary about breaking ground on expensive new projects: “The message is: be cautious about what you build because you may not have the demand to justify the expense.]’ INDUSTRIAL-SCALE WIND TURBINE FACILITIES DO NOT REDUCE CARBON DIOXIDE EMISSIONS The Mt. Storm coal-fired plant in West Virginia generates electricity for Virginia. Even , though there can only be very minimal electricity produced by wind projects near Mt. Storm, the mere connection to the wind project will be used for the purpose of satisfying the requirement for Renewable Portfolio Standards (RPS) in other states. The RPS requirement is that approximately 15 percent of the electricity in that state must be from renewable sources such as wind, solar, or hydro, or a fine is levied. A review of the actual sources mostly used for RPS requirements reveals that most of the RPS credits are stated to be from wind plants (h~S://~.Rim.COm/Rlannina/RroieCt-t-qUeUeS/queUe- gen-active.isp). The concept that the minimal amount of electricity produced by industrial-scale wind turbines constitutes an “offset” of carbon dioxide from coal-fired plants is a fallacy and a scam on the American people. Electricity from industrial-scale wind turbines can only be produced when the wind is blowing at speeds above approximately 8 miles per hour and then must be used immediately because there is no method to store the electricity (there is no need to store electricity at coal-fired plants because coal is provided at a predictably constant rate). Because of this, PJM has now lowered the amount of capacity that wind plants claim to produce to 13 percent of their nameplate capacity. This well-known fact is in direct conflict with the AES claim that a wind turbine site on New Creek Mountain would function at 28 to 35 percent capacity. The wind speeds are the least during the summer months when electricity is needed the most (http://www.ncdc. noaa. aov/odclimate/online/ccd/avawind. html). Also, the wind is highly variable minute-to-minute and is not reliable for the hour-ahead dispatch system currently in use by our PJM regional transmission organization. In their siting application, the wind resource on New Creek Mountain was characterized by AES as excellent. However, they don’t even have 2 years worth of data and they state they need to more data to fully characterize the wind resource. This obviates the statement that there is an excellent wind resource. Additionally, AES must be embarrassed or 2 afraid to provide their wind data because they have refused to provide it as information. It is essential that the coal-fired boilers used at coal-fired electrical generation maintain flame stability. When the boilers are backed down to accommodate the variable influx of electricity from a wind plant, the flame stability must be maintained least to 50 percent of their capacity even if the steam cannot be used for that specific period of time. When the boilers are heated again sufficiently, this ramping up (equal to acceleration) requires even more coal to be burned (or more gas or petroleum to be consumed in peaker units) 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. 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. If the wind plant were not providing input to the electrical dispatch system, the extra spinning reserve required for the wind plant would not be necessary. The Federal Energy Regulatory Commission has provided regulations for “spinning reserve” (http://tdworld.com/news/Dower soinnina reserve black/). Spinning reserve is capacity (generation or usage reduction) that is available in 10 minutes. It can be called upon virtually instantly to replace a power plant or transmission line that unexpectedly trips out of service ~http:/iwww.~im.com/contributions/news-releases/2006/20060501-dr- in-ancillaw-services-markets.Ddf). Plants providing spinning “spin” under no-load (or partial load) conditions and are not actually producing any substantial amounts of electricity although their rotating generators are electrically connected to the grid (htt~://ewh.ieee.orc1/r7/ottawa/ea/lEEEStan Seminar VI.pdf). Power suppliers will be paid a per megawatt hour market clearing price to provide spinning reserve services - a pricing schedule that has been approved by the Federal Energy Regulatory Commission (FERC). The manager of market development for PJM stated, ‘Wemust have sufficient spinning reserve at all times to allow quick recovery from the largest single outage anticipated, and that would be the possible loss of a large nuclear unit of more than 1000 megawatts”. Considering the required spinning reserve and the need for a coal-fired plant to maintain flame stability, it is difficult to perceive that any carbon dioxide is being offset by the use of industrial-scale wind turbines. It should be noted that the amount of spinning reserve electricity is not simply a backup for the wind turbine plant, but rather, it is a backup in the event that a major, reliable generator would go off-line. Wind power is not capable of supplying spinning reserve. Additionally, industrial-scale wind turbines use electricity from the electric grid system, referred to as “parasitic” loads. Such parasitic loads include electricity from the grid for the electric pitch system yaw motors, oil heaters, oil pumps for bearings and gearbox, cooling van for generator and turbine controller.
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