Social and Economic Justice

The proposed Na Pua Makani Wind Farm’s EIS attempts to discount the adverse effects the wind farm would have to noise levels in Kahuku Neighborhoods, schools, and hospital.  The adverse effects would not meet legal public health requirements; adverse effects could be avoided by building the wind farm on land away from communities.  The two existing North Shore wind farms are located 1,200 meters from residents, the proposed Na Pua Makani Wind farm would be 205 meters from the closest residence and 480 meters from Kahuku town.  These very large, loud, close wind turbines would reduce property values in Kahuku by an estimated $40 Million.  The Na Pua Makani Wind Farm EIS indicates “Adverse effects to property values not anticipated.”  Na Pua Makani’s 2016 EIS also asserts 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.  These harms could readily be avoided by situating the wind farm in undeveloped areas not adjacent to a town.  Na Pua Makani presents their renderings of what the turbines would look like using deceptive panoramic angles.  The view pictures shown in the image at the top of this website were clipped out of the panoramic mock-ups (on page 622 of their SFEIS):

Their rendering panoramic makes it look like the wind farm is out in the country with no homes around


Na Pua Makani presents the wind farm view effects in the EIS using a deceptive panoramic angle (top).  The photo on the bottom left is clipped directly from their panoramic view.  It show the view of rooftops of Kahuku town and proposed turbines in the “background” viewed from the Kahuku public golf course location.  The photo on the right is clipped directly from another EIS panorama, showing the proposed turbines in relation to Kahuku Elementary School.

The EIS summarizes effects to Visual Resources as: “Moderate, long-term adverse impacts due to Project visibility mitigated through design and lighting measures. Project most visible from locations within 1 mile (1.6 kilometers from wind farm site).” (ES-14).  Mitigation would mean not selecting the largest turbines available and placing them right next to a town, it would entail not putting a wind farm adjacent to a community.  Regarding “project most visible from locations within 1 mile” – certainly an understatement.  More EIS quotes:  “Although the larger turbines would create slightly more visual contrast on an individual basis, the degree of increased contrast would not be sufficient to result in a change to the overall visual impact of the wind farm at any site.”  I’m not sure the EPA and DPP (who the wind developer is trying to convince the wind farm meets the preservation of scenery goals of the Koolauloa Sustainable Communities Plan) or the public would be mislead by this statement because I can’t even figure out what it means.

Night-time Nuisance Noise Exceeding Legal Limits:  With apparent disregard for environmental disclosure laws (and for the position they would be putting any Federal or State agency decision based on their EIS, Na Pua Makani’s EIS fails to fully disclose to Federal, State, and County permitting agencies how noisy the wind turbines will be in residential areas.  The existing Kahuku and Kawailoa Wind Farms are both situated more than a kilometer downwind from 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 14aThe 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:

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   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%.  If the State Health Department decides the noise ordinance should be waived for wind farms rather than require wind farms utilize land away from residences instead, the wind developer should be required to compensate the residents for loss of property value (as is done in Denmark, the World capital of wind farms (though Denmark would never allow a wind farm this close to residents in the first place).

1200 Meter Buffer Kahuku and Na Pua Makani May 14

The wind farm would be so close to Kahuku, it would also result in significant turbine flicker and low frequency noise above 65 dB in Kahuku Town.  Low frequency 16 Hz sound levels above 65 dB correspond to the onset of adverse effects; low frequency 16 Hz sound is not heard by our ears, it is felt by our bodies.  Church organs and sub-woofers produce this type of sound.  Your body feels it rather than your ears hearing it (auditory hearing threshold is immaterial).  Low frequency 16 Hz sound caused by the wind farm would exceed 65 dB at Kahuku’s upper subdivision, the two schools, and the hospital and this adverse effect could be eliminated by moving the wind farm away from the town.  The EIS indicates the 65 dB low frequency noise would be masked by existing noise, even though no such noise currently exists in their residential area noise monitoring data.  Their EIS indicates “2.3.1 15BANSI S12.9 Part 4 The ANSI S12.9 Part 4 (ANSI 2005) provides guidelines for determining annoyance from sound propagating outdoors. Annex D of ANSI S12.9 Part 4 includes methods for assessing environmental sounds with strong low-frequency content. Annoyance is found to be minimal when sound levels in the low frequency midband frequencies of 16 – 63 Hz are less than 65 dB, which corresponds to the threshold for the onset of impacts in these lower frequencies. Part 4 also states that LFN passes through structures with relative ease and is nearly equal to outdoor predicted sound” “Negligible low frequency noise/infrasound impacts.” Page ES-6. Infrasound: “The nearest legal residence is located 814 feet (248 meters) from a proposed turbine. Low frequency noise/Infrasound level is predicted to be 83 dB at 8 Hz and 76 dB at 16 Hz which are both well below the threshold of human hearing and the DEFRA limits but higher than the ANSI S12.9 Part 4 guideline of 65 dB at 16 Hz. With regard to the 65 dB ANSI S12.9 Part 4 guideline, because the baseline sound levels are already above this threshold, the likelihood of complaints is low given that the low frequency noise/infrasound would be at least partially masked by existing low frequency noise / infrasound. Therefore, there is no anticipated low frequency noise / infrasound impact from the Project”.

Low frequency noise from the two existing distant wind farms caused families with sensitive children to sell their homes to move because their children were unable to sleep after wind farm construction (more than 1,200 meters from the homes).  Prior to moving, one family had to take their child down the coast in their car, away from the wind farm, so the child could get some sleep.

(Note, the noise study appears to have been conducted when the project entailed shorter turbines – oddly, when the developer switched to taller turbine heights, they also moved the turbines 43 meters closer to the town, from 248 meters to 205 meters).

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 natural and human environment:  We love clean energy but the costs of the proposed Na Pua Makani Wind Farm are too great in light of readily available alternatives, including situating 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 solar doesn’t kill wildlife.

The Na Pua Makani should be required to honestly reflect the realities of the project effects to the Kahuku community in their EIS and the developer should be required to locate their project away from communities to minimize effects of noise to residential areas and schools (not to mention our hospital).  If a developer wants to build a wind farm, they should follow the law rather than attempt to disguise the project’s various failures to meet noise ordinance, community plan, NEPA, and other legal mandates designed to protect the public from just this type of project.