Executive Summary of Industrial Wind Turbine Development in Brown County

Table of Contents Page 1

Sound and Health Issues Pages 2-3

Noise Emissions and their Health and Welfare Effects on Humans Page 4

Cost of Wind Generation and its Effect on Electric Reliability Page 5-6

Local Economics of Wind Turbine Development Pages 7-8

Groundwater Contamination in Southern Brown County Pages 9-10

Physical Risks of Wind Turbines Page 11

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Page 1
Sound and Health Issues

As Wind Energy projects continue to expand across Wisconsin and as the need for energy independence
becomes more urgent, controversy over siting regulations has become a dividing point in communities across the
state. The recent applications for projects in northeast Wisconsin make safe siting guidelines the center of the
argument. Brown county’s rural townships have had home rule taken away as the political process in Madison
has removed the regulatory and permit process for large industrial developments. Yet, large industrial wind
turbine developments do not belong in close proximity to locations where people live and work. As the PSC
develops guidelines for setbacks, I believe it is important for us as citizens, for our townships and our county to
make our voices heard in Madison that we are concerned that the state has not done enough, and more
importantly that the wind industry has not done enough to ensure the health and safety of those living in close
proximity to large industrial wind turbines. The safest minimum distance to protect the health and safety is to
allow for less than 40dB which correlates to 0.5 miles or 2640 feet. The optimal distance in a rural setting would
allow for no more than a 10dB increase in ambient noise which would correlate to just over one mile.
Normal sleep is essential for health and well-being. The science of sleep study has established the population
averages for the amount of time it takes to fall asleep. The number of awakenings during the night and the
number of sleep arousals that are standard. (American Academy of Sleep Medicine 2005.)

Long-term sleep disturbance has great influence on metabolic and hormonal function. Cortisol, leptin and C-
reactive protein are objective markers in the blood that increase in people with chronic sleep deprivation. Each of
these markers is associated with an increase in heart disease, diabetes, weight gain, decreased immunity and
high blood pressure.

Noise disturbs sleep. Many studies over the last 30 years show there are physical responses to noise as it
disturbs sleep. EEG changes, blood pressure and heart rate, body movement and restlessness, and awakening
can all be measured in the common sleep study. Environmental factors have been reported as sources of sleep
disturbance. They all follow a similar curve in that as noise levels increase so do complaints of sleep disturbance
(European Commission, 2004).

Wind Turbine noise is disturbing to those who live close to them. Experience is the best teacher, and planners of
wind turbine developments need to take into account the noise complaints from existing sites and the real world
examples of the noise disturbance caused by wind developments. Many of these sites have been in place for
years and those that are in close proximity to people are rife with complaints, law suits and unhappy landowners.
Proper siting away from people will prevent such complaints. (Hanning, 2009) Surveys of residents living in close
proximity to industrial wind turbines show high levels of sleep disturbance and annoyance. In Kewaunee County
52% of individuals living within 2400 feet found noise to be problematic. 32% within 4800 feet and 4% greater
than 1 mile were disturbed. 67% reported disturbed sleep if they lived within 1200 feet. (Kabes 2001)

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Page 2
Table 3 from World Health Organization 2009; Effects of different levels of night noise on the population’s health.
Average night Health effect observed in the population
noise level over
one year
Up to 30dB Although individual sensitivities and circumstanced may differ, it appears that up to this level
no substantial biologic effects are observed.
30 to 40 dB A number of effects on sleep are observed; body movements, awakening, self-reported sleep
disturbance, arousals. The intensity of the effect depends on the nature of the source and the
number of events. Vulnerable groups (elderly, children and chronically ill) are more
susceptible.
40-55 dB Adverse health effects are observed among an exposed population. Many people have to
adapt their lives to cope with the noise at night.
Above 55 dB The situation is considered increasingly dangerous for public health. Adverse health effects
occur frequently, a sizeable portion of the population is highly annoyed and the sleep
disturbed. There is evidence that the risk of cardiovascular disease increases.

What is the best setback distance? At least 14 published recommendations follow the same logic. Wind turbines
cause noise. Noise disturbs sleep. Sleep disturbance has a bad effect on health. The conclusions of many
sound studies show that the noise decreases as the distance from the turbine increases. According to
Invenergy’s sound studies as submitted to the state, noise levels of over 55db will be seen close to turbines
planned for Brown County. By being over 2500 feet from the nearest turbine, the sound will drop to the 40db
level and to drop to below 30db for optimal noise in a rural setting, a setback of over one mile is required. This
agrees with the over 14 studies published to date that look at problematic industrial wind turbine developments.
Consider the quote below from Invenergy’s Beech Ridge project.

“Most setback guidelines recommend wind towers to be located at least 1000 feet from residences–a requirement
that Beech Ridge will exceed by more than a multiple of five times. At a distance of 1000 feet, most potential
negative impacts of wind turbines are significantly reduced. At a distance of one mile, these impacts are no longer
a legitimate concern. For instance, for property one mile from the nearest turbine:
• Shadow flicker will be eliminated.
• Risks of damage from ice thrown from a turbine blade will be eliminated.
• Any potential impacts on property values should be significantly reduced.
• Turbine sound levels will be significantly lower than existing indoor and outdoor background
sound levels.”

Other concerns such as groundwater contamination, low frequency noise, shadow flicker, domestic animal
effects, and others add to the questionable risks vs. benefits. Noise impacts alone on the health and well-being of
Brown County should prompt the Board to let its voice be heard at the Public Service Commission and not let
politics impose a project on this area that jeopardizes our health and safety, making this project the next wind
ghetto in the state. The state and the wind developers should not be allowed to place corporate profits ahead of
conservative, safe and evidence based setbacks. At a minimum this should be ½ mile and 40db, optimally 1 mile
and 30db.

Herb Coussons, MD

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Page 3
Noise Emissions and their Health and Welfare Effects on Humans

Doctor Coussons findings are consistent with Richard Horonjeff’s report titled “Siting of Wind Turbines With
Respect to Noise Emissions and their Health and Welfare Effects on Humans”. Mr. Horonjeff has 40 years of
research and application experience regarding community response to noise (attitudinal surveys, noise control
strategies, noise metric development, airport/aircraft noise measurements, data acquisition systems, noise
prediction models, and psychoacoustics for both private and government sectors).

Richard Horonjeff focused on three areas important to the discussion of Industrial Wind Turbines:
• Welfare
• Health
• Margin of Safety
In the present context the term welfare refers to the potential annoyance or nuisance effect of the noise. The word
health refers to potential health effects of the noise having to do with sound level, frequency content, or temporal
character. The term margin of safety relates specifically to the many unknown factors involved in predicting the
health and welfare effects of wind turbine related sound.

He came to the following conclusions:

1. Wind turbine noise appears to be eliciting annoyance and physiological responses not
experienced from other noise sources of similar sound level.

2. Wind turbines are most often sited in rural areas where ambient sound levels are low,
resulting in audibility of the turbines at lower sound levels than would be expected in
urban or suburban environments.

3. It is not at all clear whether people’s responses to wind turbine noise are the result of the
absolute loudness (irrespective of the ambient), to the audibility of this unique source, or
to some other characteristic such as the periodic modulated nature of the sound and low frequency
content.

4. Under conditions of uncertainty where the stakes of human health and welfare are high, it
would seem prudent to use the best available information available at the moment.
Lacking sophisticated epidemiological studies, laboratory listening tests and the like,
well-reasoned interpretations of anecdotal information allowing for an adequate margin
of safety may have to be used to make these important decisions so that sufficient
protections are put in place.

Richard Horonjeff’s complete report can be found as Public Comment in PSC of WI Docket 1-AC-231
http://psc.wi.gov/apps35/ERF_view/viewdoc.aspx?docid=134323

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Page 4
Cost of Wind Generation and its Effect on Electric Reliability

Wind generation's economic costs and effects on our electric reliability will impact Wisconsin for at least the next
30 years (the typical wind project lifespan). Impact will be felt in our electric bills, our children’s employment
opportunities, and the quality of life we enjoy in Wisconsin.

Cost - Two aspects of wind electric generation conspire to tax the electrical grid disproportionately to the amount
of electricity that is actually generated:

1. Industrial wind turbines have a very low ‘capacity factor’ of 18% to 24% (often referred to as ‘efficiency’)
even in the windiest areas of Wisconsin (where the Department of Energy classifies the wind resource as ‘poor’ to
‘marginal’).
2. The grid must be ‘sized’ for the FULL nameplate capacity of wind turbines to handle that rare scenario
when their electric generation approaches their nameplate capacity.

The Joint Coordinated System Planning (JCSP) Economic Study was an investigation led by the Midwest
Independent Transmission System Operator (MISO). They examined the cost to expand the grid to be capable of
handling 20% of the state’s electric generation from wind. The 20% Wind Energy Scenario in the study requires
construction of 15,000 miles of new EHV transmission capacity at an estimated cost of $80 billion. This is $30
billion in excess of the baseline scenario they studied. The JCSP study illustrates the massive infrastructure
improvements that are needed to support the variable nature of industrial wind electric generation.
http://jcspstudy.org/

According to MISO, every $1 of renewable capital expenditure requires $0.15 –$0.20 of transmission investment.
These costs were not a consideration in the rules that the Siting Council has proposed. Higher utility rates
increases the cost of doing business in Wisconsin resulting in higher costs to consumers and even more jobs
leaving the state. With the rate increases that are always tied to wind development, how many manufacturing
companies in the state of Wisconsin will continue to be able to compete?

In the concurring opinion of PSC Commissioner Lauren Azar for Glacier Hills (PSC docket 6630-CE-302), she
states:
"The variable nature of wind resources necessarily leads to additional infrastructure to integrate wind-generated
energy onto the grid. We are already beginning to see the problems arising from adding variable resources to the
grid. As the volume of variable resources grows, so do the problems. This additional infrastructure could take the
form of electricity storage, additional transmission capacity, supplementary reactive power support, or a variety of
other infrastructure upgrades. While wind projects are forcing these infrastructure improvements, to date, the
costs of those improvements have not been captured in applications for wind projects. Wisconsin's ability to meet
renewable and carbon reduction goals will be, in part, dependent on the transmission system's ability to deliver
renewable and low- or no-carbon generation to customers. To truly gauge a proposed wind project against other
renewable energy projects (which may not be variable), future applications need to identify and at least attempt to
quantify the costs attendant to the improvements necessary for variable sources."

Wisconsin's energy costs have a direct impact on the business climate of Wisconsin. As our history shows,
companies that are able, will flee Wisconsin as utility energy rates rise. The impact to an individual's ability to get
a decent job must be figured in to the "social value" of Industrial Wind development. The temporary construction
jobs and few permanent jobs created to develop wind resources are at the cost of many more job losses as the
result of higher energy costs.
http://www.instituteforenergyresearch.org/green-jobs-resources/

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Page 5
Reliability and the Variable Nature of Wind Electric Generation

Reliability has always been at the core of electric grid design and operation due to the cost of outages to
customers. In the US, the annual cost of outages in 2002 is estimated to be in the order of $79 billion which
equals to about a third of the total electricity retail revenue of $249 billion. A similar estimate based on 2008 retail
revenue would be of the order of $109 billion. Much higher estimates have been suggested by others. A major
contributing factor is grid congestion made increasingly worse as more and more industrial wind developments
are brought on-line. In the state of Wisconsin, the grid is already being operated at its “edge” in many locations.

The unpredictability of wind energy resources is indicated by their low capacity factors (typically 18% - 24% in
Wisconsin) which are much, much lower than conventional generators. This creates challenging problems in the
control and reliability of the power grid. The variability of wind energy has little correlation to the variability of the
load and hence contributes only a little towards meeting Wisconsin's peak load demands. So, despite a large
nameplate capacity of current Wisconsin wind generation, wind generation contributes very little electricity when
we need it most (ONLY 0.33% of total generation during the 2008 peak load was from wind generation - 3:42pm
on 7/29/08)

According to MISO (The Midwest ISO is an independent, nonprofit organization that supports the reliable delivery
of electricity in 13 U.S. states and the Canadian province of Manitoba - http://www.midwestmarket.org)

• Seasonality and variability lower the availability of renewable generation, reducing electric grid stability

• Integrating renewables into the power supply requires an increase in reserve capacity to account for the
increased supply volatility

• Wind is intermittent in nature and typically most available during off-peak periods

• Large land areas are needed precluding other economic uses

• Wind development generates a high number of interconnect applications increasing operating complexity
and congestion

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Page 6
Local Economics of Wind Turbine Development

Property Values:
When the wind developers started talking to our community, they assured us that studies had been done by the
Department of Energy and the Renewable Energy Policy Project that absolutely proved that Wind Turbines do not
cause property value loss. RENEW Wisconsin likes to site these studies as well on their website and when they
talk with groups about wind projects. We initially assumed that they were telling the truth, but the more you look at
it, it just didn’t make any sense. If you imagine two properties that were exactly the same, except for one being
sited next to an industrial wind turbine, which property would you want to live at - the one where there was peace
and quiet... or the one with shadow flicker for part of the day, flashing red beacons at night, varying degrees of
unrelenting noise day and night, and ice throw in the winter. It is just common sense that wind turbines affect
property values when placed irresponsibly.

The Department of Energy study is one of the most recent from December of 2009. It studies 7500 home sales
and concludes that there is very little property value loss caused by the wind turbines. However, there were only
125 home sales out of the 7500 in the study were sold within1 mile of a wind turbine. 125 was not a large enough
number of sales to be "statistically significant" in this study, and so were simply THROWN OUT of the study.
Less than one mile is where the impact of Wind Turbines is felt, is heard, and is seen. Residents of southern
Brown County will be MUCH closer than 1 mile from a turbine if the Ledge Wind Project is allowed to proceed. To
exclude this critically important group of homes makes this study largely irrelevant when discussing the Industrial
Wind Turbine Development in Brown County. And you can come to your own conclusion, but when there were
only 125 sales of homes that were less than one mile from a turbine out of 7,500 homes in the study, that tells a
huge story all by itself. Homes in close proximity to turbines are hard to sell.

So what study is an accurate depiction of property value loss when turbines are placed in CLOSE proximity to
homes? We can look to the communities in Dodge and Fond Du Lac counties just to the south of us as an
"apples to apples" comparison. Comparable sized turbines to those being proposed by Invenergy in their Ledge
Wind Project, and the same setbacks as proposed in the Ledge Wind Project. The Appraisal Group One did an
independent study of the impact of wind turbines on residential property value in these two counties. It showed
that bordering proximity properties lost the greatest value at -43% for vacant land and -39% for improved
properties (properties with homes). The near proximity properties which are 1/2 mile from a turbine - much farther
distance than most of the homes in our community will be from a wind turbine - showed a -29% loss of value for a
vacant parcel and -24% loss in value for homes.
http://windconcernsontario.files.wordpress.com/2009/09/ago-wind-turbine-impact-study.pdf

In the town of Lincoln in Kewaunee County property values saw similar losses - 26% within a mile of a turbine and
18% between 1 and 2 miles away from a turbine. The developer of this project even bought some of the homes
and bulldozed them because the conditions in close proximity to the turbines were simply unlivable.

We hear from people in other projects that when calling in a realtor to list their home for sale, they are asked if
they live within the wind farm and, if so, the realtor often declines the businesses stating those homes are too
difficult to sell if they even sell at all.

If the wind developers are so certain that property value loss won't occur, simply write a property value protection
plan in to the project? The developers and the State of Wisconsin both refuse to do this.

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Page 7
Property Encroachment:

This map illustrates the property rights issue for neighbors of industrial wind turbines. Under previous PSC siting
regulations, turbines could exist approximately 1000’ from a home and approximately 500’ from a property line.
Thus the person that owns parcel “A” can site a turbine and collect the contracted payments from a wind
developer. (note: The draft rules being considered NOW by the PSC have actually made this encroachment
problem worse by increasing the ‘residence setback’ to 1240’ and decreasing the ‘property line setback’ to 440’
for the size of turbines proposed for southern Brown County)

The owners of Parcels “B” “C” “D” and “E” have their right to build a home anywhere in the yellow circle taken
from them without any compensation. Even worse, they cannot appeal to any local government or planning
committee. They have no say whatsoever in this ‘taking’. Even if they were allowed to build in the yellow areas
what bank would finance a home that is in the range of blade throw and 50+ sound decibels? What insurance
company would provide homeowners insurance for a home within the stated hard hat area for workers servicing
these turbines? (Note: In the Mechanical Operating and Maintenance Manual for the V90-3.0 MW turbine
published by Vestas, Chapter 2, “Stay and Traffic by the Turbine,” reads, “Do not stay within a radius of 400 m
(1,300 ft.) from the turbine unless it is necessary.” Even more disturbing is that Invenergy has stated that the
setback in the safety manual isn’t really relevant.)

We have non-participating landowners in our townships that own 40 acres of land and because of turbine
placement now cannot build the home they were planning to build on their own land. This ‘taking’ is nothing short
of legalized theft.

In some cases our Government and Public Utilities obtain the use of our property using Eminent Domain, they
have the right to do so. Invenergy is a private company and does not have the right to take our property. The
state Public Service Commission should be protecting the citizens of this state from private out of state
developers.

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Page 8
Groundwater Contamination in Southern Brown County

After a presentation by the State of Wisconsin Board of Health in which they stated “gaps remain in our
knowledge of the impact of wind energy may have on human health”, the Brown County Health and Human
Services Committee embarked on studying the subject of Industrial Wind Turbine development in Brown County.

After an in depth study of the wind development in Brown County, the Brown County Health and Human Services
Committee came to the following conclusion that was included in their resolution to the Wisconsin Public Service
Commission.

“We reviewed presentations by Kristin Morehouse, P.E. for the Brown County Citizens for Responsible Wind
Energy; and Bill Hafs, Director of the Brown County Land Conservation Department. Both reports indicate that
Southern Brown County’s unique topography presents considerable difficulties in safely installing wind turbines or
any construction which would disrupt ground in this area. The density of these Karst features is not replicated
anywhere else in the state.”

“Wind farms should not be installed in areas of Southern Brown County with Karst features. The historical record
of groundwater contamination in the southern Brown County area and the fragile geological formations, when
coupled with other potential health concerns deem this area unsafe for installation of a wind farm.”

Below is some of the information that led the Health and Human Services Committee to form their resolution.

Buried Electrical Conduits...Conduits to YOUR Groundwater

Wind turbines may seem environmentally friendly, but things aren’t always as they appear. Electrical conduits
from wind turbines can become a conduit to your groundwater. Electrical cables connect wind turbines together
and traverse across farm parcels. There are typically 3 large cables and 1 communications conduit that create a
“bundle” of electrical conduits. The voids or spaces between these cables create an underground “pipeline” that
can allow contaminated water to flow horizontally along the cable bundles. Electrical bundles are buried 4 feet
below the surface. Wind developers typically take the shortest path between two points...through the middle of
fields to shorten cable distances and save money. Cable trenches will pass over and through shallow bedrock
and Karst features including fractures. Once contaminated runoff finds these features, they can act as a conduit
to groundwater. Buried electrical cables add a path for horizontal migration of contaminants. Land application of
animal wastes directly over and adjacent to buried electrical conduits is risky business. Don’t be fooled...other
wind projects throughout the state do not face the same risks as this particular location on the Niagara
Escarpment. Karst features exist around the state, but much, much fewer than “the Ledge”.

Consider this:
• The proposed Ledge Wind Project has 81 miles of proposed cable trenching
• 97% of homes in this area rely on well water
• Proposed turbine locations are on and adjacent to shallow bedrock, karst fractures,
springheads and sinkholes.
• Over 100 wells in Morrison were contaminated in 2006. 23 wells were replaced at a total cost
of over $300,000.

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Page 9
Manure Spreaders Beware
The last thing farmers want in these economic times are more regulations imposed on their operations. Consider
the following: Karst features are prevalent in our communities. Many Karst features are not yet identified. During
construction of a wind project, many more Karst features will be discovered and documented. There will be less
land available to spread manure due to more, newly discovered Karst features. New DNA testing can trace well
contaminations to a specific herd/farm. Spreaders, haulers, farmers, owners, renters are all at risk for liability.
More spreading restrictions may be needed to protect the groundwater.

State Geologists Journal, 2007

“Karst features, including a variety of sinkholes, cavities, and solution openings, commonly occur in carbonate
rock (limestone and dolomite). Environmental problems associated with Karst features include:
• Rapid groundwater contamination
• Unpredictable groundwater flow
• Difficulty in groundwater monitoring
• Unexpected failure or collapse of surface structures such as roads or foundations.”

UW-Wisconsin Extension Discovery Farms, 2007

“Although the issue is extremely complex, one fact that is clear, and generally agreed upon, is that once
percolating waters containing contaminant loads move into the rock fractures, the potential for contaminant
attenuation is negligible and the introduction of those contaminants into the groundwater system is inevitable.”

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Page 10
Physical Risks of Wind Turbines

Blade Failure
In May 2010 in DeKalb Co. Illinois, a 131 foot blade bent at the base of
the turbine and debris flew over 500 feet. The cause of the failure is
unknown. The average wind speed the day of the collapse was 14mph
(gusting to 28mph in the hour of the collapse).

Tower Collapse
In December 2009 in Fenner, NY, a 1.5 MW GE wind turbine collapsed.
Later findings indicate that it was due to inconsistent degradation in the
concrete foundation.

In March 2009 in Altoona, NY, jumper wires that were installed after the
final inspection prevented the safe mode from activating on 2 turbines, resulting in the blades to operate at 3
times the design speed, and ultimately causing one of the turbines to
collapse.

Ice Throw
Wind developers claim that wind turbines are stopped by their control
systems before ice accumulates and is thrown. However, consider the
following quotes from GE (a leading manufacturer of industrial wind
turbines) Power’s, “Ice Shedding and Ice Throw – Risk and Mitigation”
manual. “In addition, rotating turbine blades may propel ice fragments
some distance from the turbine— up to several hundred meters (985’) if
conditions are right. Falling ice may cause damage to structures and
vehicles, and injury to site personnel and the general public, unless
adequate measures are put in place for protection.” In addition, GE indicates that “It is possible for ice to build in
a symmetric manner on all blades and does not trigger the sensor.”

Vestas, another leading manufacturer of wind turbines, indicates that their technicians should not be within * 1300
feet * of an operating wind turbine.

Risks:
• Unsafe setbacks from property lines and roads
• Farmers are allowed to farm up to the base of the turbine
• Snowmobilers/riders/hikers/hunters in danger zone
• Over speed conditions results in increased blade or ice throw
• As the number of turbines increase, the probability of injuries/failures increase
• As turbines are intermingled with people, injuries will increase

Setbacks of 1500 feet from property lines and roads would eliminate most of risk. ½ mile setbacks for the general
public are appropriate.

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Page 11