SRC,

 

I agree with Jim’s comments.  I’m going to add a few comments of my own so that I don’t forget about them during the call.

 

The SRC and AWI might want to consider the monitoring team’s grizzly bear on the trail analogy with respect to the winter shutdown exemption.  Leaving 20% of the turbines on throughout the APWRA will expose highly mobile animals to continued threat of collision.  The winter shutdown experiment in the cross-over design produced a shutdown effect but with no obvious impact on annual mortality, indicating that about the same number of birds get killed over the winter, but that they get killed at the turbines that are operating.  Imagine that 100  of the 250 red-tailed hawks killed annually are killed during the winter months.  What we may have seen with the shutdown experiment was that the same 100 got killed during the winter, but most of these got killed on the half of the APWRA where the turbines were operating during ½ or the other of the winter.  Thus, we see a strong shutdown effect without a change in annual mortality.  This result can happen if there is an age class, for example, of red-tailed hawks that repeat a dangerous behavior near wind turbines, such as hovering in declivity winds.  If they keep repeating this behavior at many different locations in the APWRA, then eventually they are going to do it by the operating turbines.  Red-tailed hawks are not static, and can fly from one end to the other of the APWRA within an hour.  Exempting the AWI turbines might result in a smaller than expected reduction of mortality during the winter, but we might also expect the majority of fatalities will be found under the AWI turbines.  If the exemption is allowed, then perhaps AWI ought to be held extra responsible for more than the usual number of fatalities under its turbines, if this situation is realized.

 

The winter shutdown exemption would require a permit change, wouldn’t it?  I thought the County was unable to require the SRC’s recommended 4 month shutdown because it says it needs approval from the BOS.  If that is the case, then wouldn’t the BOS be needed to approve the permit change so that AWI can exempt its turbines from the winter shutdown?  This year they are required to shut down turbines for 2.5 months, unless there is a change to their permits.  Can the County authorize AWI to turn their shutdown turbines back on by November 30?  (I’m assuming at least half of AWI’s turbines are currently shut down.)

 

The proposal does not state anywhere that the study design is inconsistent with the SRC’s recommendation that all 920 turbines be used as the pool from which to draw the random sample. 

 

Health effects are cited in justification of the experimental design.  If the SRC approves the study design as written, is it not also agreeing with the justification for the design?  The justification is that wind turbine operations save human lives, so the winter shutdown exemption is needed to save human lives.  Before agreeing with this justification, I would rather see solid evidence that wind turbine operations result in reduced emissions from coal-fired and gas-fired power plants.  In general, it seems like the study design is being justified by wind power advocacy, which perhaps is beyond the scope of the SRC.

 

Jim’s points about the long-term application of any results are important.  I think the SRC might want to learn whether AWI or the other companies have access to spare parts that will keep their old-generation turbines running for much longer.  I recall the companies told us the parts are no longer available.  Each time I go to the Altamont, I see more rotors and blades spread around the hillsides, and quite a few turbines are not being fixed.  Is there really any hope of applying the black blade painting scheme to old-generation wind turbines beyond next year?

 

Shawn

 

 

 

 

All:  not sure to what extent or in what form the SRC should be providing comments on the black blade study, but attached is my summary of comments and questions for purposes of discussion. 

 

Jim.