<<

On Mar 7, 2019, at 5:06 PM, Barbara Durkin wrote:

Dear Mr. Foley,

Thank you for accepting my comments on DRI. I am a MA resident & tourist of the Cape & islands who has independently researched offshore wind energy for 15 years.

The biggest problem with offshore wind is technology failure—70% offshore wind projects’ insurance claims are for cable failure.

I will confine these comments to cables by Anbaric and those that are associated with Vineyard Wind.

The US has it backwards as the U.K. has learned the hard and expensive way that transmission must be installed before wind turbines, according to Anbaric.

Anbaric Pushes Offshore Grid Plans July 22, 2018 Clip- “But the lesson learned is that you need to do the transmission first,” Conant said. “Early on in Germany, the delays caused costly headaches. Developers cite that as a reason to have control over transmission, but it’s only part of the story, the beginning,” agreed Knobloch. “The Danes and the Germans quickly moved to planning transmission before soliciting offshore wind generation.” https://www.rtoinsider.com/anbaric-offshore-wind-96507/

‘Vineyard, Anbaric Team on 1,200-MW Offshore-Tx Proposal February 14, 2019’

“Vineyard, a 50/50 partnership between Copenhagen Infrastructure Partners and Avangrid Renewables, last May won a contract from for a 1,200-MW offshore wind project off Martha’s Vineyard...” https://www.rtoinsider.com/vineyard-anbaric-111360/

How will the Commission be reasonably certain that production of power will occur by Vineyard Wind to serve 60,000 homes, (or to a home), after year one of operation?

Avangrid will not release the amount of project production after one year of project operation.

‘Study: Wind turbines in North Carolina don't impact radar’

“The turbines were expected to produce 208 megawatts, or enough to power 60,000 homes a year. Avangrid Renewables will not release the amount of power actually produced after more than a year of operation, said company spokesman Paul Copleman...” https://www.whsv.com/content/news/Study-Wind-turbines-in-North-Carolina-dont-impact-radar- 487697911.html

Exit Strategy Decommissioning Protocol Current UK

UK is Decommissioning 37 offshore wind farms UK @ €4.12 bn or US $5.45 bn cost.

**To leave cable in situ (“as inter-array cables being disconnected and their ends being buried”) Disconnect and bury the ends of Low-pressure oil-filled (LPOF), cables?

Foundations being cut below seabed, top section to be removed.

Clip- “Consultants at Arup defined decommissioning’ as inter-array cables being disconnected and their ends being buried, wind turbines being dismantled and transferred to shore, and foundations being cut below the seabed, and the top section removed and returned to land. BEIS is the ‘executioner of last resort’ if a project’s developer or owner cannot fund decommissioning, Arup explained in its report, ‘Cost estimation and liabilities in decommissioning offshore wind installations’.” https://www.windpoweroffshore.com/article/1487845/offshore-decommissioning-cost-uk-36bn

Oil, any type, is hazardous in the marine environment.

The following is a brief introduction to cable types and components as it pertains to offshore wind installations. Insulation Three types of cable insulation are in common use for submarine transmission for long distances (at least several kilometers.) While insulation construction and thickness vary based on voltage, all three types discussed here are used for both medium and high voltages. Insulation is characterized by their insulation material, their construction, and whether the dielectric (i.e. insulation) is lapped or extruded. Low-pressure oil-filled (LPOF), or fluid-filled (LPFF) cables, insulated with fluid-impregnated paper, have historically been the most commonly used cables in the US for submarine AC transmission. The insulation is impregnated with synthetic oil whose pressure is typically maintained by pumping stations on either end. The pressurized fluid prevents voids from forming in the insulation when the conductor expands and contracts as the loading changes. The auxiliary pressurizing equipment represents a significant portion of the system cost. LPFF cables run the risk of fluid leakage, which is an environmental hazard. Fluid-filled cables can be made up to about 50 km (30 mi.) in length. They are rarely used for DC applications, which are generally longer than practical for pressurizing. While LPFF cables are widely installed worldwide, the cost of the auxiliary equipment, the environmental risks, and the development of lower-cost alternatives with lower losses, have all contributed to the reduced use of LPFF cables in recent years. https://electrical-engineering-portal.com/offshore-wind-farms-transmission-cables

Cable problems DeepWater Wind

‘Town demands long-term solution for cable issues’ By Cassius Shuman Thu, 10/11/2018 - 6:30pm Clip- Meaghan Wims, spokesperson for Deepwater Wind, said, “Deepwater Wind is currently reviewing historical information, collecting additional survey data and conducting necessary engineering to finalize a long-term plan for the export cable at Town Beach. We’re confident that we’ll have a long-term plan by early 2019 for maintaining the cable’s burial depth.” National Grid and Deepwater Wind’s cables, which are integral to the Block Island Wind Farm, have become exposed due to shifting sands close to the shoreline at the Town Beach. National Grid’s cable connects the mainland to the island’s power grid, while Deepwater Wind’s cable connects the island to the wind farm. Roberge noted that the CRMC wants the two companies to furnish the agency with “engineering solutions for dealing with the cable on a long-term basis.” The CRMC is the state agency that has jurisdiction over the permitting process for both of the cables. Roberge said the geotechnical field surveys will be conducted “to better understand what’s beneath” the sea floor. “It’s been described as a field of cobble.” “Back in August, the CRMC met with National Grid and Deepwater Wind,” said Roberge. At that time the plan was for Grid install a protective sleeve around its exposed cable. However, Roberge said that plan was scrapped after the three entities decided at the end of September to explore “longer-term solutions. This is a good thing,” he said. “We’re working toward a long-term solution.” Roberge said that in his mind there are two long-term options for addressing the issue with the cables: “relocating or replacing” the cables. Relocating means installing the cables at their proper burial depth in a different location, while replacing the cables involves cutting and splicing the exposed sections of cable and reinstalling them at appropriate depth. As for working with Deepwater Wind, which is in the process of being purchased by a Denmark-based offshore wind developer, Roberge said, “We don’t see any change. It’s the same folks that we’ve been dealing with. So everything is the same.” https://www.blockislandtimes.com/article/town-demands-long-term-solution-cable-issues/53442

CABLE [Offshore Wind]

‘Industry must face up to growing cable failures’

“Operational failures now make up about 80% in value of all cable-related claims, a delegate from the insurance industry claimed...” https://www.windpowermonthly.com/article/1428525/industry-face-growing-cable-failures

“Cable failures are one of the main risks affecting offshore wind operations Cable failures are one of the main risks affecting offshore wind operations because they can shut down an (important part of an) offshore wind farm for a duration of months, resulting in a financial as well as a societal impact. Despite the fact that power cables typically form only 5 to 10% of the total investment costs in an offshore windfarm, they account by far for most of the unavailability of the windfarms, and for claim costs of 100s of millions of Euros annually. In view of the development of the number of offshore wind farms, this amount will increase considerably in the future. Cable inspections and repairs are expensive maritime operations. Repairs on cables can easily take weeks or even months because of the weather or the limited available of equipment and vessels. That can severely impair revenue and also reduce the technical lifetime of offshore wind farms...” https://www.dnvgl.com/news/offshore-wind-industry-joins-forces-to-reduce-costs-of-cable-failures- 117811

Cable installation and repair cost-

Cable problems, (more than 70% of wind project insurance claims), repair average cost is U.S. $6,450,630.08. ( conversion € 5 million).

Offshore Cabling 2017 2017-03-07 - 2017-03-09 Cable damages remain an ongoing issue with average costs of € 5 million per repair. Submarine cable repairs account for more than 70 % of all insurance claims of installed wind parks. http://www.offshorewind.biz/events/offshore-cabling-2017/

“Offshore transmission has proved to be challenging and costly in Europe, and will present additional challenges in the US because of the lack of domestic manufacturers of high-voltage, high-capacity submarine cable, and lack of equipment for and experience in installing this type of cable...” https://electrical-engineering-portal.com/offshore-wind-farms-transmission-cables

AMERICAS FIRST DEEPWATER WIND TECHNOLOGY-safety-turbine, cable problems-

1st US Offshore Breaks Before It Even Opened For Business' about DeepWater Wind with 20% project mechanical failure at the start- http://dailycaller.com/20http://dailycaller.com/2016/12/06/1st-us-offshore-wind-turbine-breaks-before-it- even-opened-for-business/16/12/06/1st-us-offshore-wind-turbine-breaks-before-it-even-opened-for- business/

Think Wind-Generated Power Is Saving People Money? Check Out America’s First Offshore Wind Farm By Stephen Beale | August 6, 2017, 13:55 EDT America’s experiment in off-shore wind-based energy is raising rates on residents and creating another burden for businesses in a state that is already consistently ranked one of the worst places for businesses in the country. In December last year, the first off-shore wind farm started operating off the coast of . Although hailed as an innovative step forward in renewable energy, some customers are balking at the higher costs. “My whole objection to the process back in 2010 was the excessive cost involved in the demonstration project and that’s a concern that persists to this day and I think is actually being borne out by real numbers,” said Larry Ehrhardt, a former Republican state representative from North Kingstown. cut- continue reading- http://newbostonpost.com/2017/08/06/think-wind-generated-power-is-s...

1/11/17 Block Island Times US First DeepWater Wind transmission cable needs to be reburied Although the interconnection between the National Grid and Block Island substations is expected to be completed by April 1, there is a problem with the cable that will need to be addressed sooner than that. Recent surveying of the cable revealed that some of it is not buried at the required depth of six feet below the surface of the ocean floor. In some areas, concrete pads have been placed over sections of cable to protect it, but that has not been deemed feasible for the section just offshore of Fred Benson Town Beach. Starting 200 feet from shore, the next 80 feet of cable are currently only three feet below the ocean, and will need to be reburied. http://www.blockislandtimes.com/article/news-update-portion-transmission-cable-needs-be- reburied/48505

Associated Press - Jennifer McDermott - March 2, 2017 A turbine isn't spinning at the nation's first offshore wind farm, but repairs are expected to be complete soon. ...There was an issue with a cable connection on the turbine, but it should be back up within days, said Paul Murphy, the company’s vice president for operations and engineering. The same turbine previously was taken offline while its generator was repaired after a drill bit was left inside. http://www.windaction.org/posts/46391-regulators-updated-on-first-u-s-offshore-wind-farm-operations- off-block-island#.WLm9AlXaeM9

Next Source 4Coffshore.com 30-July 2015 "An accident occurred where construction barge collided with the jacket foundation at the site. This collision dented one of the four hollow legs of the foundation."

10 Sept 2015 "ABS Group published a report highlighting the Health and Safety problems at DeepWater Wind. The issues include near misses, dropped objects, loss of control of suspended loads, employees working under suspended loads, improper placement of safety equipment, and rescue skiff." 2 Dec 2016 "The Block Island Times announces that turbine number two has been damaged, due to what the project’s developer is calling “human error.” DeepWater Wind, said the turbine will be offline temporarily, but will be operable for commercial operation in the near future. According to DeePWater Wind, the damage occurred during testing of the wind farm, some time after construction was completed on Aug. 18, 2016. “During recent tests, General Electric learned that as a result of human error a drill bit left inside the generator of turbine number two caused some damage.” 12 Dec 2016 "Commercial operations began, on finalization of power contract between DeepWater Wind and ISO New England, the operator of the region’s power grid. Only for of the five turbines came on line, as turbine two broked down in early November during routine testing, after a 6-inch drill bit, left behind during assembly, was found in a gap between the turbine’s generator and direct-drive system, causing damage to magnets in generator." 17 Jan 2017 "The repair of turbine 2. That was damaged when a dril bit was left in the generator, began. The work was completed in the first week of February." http://www.4coffshore.com/windfarms/project-dates-for-block-island-wind-farm-us12.h

Department of Business, Energy and Industrial Strategy Cost Estimation and Liabilities in Decommissioning Offshore Wind Installations Public Report https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/725316/ Cost_and_liabilities_of_OWF_decommissioning_public_report.pdf

Your time and review of my comments is greatly appreciated. I ask that you consider that industry has not resolved offshore wind cabling issues, corrosion, blade or foundation failures.

‘TYPE FAILURE OR WEAR AND TEAR IN EUROPEAN OFFSHORE’ 25/02/18

“Recent reports indicate that major repairs are required on 500 offshore wind turbines in United Kingdom waters, and nearly two hundred more at sites off the Danish and German coasts...” https://www.thegwpf.com/type-failure-or-wear-and-tear-in-european-offshore-wind/

Orsted has offshore wind leases from MA 2 Virginia & 2,000 failed blades 2/18: http://www.windaction.org/posts/47883-siemens-sets-billions-orsted-must-repair-hundreds-of-turbines#.XIGTBhZOmEe

However, they added, there was “disagreement between Ørsted and as to whether the problems are covered by the guarantee or are a case of ordinary wear and tear.”

Bard 1 Germany flagship Offshore Wind Biz (June 2014) cites: "frequent technical problems with the converter substation," "a smoldering fire," "failure of the system," "five unplanned outages since the beginning of 2014" and "transmission problems." https://thehill.com/blogs/congress-blog/energy-environment/226050-offshore-wind-farms-are-no-public-benefit?amp

WindPowerOffshore, same timing, (September 19, 2014), reports the Danish company Vattenfall is going to dismantle the Yttre Stengrund in Swedish waters after only 13 years of operation. "Only one in (5) turbines is currently operational."

Protocol is to leave these cables in the seabed, detach and bury the ends, for decommissioning of offshore wind.

It would be tragedy if Vineyard Wind is allowed to construct this project that will fail to deliver reliable energy at commercially reasonable cost.

Thank You,

Barbara Durkin 48 Moore Lane Northboro, MA 01533

Sent from my iPhone