Summary of Environmental and Social Justice Concerns

Na Pua Makani Wind Farm fails to disclose or compensate for the serious consequences their proposed project would have to endangered bats and to the vulnerable residents of Kahuku.  In addition, Na Pua Makani’s relatively expensive $0.15/kwh power purchase agreement would not benefit ratepayers in light of less expensive (and less environmentally harmful) alternatives such as solar.  This developer has broken the trust of the public and they are providing misleading, unfounded, and incomplete information to Federal, State, and County permitting agencies in their attempt to obtain project permits.   Please help prevent this illegal unjust project.  We can meet our clean energy needs working with developers who respect our communities, environment, and laws.

Endangered Bats:  Na Pua Makani Wind Farm would kill bats (many more bats than they assert) and their proposed mitigation would not benefit an individual bat or the Oahu bat population.  To meet State and Federal endangered species laws, they must be required to shut down the wind turbines at night to avoid killing more bats than their compensatory mitigation produces.

Wind Farm Low-Balling their Estimate of Endangered Bat Take:  The public is tired of Hawaii wind farms low-balling their calculations of anticipated mortality of endangered Hawaiian hoary bats then exceeding their incidental take permits/licenses within four or five years of their 20-year permit.  Na Pua Makani calculated their anticipated bat take on a per-turbine basis, using bat take observed at the Kahuku Wind Farm where each turbine’s rotor swept area is approximately 1/2 the size of the proposed turbines.

To Meet State and Federal Endangered Species Requirements, Na Pua Makani Must Increase Low Wind Speed Curtailment to Protect Endangered Bats:  Na Pua Makani Wind Farm’s proposes to minimize bat take by implementing low wind speed curtailment when wind speeds are 5 meters/second or lower at night (stopping blade spinning when winds are light and bat activity is high).  However, these relatively large, strong-flighted Hawaiian hoary bats are detected flying around wind turbines at existing North Shore wind farms up to wind speeds of 12 m/s (Figure 2, adapted from Gorresen et al 2015, Figure 19, p. 25 https://dspace.lib.hawaii.edu/bitstream/10790/2585/1/TR64_Gorresen_Bats_Final.pdf).

In the August 7 contested case hearing, the wind developer was asked if they could implement low wind speed curtailment at 6.5 m/s instead of the proposed 5 m/s and the developer confirmed it would be possible to curtail at 6.5 m/s.  Bat observations by Gorresen et al 2015 (See Figure 2 below) indicate curtailment at 6.5 m/s versus the proposed 5.0 m/s would reduce bat take by ½ (See Figure 1).  Curtailment at 6.5 m/s could reduce bat take enough to compensate for the developer’s low-balled estimate of take, in which they based their per-turbine take on turbines that had 1/2 the rotor swept area of their very large proposed turbines.

For some reason, the wildlife agencies don’t appear to have asked the developer to reduce bat take by implementing the 6.5 m/s low wind speed curtailment instead of 5.0 m/s.  Because Na Pua Makani Wind Farm has agreed they can implement low wind speed curtailment of 6.5 m/s, their project does not meet the State and Federal endangered species laws which both require the applicant to minimize and mitigate take to the maximum extent practicable.

Gorresen bat wind speed explanationsFigure 1.  The relatively large, strong-flighted Hawaiian hoary bats are detected flying around wind turbines at existing North Shore wind farms (blue curve) at average wind speeds up to 12 meters/second.  By implementing low wind speed curtailment of 6.5 m/s (red arrows) instead of the proposed 5 m/s, Na Pua Makani Wind Farm could reduce bat take by 50%.  Low wind speed curtailment at 8 m/s would almost eliminate bat take.  Graph adapted from Gorresen et al 2015, Figure 19: https://dspace.lib.hawaii.edu/bitstream/10790/2585/1/TR64_Gorresen_Bats_Final.pdf

Avoidance of Bat Take Would Require Low Wind Speed Curtailment at 12 m/s average wind speed:  Because Na Pua Manaki Wind Farm’s proposed mitigation fails to offset take of even one bat (as explained below), the wind developer must be required avoid all bat take, which would entail low wind speed curtailment when wind speed averages 12 m/s or lower.

Failure to Compensate for Bat Mortality:  Native Hawaiians, Polynesians, and the general public are fed up with Hawaii wind farms proclaiming that their take of bats will be offset by mitigation as required State’s “net benefit” requirement.  After eleven years of industrial wind farm operations in Hawaii, there is no evidence a single bat has benefited from a wind farm mitigation project and it’s possible mitigation is harming individual bats and bat populations.

To meet Federal and State endangered species law, all wind farm mortality of the endangered Hawaiian hoary bat must be compensated for with mitigation that offsets the take – the bats must be better off as a result of the project (take plus mitigation), than they would be without the project.  As it currently stands, the wind farm’s proposal to manage invasive plants and pigs in a natural area of the Koolau Mountains and bat research seems unlikely to help one single bat.  The DLNR is already managing the natural area and just installed a new fence to remove feral pigs (which create wallows that serve as mosquito breeding grounds).  These actions benefit forest birds by reducing mosquito populations.  Mosquitoes are not a primary food item for the Hawaiian hoary bat, but one would not expect the reduction in mosquitoes to benefit the bat.  Removal of ungulates is actually correlated with a reduction in bat detections at the Kahukinui Forest Reserve on Maui.  Likewise, although attaching radio-transmitters to bats to study, or conducting other studies of the bats may not be expected to kill the bats, it would certainly not benefit the animal or the population.  Implementation of the results of research may help bats – research itself does nothing for a single bat.  The developer must take actions that actually help bats if they are authorized to kill bats.

See video of contested case hearing addressing unlawful endangered species aspects of the project:

http://www.hawaiinewsnow.com/story/36083754/endangered-bat-at-center-of-fight-over-kahuku-wind-farm-proposal

Night-time Nuisance Noise Exceeding Legal Limits:  Na Pua Makani’s EIS fails to fully disclose to Federal, State, and County permitting agencies how noisy the wind turbines will be, situated so close to residential areas.  The existing Kahuku and Kawailoa Wind Farms are both more than a kilometer from any residences; Kawailoa is more than 1,500 meters from the closest residence and the Kahuku Wind Farm is approximately 1,200 meters from the closest residence.  Na Pua Makani proposes to build turbines that are 56% taller than the Kahuku turbines and put them 205 meters (672 feet) from the closest residence and 480 meters (1,575 feet; 0.3 mile) from the Kahuku town residential area mauka of Kamehameha Highway, containing two schools and a hospital.

1200 Meter Buffer Three Wind Farms closeup may 14a

The two existing wind farms are 1,200 meters from communities; the proposed Na Pua Makani Wind Farm would be 205 meters from one home and 480 meters from the community raising serious noise concerns for residents, two schools, and our hospital.

The legal limit for night-time noise is 45 dBA during no more than 10 percent of any 20-minute period.  When the vacation rental down the street parties and wakes us up at night, we use the “Sound Meter” app on our phones and noise, at my lot line, is below 40 dBA and never spikes above 45 dBA.  Na Pua Makani’s EIS indicates the turbine operation AVERAGE (LEQ) noise would be 44 dBA in residential areas.  Please install the “Sound Meter” app on your cell phone so you see how sound works – an example noise graph is below:

noise example

LEQ is the horizontal line (essentially the average noise energy – in this case, for 10 seconds) and the red line is the noise energy over time – the red line is what you’ll see when you use the “Sound Meter” application.  Image From:  http://www.noisenet.org/Noise_Terms_Leq.htm

You’ve noticed noisy things are louder under certain conditions – like when you’re downwind from the noise and when the ground is wet from rain.  If the LEQ (average over the year) wind farm noise in the Kahuku community would be 44 dBA, it seems impossible for the L10 to not exceed 45 dBA.  Unless the wind farm is going to have spikes of very very loud noise that would pull the average way above the noise caused by normal operation, it seems impossible for the L10 to not exceed the legal limit of 45 dBA.  We can assume when the tradewinds are blowing from the wind farm toward the town or when it’s rained, the average noise energy that night will be louder than 45 dBA.  Current L10 noise levels in Kahuku town at night that I’ve measured are between 20 and 35 dBA.  The applicant has not disclosed the nighttime L10 noise for the project and the EIS’s use of LEQ is misleading and unscrupulous – this developer appears to be attempting to get permits based on incomplete and misleading noise information.

In addition to the illegal nighttime noise, there is the serious problem of low frequency noise.  Kahuku and Pupukea residents experience sleep disturbances from wind turbines located more than 1,200 meters downwind from their homes.

These giant, very close wind turbines would cause severe loss of property value – certainly no less than 10% in Kahuku, and possibly greater than 25% (see Heintzelman and Tuttle 2011 http://iiccusa.org/wp-content/uploads/2011/03/Values-in-the-Wind.pdf).   For these Kahuku homes with an estimated value of $400,000, this wind farm would result in the loss of $40,000 to $100,000 per family with no just compensation from the developer.  Local property value is primarily in the value of the land so property value effects in Kahuku could exceed those seen on the mainland.  Total loss of property value in Kahuku would be approximately $40 Million if the properties in the upper subdivision lost 25% and the properties makai of Kamehameha Highway only lost 10%.  Video from a public hearing addressing noise is online here:

http://www.hawaiinewsnow.com/story/24467219/resident-generate-heat-at-wind-turbine-meeting

Na Pua Makani’s 2016 EIS says there would be no high or adverse effects to any minority or low income population and, therefore, no environmental justice issues resulting from this Project.”  According to the Census Bureau, Kahuku has a total population of 2,614 people in 622 housing units (53% owner-occupied; 47% renting) that are 8.6% (224) white, 34% (888) Native Hawaiian; 26% (641) Filipino, and 31% (823) two or more races, 62% born in Hawai‘i, 23.5% born in foreign country.  Twenty five percent of the of population 25 years and older did not graduate from high school; 53% of Kahuku residents completed no more than 8th grade.

Solar is less costly to ratepayers and less harmful to the environment:  We love clean energy but the costs of this (what would be illegal) wind farm are too great in light of readily available alternatives (including moving the wind farm away from communities) and use of solar with battery storage instead.  Because solar with battery storage is less costly ($0.139/kwh) (less than 0.10/kwh for solar alone, but it does not meet nighttime energy needs), the wind farm is not in HECO ratepayers’ best interest.  Ratepayers would pay $20 Million more for power from Na Pua Makani than they would if that power came from solar with battery storage.  Solar is compatible with grazing (best to avoid installing solar on arable agricultural land) and it doesn’t kill wildlife.  Champlain Wind Power’s Director, Kevin Smith (http://www.champlinenergy.com/our_team.html) is the CEO of SolarReserve LLC, a company that’s installed solar farms all over the world.  I notice they also install the mirror concentrating solar farms in addition to PV with battery storage, but this company certainly has the ability to be pitching in to actually HELP Hawaii meet clean energy goals by building a solar farm with battery storage instead of trying to get permits with this unlawful wind farm.

Status of Permit Applications:  Keep the North Shore Country is addressing the endangered bat aspects of the project in a contested case at the DLNR.  The US Fish and Wildlife Service has not made a decision on the applicant’s request for an incidental take permit for the endangered bat.  We hope the wind farm will be required to avoid any bat take they can not offset.  The City and County of Honolulu has not issued a permit for wind turbine construction and we hope the State Health Department and EPA will step in to ensure the wind farm is required to move to a location where it will not have serious social and economic justice implications.

Please Help Prevent the Na Pua Makani Wind Farm:  Kahuku Community Association, an anonymous Native Hawaiian benefactor, Mothers Against Wind Turbines, and local residents are combining forces to support Keep the North Shore Country’s contested case.  Please donate to Keep the North Shore Country (an anonymous Native Hawaiian benefactor is matching donations at this time).  Tax deductible donations can be made online at https://www.keepthenorthshorecountry.org/donate.; personal checks can be mailed to:

Keep the North Shore Country
66-250 Kamehameha Hwy, Suite D103
Haleiwa, HI 96712

*  I am a volunteer member of the community applying my math, science, and mapping skills to opposing this project on my weekends and periods outside work hours.  I present information I believe to be true based on my personal research as a member of the public and information compiled by collaborators and the various non-profit entities engaged in addressing the Na Pua Makani Wind Farm.

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