Comment ID: 210822 Comments…

Comment ID: 210822

Comments for Otter Creek wind project, EB 013-1043 drafted July 25, 2017 Turbine model and Noise Impact Assessment Report BACKGROUND The selected turbine for the Otter Creek wind project is the Enercon E-141 EP4. That turbine model has a nameplate capacity of 4.2 MW, a tower height of 129 meters, and a rotor diameter of 141 meters. If deployed, these would be the highest output, and largest wind turbines in Canada. COMMENTARY 1: ENERCON AND OTTER CREEK DOCUMENTATION 1.1: ENERCON'S TURBINE SPECIFCATION REPORT 1.1.1 The first draft Turbine Specifications Report provided by Enercon, and made available on the Otter Creek website, is dated October 2016. That document was later updated with a new version dated February 2017.* Comments directly below Table 1.1, copied below, indicate that the October 2016 timing for publication was for compliance with consultation requirements in O.Reg. 359/09. (start quote) This Wind Turbine Specifications Report was provided to Municipality of Chatham-Kent 90 days in advance of the second public meeting. It was also be provided to First Nations and Aboriginal communities, government agencies and the public for review 60 days in advance of the second public meeting. These timelines align with the distribution requirements outlined in O. Reg. 359/09, as amended. (end quote) * A copy of Enercon's latest specification report can be found here: http://ottercreekwindfarm.ca/wp-content/uploads/2013/06/CER_03a_Wind-Turbine-Specifications-Report- 03.03.2017.pdf 1.1.2 Table 1.1 in the Turbine Specification Report titled “ Adherence to Wind Turbine Specification Report Requirements under O. Reg.359/09, as Amended” claims a noise emission of 105.5 and 104.5 dBA for the 4.2 MW E-141 EP4 turbine, and the 4.0 MW downrated version respectively, with an uncertainty of +/- 1 dBA. 1.1.3 These comments are contained within Table 1.1: (start quote) The acoustic emissions data, determined and reported in accordance with standard CAN/CSA-C61400-11-07, “Wind Turbine Generator Systems – Part 11: Acoustic Noise Measurement Techniques”, dated October 2007, including the overall sound power level, measurement uncertainty value, octave-band sound power levels (linear weighted) and tonality and tonal audibility. (end quote) I would point out the specific wording in Table 1.1 in the turbine specification report: “The acoustic emissions data, determined and reported in accordance with standard CAN/CSA-C61400-11-07...” is ambiguous. A casual reader could reasonably conclude that the emission data was determined by field measurement of an operational turbine as required by CAN/CSA-C61400-11-07. This is not the case as outlined in Section 1.2 below. 1.1.4 The Enercon data sheet included in the February 2017 Noise Impact Assessment Report contains these comments: (start quote) Due to uncertainty in acoustic measurements and serial product variation, the sound power level values indicated in this document are subject to an uncertainty of ±1 dB(A). Therefore, if a measurement is performed in accordance with valid standards, measuring results in the range of stated values ±1 dB(A) may be expected. Standards are TR 1:2008 and IEC 61400-11:2012. If, during measurement, the difference between total noise and extraneous noise is less than 6 dB(A), a greater uncertainty should be assumed. THIS DATA SHEET MUST NOT BE REGARDED AS A GUARANTEE THAT PROJECT OR SITE-SPECIFIC SOUND POWER LEVEL REQUIREMENTS ARE MET. (end quote) (capitals are my emphasis) 1.2: ENERCON'S MEDIA RELEASES 1.2.1 The following media release by Enercon indicates that the FIRST ROTOR FOR THE FIRST PROTOTYPE of the E-141 EP4 wasn't due to be installed until MID-NOVEMBER, 2016: http://www.enercon.de/en/news/news-detail/cc_news/show/News/first-rotor-blade-set-for-enercons-low- wind-speed-wec-e-141-produced/ (start quote) KTA Kunststofftechnologie Aurich GmbH, ENERCON’s rotor blade manufacturer, successfully completed the production of the first set of outer rotor blades for ENERCON’s new low wind speed WEC E-141 EP4. The blades are intended for the E-141 EP4 prototype that is currently under construction in Central Germany. At present the WEC components are assembled at the construction site. “We are well on schedule with the installation,” says Arno Hildebrand, the EP4 programme manager. “THE INSTALLATION OF THE ROTOR BLADES IS SCHEDULED FOR MID-NOVEMBER. COMMISSIONING IS PLANNED BEFORE END OF THE YEAR. (end quote) (Capitals are my emphasis) 1.2.2 The following media release by Enercon confirms that the prototype was scheduled to become operational in late 2016 after the rotor was installed, and that series production would start in 2017. http://www.enercon.de/en/news/news-detail/cc_news/show/News/enercon-announces-new-low-wind-speed-we cs/ (start quote) With its large rotor and a nominal power output of 4.2 MW the E-141 EP4 will generate an annual energy yield of more than 13,000 MWh even at sites with relatively low winds where mean wind speeds are 6.5 m/s. The sound emission remains low at 105.5 dB(A). This makes it the world’s highest yielding wind class III WEC. A PROTOTYPE HAS BEEN SCHEDULED FOR LATE 2016 with series production starting in 2017. (end quote) (capitals are my emphasis) 1.2.3 Since the E-141 EP4 prototype was not operational until December 2016 at the earliest, any noise emission testing by Enercon for that specific model could not have been completed when the draft Turbine Specification Report for Otter Creek was first published in October 2016, and thus are estimates, with a precision of 0.1 dBA, for a turbine that did not exist in completed form at that time. 1.3: OTTER CREEK DOCUMENTATION 1.3.1 The first draft of the Otter Creek Noise Impact Assessment Report, dated November 2016, was updated and posted on the Otter Creek website dated May, 2017. The May 2017 version* includes a letter sent to the MOECC dated May 17, 2017, by Otter Creek representative, Asier Aria. That letter includes the following comment: (start quote) In reference to our REA application (reference: 2629-AKAKE6) for the project, Otter Creek will provide the appropriate sound emission test reports for the 4.2 MW and 4.0 MW Enercon E-141 turbine models within the first 3 months of the Technical Review phase. (end quote) Mr. Asier has acknowledged that the actual E-141 noise emission testing results had not yet been provided to the MOECC by May 17, 2017. *The May 2017 version of the Otter Creek Noise Impact Assessment Report can be obtained here: http://ottercreekwindfarm.ca/wp-content/uploads/2013/06/B4_03a_DO-App-B.pdf 1.3.2: THE TIMING FOR THE TURBINE SPECIFICATION REPORT As noted in comment 1.1.1 above, the first draft of the Turbine Specification Report was published in October 2016 in order to comply with the reporting requirements, in O.Reg. 359/09. Since the turbine manufacturer's media releases indicate that the first prototype of the turbine model would not be completed until the end of 2016, the municipality of Chatham-Kent was provided with a turbine specifications report for a new turbine model that had yet to be built, would not have the first prototype commissioned for at least two months in the future, and, according to Mr. Aria's letter, still had not been fully tested for noise emissions by May 17, 2017. COMMENTARY 2: THE TRANSITIONAL RULES ON TURBINE NOISE EMISSION UNCERTAINTY AND THE GLOBAL GROUND FACTOR 2.1: The updated O.Reg. 359/09 document includes the following changes: i) The requirement for wind project developers to include the positive uncertainty in the turbine noise emission specification to their modelled noise at the receptors. ii) The requirement that the modelled noise at receptors use the global ground factor 0.5, not 0.7 For a turbine with noise emission uncertainty of 1 dBA, the combined effect of the two changes would be an increase of 2.0 dBA in the modelled noise at receptors. i.e. a modelled noise level of 38 dBA calculated using the older guidelines would now be modelled at 40 dBA. This change could require a slightly increased setback between some turbines and some receptor sites. 2.2: The MOECC document: “Updates and clarifications to the “Noise Guidelines for Wind Farms”* EBR decision, EB 012-4493, states the following reason for the transitional rules: (start quote) As LRP I bid proposals were submitted to the IESO shortly after the Ministry proposed amendments to the guideline on August 4, 2015, LRP I PROPONENTS INDICATED THAT THEY DID NOT HAVE SUFFICIENT TIME TO ACCOUNT FOR POSITIVE UNCERTAINTY OR THE CHANGE TO GLOBAL GROUND FACTOR. As a result, a transition rule has been added with respect to LRP I projects. LRP I projects will not be required to include the positive uncertainty value or the reduction in the global ground factor value when conducting noise assessments as part of an application for an approval. HOWEVER, THEY HAVE THE OPTION OF DOING SO. (end quote) (capitals are my emphasis) *The “updates and clarifications....” document can be found through the following link: https://www.ebr.gov.on.ca/ERS-WEB-External/displaynoticecontent.do?noticeId=MTI1NDY0&statusId=MTkxM Tky&language=en 2.3: The MOECC document “Amendments to O. Reg. 359/09 (Renewable Energy Approvals under Part V.0.1 of the Act”,* posted to the Environmental Registry under EBR 012-4493 contains the following statements: (start quote) Consistent with the intent of the regulatory proposal, O. Reg. 359/09 has been amended to provide TRANSITION RULES to take into account projects that are ALREADY SIGNIFICANTLY UNDERWAY. (end quote) (capitals are my emphasis) *The Amendments document can be found through the following link: https://www.ebr.gov.on.ca/ERS-WEB-External/displaynoticecontent.do?noticeId=MTI1MzYz&statusId=MTkxM jMw COMMENTARY 3 OTTER CREEK NOISE ASSESSMENT REPORT OPTS TO USE THE TRANSITIONAL RULES 3.1: The following excerpt from the Otter Creek Noise Impact Assessment Report dated November 2016 and repeated in the May 2017 states their intention to ignore the turbine uncertainty and new global ground factor in O.Reg. 359/09 simply because they are “not required” to do so, while ignoring the intent of the transitional rules as outlined in comments 2.2 and 2.3 above: (start quote) The noise assessment incorporated the manufacturer’s octave band sound level spectrum (from 31.5 Hz to 8,000 Hz) that produced the maximum noise impacts (as per Section 6.2.4 of the Guideline). As the Project is PART OF THE LRP PHASE I PROCUREMENT PROCESS, A POSITIVE UNCERTAINTY VALUE IS NOT REQUIRED AS PART OF THE TURBINE SOUND POWER LEVEL CALCULATION (O.Reg. 359/09, Section 6.3 a), and was not included in the Project turbine sound power level calculations. AS THE PROJECT IS PART OF THE LRP PHASE I PROCUREMENT PROCESS, THE NOISE ASSESSMENT INCORPORATED A GLOBAL GROUND FACTOR OF 0.7 (as per Section 3.1.3 of the Guideline). (end quote) (capitals are my emphasis) 3.2: JUNE 2016 The first draft of the Otter Creek Project Description Report* dated June 2016 has since been removed from the Otter Creek website, but a copy can be provided on request. Section 1.4 in that document states: (start quote) The Project will use wind to generate energy through the use of commercial wind turbine technology. The Project’s nameplate capacity is up to 50 MW and the wind farm will consist of UP TO APPROXIMATELY 19 TURBINES, THE LOCATIONS OF WHICH ARE CURRENTLY BEING ASSESSED as part of the REA process. As a note, the proposed wind turbine technology for the Project is currently under review. THE TOTAL NUMBER OF TURBINES IS DEPENDENT ON THE TYPE(S) OF TURBINES THAT WILL BE USED, THE INDIVIDUAL MW GENERATION CAPACITY OF EACH TURBINE, and potential changes to the overall nameplate capacity. With a nameplate capacity of up to 50 MW, the Project is categorized as a Class 4 wind facility and will be in compliance with the requirements outlined for such facilities. (end quote) (capitals are my emphasis) The publication of the initial Otter Creek Project Description Report in June 2016, indicates that the proponents had not yet selected a turbine model and thus did not have a turbine noise emission, nor had they finalized the number and locations of potential turbine sites. Thus 9 months after the September 1, 2015 deadline for LRP I submissions, and 10 months after the proposed amendments were made public on August 4, 2015, the Otter Creek project was still in the concept phase; it was not “already significantly underway” when they submitted their LRP I proposal. The Otter Creek developers cannot legitimately claim that they did not have sufficient time to account for the turbine emission uncertainty and the new global ground factor when they submitted their LRP I proposal. COMMENTARY 4: SUMMARY COMMENTS 4.1: The October 2016 turbine specification report in the REA documentation, claiming a noise emission with a precision of 0.1 dBA, was not verified with an operational turbine using the CAN/CSA-C61400-11-07 protocol, and appears to have been drafted to meet reporting requirements in O.Reg. 359/09. Thus the Otter Creek Noise Impact Assessment Report, also with a claimed precision of 0.1 dBA, is based on an non-verified estimate. Those two documents cannot be “deemed complete” but were presented to the public for comment as such. 4.2: The wording in the MOECC's “Updates and clarifications to the “Noise Guidelines for Wind Farms” document, and its “Summary of changes to O.Reg. 359/09” document, clearly indicate that the transitional rules were included in O.Reg. 359/09 for the benefit of those projects that were “ALREADY SIGNIFICANTLY UNDERWAY” and “DID NOT HAVE SUFFICIENT TIME TO ACCOUNT FOR POSITIVE UNCERTAINTY OR THE CHANGE TO GLOBAL GROUND FACTOR.” 4.3: The MOECC's “Updates and clarifications to the “Noise Guidelines for Wind Farms”document,, stated that the transitional rules are OPTIONAL, and project proponents with projects at a very early design stage, where the positive uncertainty and global ground factor had not entered into their design criteria, have the OPTION of using the May 1 2016 guidelines. 4.4: The Otter Creek developers would have been aware of the requirements in the updated O.Reg. 359/09 prior to making their turbine selection sometime after June 2016. Their project planning and design, and their Noise Impact Assessment Report, could have easily incorporated the new sound power level requirements and new global ground factor if they had chosen to do so. 4.5: Given the absence of the turbine model and output, and the absence of the turbine site selection, by June 2016, the Otter Creek Noise Impact Assessment Report, produced by AECOM, dated November 2016, would have been started sometime after June 2016. 4.6: As indicated in comment 2.1 above, the inclusion of the positive uncertainty of 1 dBA in the turbine noise emission, plus the use of a global ground factor of 0.5 rather than 0.7, will result in an increase of 2 dBA in the modelled noise at the receptors. i.e. noise modelled at 38 dBA using the pre-2016 rules would be modelled at 40 dBA with the rules introduced in May 2016. 4.7: Based on the modelled noise data in the Otter Creek Noise Impact Assessment Report, 21 NON-PARTICIPATING (NON-LEASEHOLDER) RECEPTORS, as modelled under the transitional rules, WOULD NOT MEET THE CURRENT NOISE COMPLIANCE LIMITS IN O.REG 359/09. 11 OF THE 12 TURBINE SITES WOULD NOT MEET THE SETBACK REQUIREMENTS UNDER THE UPDATED O.REG. 359/09. 4.8: The Otter Creek developers are not justified in using the transitional rules in O.Reg. 359/09. They are requesting the MOECC to award them an REA for a project design and layout that would be completely unacceptable under the current O.Reg. 359/09 standards. The residents in the Otter Creek project zone should not be subjected to any noise higher than necessary for the convenience and expediency of the Otter Creek developers. 4.9: The MOECC Approvals Branch has the authority to deny, delay or modify any Renewable Energy Approval. RECOMMENDATIONS: 1. Cancel the Otter Creek technical review and public comment period: 2. Require the Otter Creek developers to resubmit the E-141 EP4 specification report using noise emission data obtained from an operational E-14 EP4 turbine using the CAN/CSA C61400-11 2012 protocol. 3. Require the Otter Creek developers to obtain and submit all the SCADA data collected by Enercon during the turbine emission testing, including the noise spectrum of the Enercon E-141 EP4 turbine using fast averaging of 200 or 250 milliseconds. 4. Verify the veracity of the reported turbine noise emission by an MOECC noise engineer, and an independent, recognized, acoustician with access to the SCADA data referred to in Recommendation 2 above. 5. Require the Noise Impact Assessment Report is resubmitted using the verified turbine noise emission levels and all the 2016 rules in O.Reg. 359/09