RENEW Wisconsin respectfully requests the Commission consider the following comments in response to the Emergency Request filed by Highland Wind Farm LLC on February 22, 2013 (PSC REF# 181219). RENEW Wisconsin is an intervener in this proceeding.

RENEW Wisconsin has reviewed the Applicant’s Emergency Request as well as the exhibits and affidavits associated with that filing. Highland Wind’s filings address the central issue—the ability of this project to comply with applicable sound emission limits–that led to the Commission’s motion to deny the Application at its February 14, 2013 open meeting. Applicant’s Emergency Request asks the Commission not to issue a final order denying Highland Wind’s CPCN at its March 1st open meeting. Instead the Applicant asks the Commission to conduct further discussion of the evidence that is already in the record and, if necessary, to also consider the information contained in the Applicant’s filings as a basis for determining whether the Highland Wind project can comply with the sound limits established by the Commission. Based on our review, RENEW believes that this information warrants Commission consideration. We therefore support Applicant’s request for leave to present additional evidence, as well as its request to allow interveners to respond to its request prior to the next open meeting. RENEW also supports Applicant’s request to the Commission not to issue a final denial order in this proceeding, as well as its suggested procedures and related time frames for presenting additional evidence in a manner that allows the Commission to issue a final order by March 25. 

Discussion: RENEW supports the Applicant’s Emergency Request because we believe that operational curtailment is an appropriate and effective mitigation measure to ensure compliance with applicable sound emissions standards. In fact, we believe that operational curtailment is the most effective tool available to a windpower project operator for reducing sonic output from individual wind turbines to allowable levels. Of the many variables and factors that determine what levels of sound might be measurable at a residence near a wind turbine (e.g., wind speed differential at different elevations, barometric pressure, humidity, background sound levels), the only one that is fully under the project operator’s control is power production.  Operational curtailment limits power generation from turbines, which results in a reduction of sound emissions. The Commission is fully cognizant of the role that operational curtailment can play in controlling sound emissions, as demonstrated by the conditions it imposed on the Glacier Hills wind project in its January 2010 order and by the provisions it approved in the development of PSC 128. In the latter instance, PSC 128.14 explicitly allows project owners to use curtailment procedures to maintain sound emissions below the maximum allowable levels.

Many of today’s utility-scale wind turbines come equipped with automated curtailment protocols that are triggered under a variety of atmospheric conditions. The more sophisticated models can ratchet power production when sensors detect atmospheric conditions that could contribute to long-distance sound propagation. As stated in its Emergency Request, Highland Wind is committed to using only those wind turbine models that are programmed to curtail power output based on real-time atmospheric phenomena such as wind shear. This commitment should remove any lingering uncertainty over whether Highland Wind can operate in full compliance with the sound limits specified by the Commission in this proceeding.

Summary: Apart from the question of whether Highland Wind can comply with sound limits modeled for the Commission’s consideration, this project undeniably advances the public interest in terms of stimulating local economic development, diversifying our region’s resource portfolio, enhancing energy security, and reducing pollution caused by fossil generation sources. We believe that the Applicant is correct that the existing record supports issuance of a CPCN with appropriate conditions.  Moreover, the exhibits and affidavits submitted with Applicant’s Emergency Request fully address any lingering questions that the Commission might have about the project’s sound profile. For that reason, RENEW believes that these filings should be entered into evidence and made a part of the record, so that the Commission has a factually solid foundation for rendering a decision on Highland Wind.

Respectfully submitted this 25th day of February 2013.