Summary of Environmental and Social Justice Concerns

Champlin fails to disclose the serious consequences their proposed project would have to endangered bats and to the vulnerable residents of Kahuku.  In addition, Champlin’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.

Endangered BatsThe facts are, bat mitigation does not help a single bat and what the endangered bat species actually needs is for the wind turbines to be shut down at night to avoid killing the endangered animals.  New research indicates bat mitigation such as removing pigs (ungulates) from the landscape and taking actions such as converting pasture to forest, does not benefit bats, it actually seems to result in a reduction in bat occurrence.

New Research Indicates Mitigation Does Not Work:  The applicant proposes ungulate removal, native forest management, and research to offset take of the bats but there is no reason to think either will help bats.  Monitoring indicates removal of ungulates and native forest restoration harms bats more than it helps them.  Granted, forest birds are helped by ungulate removal because the birds prefer native forest habitat without mosquitoes – but maybe the bat population is supported by the ungulate population and the related dung beetles and mosquito food.  Research will only help bats if the wind farm implements the results of the research – research in and of itself does not benefit even one bat.  Capturing bats in nets, which is often a component of research, injures them.  By law, Hawaii wind farms including Champlin must avoid bat take by shutting down at night until either:

1.) an effective bat deterrent method is implemented at the wind turbine or

2.) an effective bat mitigation method is developed and the wind farm implements it to offset their bat take.  State and federal tax credits are already paying for construction and operation of these wind farms (and ratepayers are paying through the nose for every drop of power they push into the grid, whether it’s used or not) – so don’t do research and then expect us to fund the wildlife agencies to be the ones to implement the actual work it will take to offset your bat take.  Don’t kill it if you can’t offset it yourself.

Additional details about night-time shut down are below.  Note, the reason they must shut down is it is practicable for them to do so – because they can afford to (see: Opportunity Cost of Hawaii Wind Farms).

When the existing permitted wind farms received their incidental take permits and licenses to kill bats (in January 2012 and earlier), it would have been reasonable for the wildlife agencies to have considered that restoring native forest helps endangered bats.  Champlin is the first wind farm proposed since the new information about the ineffectiveness of bat mitigation became available.  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 more likely mitigation is harming individual bats and bat populations.

To Avoid Killing Endangered Bats, Champlin Must Shut Down at Night:  Champlin 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 lighter because bats are flying under light wind conditions).  However, new research indicates the relatively large, strong-flighted Hawaiian hoary bats are still flying around wind turbines at existing North Shore wind farms up to wind speeds of 12 m/s (Figure 1, adapted from Gorresen et al 2015, Figure 19, p. 25 https://dspace.lib.hawaii.edu/bitstream/10790/2585/1/TR64_Gorresen_Bats_Final.pdf).

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, Champlin 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 Champlin’s proposed mitigation fails to offset take of even one bat (as explained below), the wind developer must be required avoid bat take, which would entail low wind speed curtailment when wind speed averages 12 m/s or lower.

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

Social Justice

Champlin’s EIS (which doesn’t seem to be readily available online any more, so here’s a copy:  Champlin SFEIS fails to disclose to Federal, State, and County permitting agencies how noisy the wind turbines will be, situated so close to residential areas.  Na Pua Makani’s 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.

I estimate these wind turbines could reduce property values in Kahuku by an estimated $40 Million.  The giant wind turbines (now apparently 8 turbines, situated 2,000 feet from Kahuku town) would result in a significant loss of property value – certainly no less than 10% in Kahuku, and possibly greater than 25% (see Heintzelman and Tuttle 2011http://iiccusa.org/wp-content/uploads/2011/03/Values-in-the-Wind.pdf).   For these Kahuku residential properties, with an estimated value of $400,000, this wind farm would result in the loss of $40,000 to $100,000 per family.  Because local property value is primarily in the value of the land rather than the residence itself (these are single-wall construction 2 bedroom homes), property value effects in Kahuku could exceed losses observed at mainland residences affected by wind farms.  I estimate the properties in the upper subdivision would lose 25% and the properties on the ocean-side of Kamehameha Highway may only lose 10%.  The adverse effect to property value should be assessed by an independent entity selected by the agencies.

Night-time Nuisance Noise Exceeding Legal Limits:  The existing Kahuku and Kawailoa Wind Farms are both more than a kilometer from any residences; Kawailoa is more than 1,500 meters (5,000 feet) from the closest residence and the Kahuku Wind Farm is approximately 1,200 meters (4,000 feet)  from the closest residence.  My understanding from the DLNR Board is Champlin proposes to build turbines 609 meters (2,000 feet) from the Kahuku town residential area 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 609 meters from the Kahuku community raising serious noise concerns for residents, two schools, and our hospital.  This map is outdated – the exact location of the turbines has not been disclosed.

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.  Champlin’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, particularly when the turbines are upwind from their houses.  These Champlin turbines would be upwind from Kahuku town and half the distance of the existing turbines.

Video from a public hearing addressing noise is online here:

Video of the DLNR Contested Case Hearing

Solar is less costly to ratepayers and less harmful to the environment.  Even burning coal and offsetting the carbon by buying carbon credits with the excess (since this wind farm’s power would be so expensive), would be better for the Earth’s carbon budget than this project:  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 using solar with battery storage instead, and burning coal and paying to plant trees (see: Opportunity Cost of Hawaii Wind Farms) or build solar somewhere less expensive to offset the carbon.

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 addressed the endangered bat aspects of the project in a contested case at the DLNR, with hearings held August 7 and 8, 2017.  On November 1, 2017, the DLNR’s contested case hearing officer Yvonne Y. Izu, Esq. recommended the Board of Land and Natural Resources deny the Na Pua Makani Wind Farm’s application for an incidental take license Hearing Officer Recommends Board Deny License.  Without fixing the fatal flaws such as rejecting the wind farm’s proposed habitat mitigation and requiring the wind farm to shut down to avoid bat take, the Board of Land and Natural Resources approved the wind farm’s permit on May 15, 2018.  Keep the North Shore Country has appealed this decision in State court (so now the State’s attorney’s get to defend a DLNR decision they’d recommended against in the first place).

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 Stop Champlin:  Please donate to Keep the North Shore Country 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

Advertisements