STATE OF THE ART IN COMMENTING ON WIND FARM APPLICATIONS

 COMMENT ON DRAFT SCOPING REPORT

EIA FOR PROPOSED KLIPHEUWEL/DASSIESFONTEIN WIND FARM AND ASSOCIATED INFRASTRUCTURE, NEAR CALEDON REF SUSTAINABLE FUTURES (DEA REF 12/12/20/1746) OF MAY 2010

SUMMARY OF COMMENT ON THE SCOPING PROCESS

The general objectives of integrated environmental management laid down in NEMA include “to ensure adequate and appropriate opportunity for public participation in decisions that may affect the environment”.  A large-scale Wind Farm, the subject of this proposal, has not yet been constructed in SA, so the only understanding the public can have of the implications and impact of such a facility comes from the media or from the EIA process. It is regretted that in this case the EIA Scoping process, although very professionally presented has been very one-sided, selectively presenting material favourable to wind power.

The worldwide population of tens of thousands of large wind turbine generators has created such an intensity of environmental, technical and economic argument that the approval of each proposed facility must only be given after highly competent and professional consideration. In this case, it is considered totally unsatisfactory to evaluate this particular Wind Farm only, and to ignore other options that could meet the defined needs for renewable energy.  Furthermore, although it is generally accepted that electricity generation, transmission and consumption in SA are in dire need of major restructuring, and that renewable energy sources are of crucial importance, the opportunity to evaluate the whole situation, particularly in the Western Cape, has not yet been taken. The sheer number of current applications for environmental approval suggests that this should be carried out urgently. It is therefore considered essential that the draft Scoping Report is fundamentally enhanced to include a proper understanding of Government Energy policies, the implications of the latest NERSA feed-in tariffs, the consequences of the latest Eskom/Government consumer price increases for users, changes to the selective energy subsidies to South African industry, and the sustainability of Wind Farms in general. It is unfortunate that the Dept of Energy's Integrated Resources Plan(IRP) program has only just been started, and will not be completed till after the deadline for this Report. It is assumed that the implications of the IRP will be considered as part of the EIA?

BACKGROUND

Wind power worldwide has grown by an average 29% per annum for the last 10 years. In the UK, there are 6229 turbines installed or in progress, with a total generating capacity of 13348 MW (gross), but an actual contribution to the grid of maybe 4000 MW. In the planning stages, there are a further 3470 turbines which will maybe contribute 3000 MW more. In total, this capacity is claimed to be equivalent to saving the need for 2-3 large conventional power stations.  Nevertheless, there are increasing signs of public and institutional concern over a number of technical and commercial issues involving not only the construction and operation of these Wind Farms, but also the area of climate change, carbon emissions etc. In the Cape, Eskom's demonstration Wind Farm at Klipheuwel is only about 3 MW, and has only been generating successfully for 10% of winter and up to 35% of summer months. The installation at Darling is a private venture of about 7 MW (gross) size, due to be expanded later with 16 additional machines, and is under contract to supply 'green electricity' to Cape Town Municipality. Eskom's proposed 200 MW farm near Vredendal is currently expecting environmental approval.  The SA national target for 2013 is a contribution of 10,000 Gigawatt-hours per year (which is equivalent to about 1141 MW of generating capacity) from renewable sources, with the possibility of achieving much of this target by solar water heating alone.

THE WESTERN CAPE

Available power from the local grid in 2007 was given as 2500 MW, plus 1000 MW extra power specially to meet peak needs. Up to 2500 MW is also available from the national grid. The Cape's total demand was 19,000 Gigawatt-hours, initially expected to grow by 6% per annum, now reduced because of the global situation.  Targets were set for 12% of total electrical consumption by 2013 to be generated from renewable sources (to be increased to 18% by 2020). Institutions (including Municipalities) will be expected to use 15% minimum of their energy from renewable sources:

Year 2013 Year 2020

Forecast demand: gigawatt-hours 26,000 31,000

Capacity needed: MW 2922 3562

Targets for renewable power: MW 350 640

The Western Cape already has 2 major renewable sources, namely Palmiet and Steenbrass pumped storage systems, with a total capacity of 580 MW, both used primarily to meet peak power needs, but also for pumped supply of water to Cape Town. Two additional potential sites have been identified, totalling 1800 MW.  Together with the proposed 300 MW Caledon Wind Farm on the R43 road a few kilometres north of the N2, 20% of the target for 2020 can already be achieved. We are aware of 10 current applications for Wind Farms in the Cape that could generate the total of 1200 MW of electricity – the total area of land used would be in excess of 740 square kilometres.

THE NATIONAL GRID

Eskom's Annual Report for the year to end of March 2009 reveals some interesting and confusing data:

Nominal capacity: 44,000 MW, reduced to 40,500 MW net capacity (repairs etc).

Total electricity sales 214,850 Gigawatt-hours, equivalent to 24,500 MW.

Average cost of electricity 27.63 cents/kWh; previous year was 19.78 cents/kWh.

Average Selling Price of electricity 24.97 cents/kWh. Loss for year was R 10.2 million.

Over 40% of total consumption is by industry.

Eskom has yet to explain the above figures and confirm the claims that they have special deals with selected major industrial customers with prices as low as R 0.12/kWh. At the other end of the spectrum, the indigent section of the community get an inadequate 50 kWh per household monthly free allowance. Domestic consumers will be paying nearly R 1.00 per kWh in 2010-11.  Generating capacity commissioned in the year was 1770 MW (previous year was 1061 MW).

Target for 2013: 50,510 MW, an increase of 15%.

Target for 2017: 56,560 MW, a further increase of 15%.

The current schedule includes the refurbishment of plant that was mothballed some time ago, the construction of 2 large coal-fired plants and finalisation of the next stage of nuclear power. All this needs to be planned to fit with the decommissioning of older coal plant.

NEED AND JUSTIFICATION FOR THE PROJECT

The Government has given cogent arguments supporting their policies to reduce South Africa's relative dependence on coal-fired electricity generating plant, and to increase the use of sustainable renewable energy resources. This seems to be acceptable to the public in general terms, and represents a broad and adequate description of the basic medium term need.

The proper assessment of need and desirability in the EIA decision-making process requires consideration of the strategic context of the proposal along with broader societal needs and public interest. In this case, the electrical generation and distribution system in South Africa uses capital plant that affects the public environment, uses funds provided by the public and industry/business, and provides a valuable consumer service that should benefit all of the public. NERSA has evidently listened to submissions made after the REFIT 1 proposals of December 2008, and made significant adjustments, which are largely responsible for the recent deluge in applications by Independent Power Producers to construct Wind Farms. The costs, together with the related benefits must be properly assessed in order to define the real need for the program, and not just one individual Wind Farm near Caledon. The need must also be quantified in terms of the benefit to the public in general, who will be bearing most of the costs, and to those other sectors of the community that are effectively subsidised.

In other words, in the absence so far of an EIA process to investigate and assess all the strategic alternatives for implementing the Government's policy stated above, each and every site-based EIA for a Wind Farm should have to fulfil this requirement. It is considered that it should be the Dept of Energy's responsibility to demonstrate conformity of this investigation and assessment using the current IRP process, by one method or the other.

Various claims are made in the Report supporting the justification for Wind Farms, that are considered to be spurious:

• Generating capacity is said to be up to 100 MW, when in fact the theoretical rating of the machines is 100 MW, and the generating capacity over a period of time, because of the erratic, variable and largely unpredictable nature of wind, is only 20-30 MW.

• Wind power is said to be cheapest of the renewable energy sources, without any basis for such a claim. The guaranteed buy-in price from Eskom (NERSA REFIT) is one of the highest, significantly more than the cost of electricity from conventional plant.

• Employment figures are stated to be 20,500 to meet the 2013 target for SA (1142 MW), which averages out at 11 people per turbine – perhaps this includes all the manufacturing of the towers and turbine-generating equipment. If so, it is a shame that all the main equipment is imported.

• It is stated that the EIA process will inform the placement of the machines on site in order to minimise the impacts on the environment. How much displacement from optimum position for wind flow will be tolerated? How will these displacements minimise any visual or other impact?

• The capability of wind power, already at 20%-30% load factor because of the wind variability, to replace conventional base-load capacity is therefore reduced to below 10% because of the need for high response rate back-up plant to ensure steady power output overall. This figure will be reduced even further, maybe to 5%, as the relative % of wind power to total power is significantly increased, as the industry strives to meet existing targets for renewable energy sources.

The DSR claims (section 3.2.2) that the proposed Wind Farm, at a 30% load factor, would replace the same amount of energy that could be generated from coal. Therefore, carbon dioxide emissions would be reduced by 21,000 tons per year. This calculation, based on 1000 grams of carbon dioxide emission per kWh of generated power may apply to 'dirty' coal in SA. However, coal-fired plant is not responsive to rapid demand changes to suit variable wind conditions, so the back-up plant is used for this purpose is gas-fired, with typical carbon dioxide emissions of about 430 grams/kWh. This has been ignored in the Report. It is regretted that such misinformation as this demonstrates, not an unfortunate series of errors, but the desire to mislead the general public into giving its support to the industry.

To summarise this section, it is considered that there is no actual 'need' for this specific Wind Farm in order to meet the accepted Government or Provincial policies for increased relative use of renewable energy generation. Even if the wind parameters in this area did indicate a higher generating efficiency than elsewhere in the Cape (and absolutely no data was provided to even suggest this), it should then still become necessary to evaluate all the alternative locations. It would seem that this cannot be done until the wind atlas of SA, or just the Cape, has been completed.

Furthermore, the current Spatial Development Frameworks for Western Cape Province and Theewaterskloof Municipality do not indicate any strategic need for either a large number of viable wind farms or indeed any specific locations. The IDP only mentions a potential partnership between DBSA and private investors involving one proposed wind farm.  There is certainly no defined need or desirability for another swathe of pristine agricultural hill country to be marred by a 'factory facility' with only a marginal local relevance. 

PROJECT ALTERNATIVES

The EIA Regulations state that all identified, feasible and reasonable alternatives are required to be assessed in environmental, economic, technical and social terms. 'Alternative' is defined as different means of meeting the general purposes and requirements of a proposed activity – location, activity, process or technology, different time or 'do nothing'.  The current DSR does not comply with these requirements. The alternatives identified so far that will be evaluated are turbine rating, turbine blade size, and of course the positioning and alignment of the machines themselves.

It is evident that the actual need or activity that is supposed to drive this EIA process is the need to significantly reduce the carbon footprint of South Africa's power generation plant, to hugely increase the utilisation of renewable energy resources in relation to total usage, and to continue the process of reducing avoidable household and industrial electrical consumption.

Wind Farm power is just one of many means of achieving the objectives above. Some of the others that should be considered certainly in the context of the Western Cape area are:

1. More efficient use of the 2 local pumped storage generators for meeting peak demand.

2. Smart tariffs and usage control to reduce electricity demand (Eskom and municipalities).

3. Solar power generation and water heating.

4. Specific policies to target the proper insulation of all hot water geysers.

5. Building design and space heating.

6. Transport systems.

Some aspects of Government policy should be considered during the EIA as they significantly

effect the economic situations of Eskom and the general public:

• Structured application of Eskom's latest direct and resale prices (e.g. Municipalities), to minimise average and peak demand.

• Costs for Eskom to upgrade the existing coal-fired power stations to various improved levels of carbon footprint.

• Costs and timeframes for Eskom's possible new 3000 MW nuclear plant(s).

• Comparative benefits of concentrating financial resources on accelerated Demand Management and renewable sources such as solar water heating and solar panels.

• Evaluation of Eskom's current selective and loss-making pricing to industry and commerce, in particular how overall employment may be effected by this pricing. If there is a reluctance to assess, not just this particular Wind Farm but all the others now in the approval process, on a more strategic and realistic level then it must be strongly suggested that the preferred alternative for this Wind Farm should be the No-Go one.

  TURBINE TYPE ALTERNATIVES

Although different sizes and designs/manufacturers of the turbines are referred to, one questions the total absence of any discussion of alternative, fundamentally different types of turbine in particular the vertical axis machines, which are reported to be fundamentally less lethal to avifauna. The EIA should examine all alternative designs and compare costs, generating performance and all the environmental impacts which are, individually and cumulatively so negatively significant.

SPECIFIC ENVIRONMENTAL IMPACTS

Noise

The Scoping Report has no data of the number of residents within the area, nor of their proximity to the nearest potential turbine. In fact, reference was made to acceptable proximities of 500 metres. A 'disturbing noise' is defined in the Report as a noise level that exceeds the ambient sound level measured continuously at the same point by 7 dB or more. However, what is not included in the Report, but referred to in America, is very interesting and very disturbing:

• Residential areas background noise levels may be 45–55 dB, whereas rural communities are said to be 35–45 dB. Wind noise levels of 45–100 dB are reported in the low and mid frequency spectrum.

• Low frequency vibration, also known as aerodynamic modulation, especially noticeable at night and at lower wind speeds, seems to relate to the way in which the array of machines is positioned.

There are numerous reports in the media concerning symptoms of sleeplessness, headaches and 'stress', suffered by residents and workers near to the turbines. This should be of enough concern for the farmers in the area and their employees to be informed and warned. Maybe, the proposed turbines have a much lower noise profile than those associated with the complaints? Noise emission specifications for each of the turbine models under consideration should be provided.  Data should also be provided from existing Wind Farms, of similar layout. 

Real Value of wind-generated power

Unfortunately wind is a variable, erratic and largely unpredictable energy source that may or may not be available when required. A turbine starts to generate at a specific minimum wind speed, and produces a variable amount of energy as wind speed increases until a level at which the blade geometry must be controlled to prevent damage.  It is evident that, more especially when wind power becomes a significant mix % of total power, the absence of sufficient wind to generate electricity at a particular time must be compensated for by additional standby capacity from the grid – otherwise there are outages. The grid must therefore be controlled to respond at the same rate as the change in wind power. This must entail the provision of high response standby equipment, available continuously.

The proponents of wind power are still bound to their advocacy for the replacement of base load power (coal or nuclear) by wind power, but with no evidence to substantiate the claim. One view of the German industry is a projection that 48,000 MW of installed wind power would actually replace 2000 MW of conventional power (all other aspects being equal).  As there is no mention of this fundamental problem in the DSR, nor discussion of its solution, the whole purpose of the EIA must be questioned unless this subject is included in the assessment of alternatives.

Maintenance Costs

As the turbine blades get longer, and the towers higher, in order to achieve improvements to wind collection efficiency, blade geometry and control, and energy transfer to the generators – so do the boundaries of experience get breached and safety factors get reduced. Various types of stress failure already are known to occur. With blade tip speeds up to about 280 km per hour, gusty wind conditions and heavy rotating machinery, it is no surprise to hear of blade failures in the industry and more stringent inspection and monitoring systems being adopted. Some Insurance Companies are already requiring blade replacement before the 20 year term.

LED and Employment

The employment situation in South Africa is so bad that any strategic decision to significantly address this preferentially should surely be considered. The published figures show that employment in the conventional base load generating industry is 2 people per MW capacity, 5 for wind power and 35 for solar heating (CABEERE project 2005). As most of the employment benefit from Wind Farms seems to relate to manufacture of the machines and control equipment, and most of this appears to be in Europe, questions need to be asked concerning priorities.  Key conclusions of the Social Study in the DSR claim support by the Theewaterskloof Municipality, because of the job opportunities in the construction and operational phases and the establishment of a new 'Green' Tourism sector. Also referred to is the compatibility of this site with TWK's 'vision'. Where is this 'vision' recorded in an approved policy document? Construction and Operational team numbers and skill levels are identified – just how many will be locally sourced? What training will be available?

A meeting between TWK and the Consultants, during the participation stages of the Monitoring Masts BAR, concerned a Regional Assessment of suitable sites for Wind Farms within the municipal area. TWK proposed a 2 km buffer zone along the N2 with no turbines and, specifically that no turbines should be visible from the N2. Why has this been omitted from the Scoping Report?  Many other renewable energy sectors, both for generating electricity and for reducing its consumption, such as the biofuel, biogas and solar water heating sectors, offer much higher Nemployment opportunities for South Africa, particularly for the unskilled and semi-skilled. With limited Government funding available, it is considered that these options should be preferred.

Visual Impact

However cosy the feelings that some people have for Wind Farms, the resulting factories of turbine towers, and the stark industrialisation of this rural landscape, remain for many years as a monument to the loss of wonderful scenic views and inspiring open spaces with its tragic loss of sense of place. This is after all an area of largely 'contour' farming, typical in the hilly parts of the Overberg. It is very unlikely to become a tourism destination when huge areas of the countryside are covered with hundreds of shiny white metallic towers up to 100 metres high with the added height of 40 - 60 metre long turbine blades. The only mitigation would be to install the towers as far down the slopes as possible, and out of view from the roads (R43, N2 and R406) – maybe with less wind availability and therefore less profitability.

A buffer zone was said to be possible, along the N2 corridor, but its extent was not revealed. From the point of view of tourism, general motorist safety, and visual experience of local residents this could be important if, for example, all the machines were hidden from view behind the ridges. Can this happen? Routing of the service roads so that a minimum only can be seen from the R43 and N2 main roads would also mitigate the visual impact to an extent.

Impact of Construction Process

The DSR reveals the sizes of the tower foundations to be about 400 square metres in area and 2.0 to 3.0 m deep, giving up to 1200 cubic metres of rock and soil to dispose of. How much of this spoil will be used in road construction? Where will the surplus be trucked to? Each tower therefore needs about 3000 tonnes of concrete, to be trucked in (from where?) in convoys. With the possibly rocky nature of some of this area, blasting may have to be used for the foundations and part of the trench system for cables. The extent of this needs to be determined.

On some Wind Farms the concrete foundations are actually buried 1.5 m below ground level, so can be left in the ground rather than be broken up in the decommissioning process. There will also be very significant land disturbance issues with the access roads to each tower in the array. Will the local drainage system be irreversibly changed over 20 years?

Safety Aspects

How much of the site will be fenced and patrolled, during construction and operation? Is cable theft or vandalism perceived to be a problem? Most wind Farms are in remote country and coastal areas. The proposed one is alongside a main road and within easy sight of the N2, both being main tourism routes. There needs to be a full analysis of the impact on vehicle drivers of the unexpected appearance of metallic towers, flickering reflections and, at night, an array of red lights.  The apparent response of the Caledon Airport authority and the CAA to the close proximity of this Wind Farm is very surprising and should be checked again especially with the large development planned at Caledon Airport.

Property Values

With 20+ year contract terms with the farmers and land owners, the financial benefits from the Wind Farm may well seem to be a significant contribution to sustainable farming. However, local municipalities may find, as elsewhere, that claims for Rate rebates to compensate for the negative environmental impacts will have a serious impact on their revenue. In particular, farmers and others with local tourism interests may find that their actual business is not sustainable in the vicinity of a Wind Farm. Resale values of all property within the affected area of a Wind Farm will undoubtedly be at risk. It is not clear if this is taken into account in the contracts with the Wind Farms.

Furthermore, the demand for high value property in premium country areas is related to 'quality of life’, which includes unspoilt countryside, uncluttered views of mountains and hillsides and the absence of continuous noise and bustle typical of large towns and cities. This premium value will disappear in areas dominated by arrays of wind turbines.

Avifauna

There should be on-site checks for bird breeding activity prior to construction in each area, which should form part of the EMP; this should be performed by the appointed avifauna specialist, or his deputy. It may in any case be more prudent to avoid the known breeding periods of Red Data species. As regards avifaunal impacts, research has shown that there should be at least a 2 year study period before installation, and a longer period afterwards to assess the actual impact. The areas in question have in recent years seen an enormous ingress of Red Data Blue Cranes.

As regards available data from the ADU, it is essential that those data from the SABAP2 and other ongoing projects, CAR and CWAC, be reviewed on a regular basis during the EIA process as these programmes are ongoing.  Has the African-Eurasian Migrating Waterbird Agreement, to which South Africa is contracted, been considered? See http://www.unep-aewa.org/about/introduction.htm Constant red lights on turbines may affect migrating birds. It has been estimated that a 70% reduction of avian mortality can be achieved by using blinking lights – perhaps special dispensation could be sought from the CAA for installations such as this?  The combined and cumulative impact on avifauna of this and other planned WEFs in the area is mentioned. The other facilities are supposed to be illustrated in Fig 2. They are not shown, although IBAs are. It is recommended that combined/cumulative impact assessments of neighbouring projects be mandatory (to date, 2 others, one very large are known in this area).

Fauna Report Appendix F

Appendix F, the specialist fauna report has been conducted by a botanist. Why is this? (Appendix H provides an excellent botanical assessment). In the Western Cape all lizards, frogs, toads, tortoises and snakes of the families Typhlopidae, Leptotyphlopidae and Colubrinae are protected animals. However, only the Yellow Bellied House Snake is mentioned. There is also no mention of Cape Dwarf Chameleons. 

Bats.

It has not been sufficiently emphasised that bat mortality is caused more by barotrauma, than from direct impacts. It is however positively noted that a dedicated bat study by Prof. David Jacobs will form part of the EIA process. It is hoped that the combined and cumulative impact on bats of this and other planned WEFs in the area will form part of that study

Flora Report Appendix H The important recommendations regarding the Critically Endangered fynbos and renosterveld habitats are noted, as are the important botanical constraints regarding siting and construction.  The opportunities to formally conserve habitats through stewardship contracts with CapeNature, and the funding and implementation of an Operational Environmental Management Plan are regarded as being critical to the whole process.

DSR 5.6.2 Land use/land cover & vegetation

The habitat assessment in this section (taken from the Fauna Specialist Report, Appendix F) is completely at odds with 5.6.5 Ecological Profile (taken from the Flora Specialist Report, Appendix H). This must suggest doubts about the overall credibility of Appendix F.

Database of I&APs

The following bat specialists have been wrongly designated as ornithologists; Sandie Sowler, Ted Bodsworth and Samantha Stoffberg.

CUMULATIVE ENVIRONMENTAL IMPACTS

The countryside in all its forms, especially in the Western Cape, is one of the main magnets for tourism and therefore for an increasing and sustainable quality of life and employment for local people. As much as some people see a degree of mechanical art in a factory of wind turbines, the reality for most, and certainly for the tourist, is that Wind Farms are a massive visual intrusion with little or no community benefit.  A batch of current applications for 10 Wind Farms in the Cape totals 4000 MW, with a total land use of 740 square kilometres. However, this potential will only generate 1200 MW at an optimistic load factor of 30%, producing just 10,500 Gigawatt-hours of electricity. Scaling this up to the sort of levels of wind generated electricity that some proponents are suggesting will desecrate vast tracts of irreplaceable, open countryside.  The actual viewshed area for the above 10 sites in total is considered to be about 15,000 – 20,000 square kilometres. The cumulative effect of all the new proposed Wind Farms on energy infrastructure costs and the environment is considered to be extreme and therefore must be fully assessed and considered.

SPECIFIC TECHNICAL QUESTIONS REQUIRING ANSWERS FROM THE EIA PROCESS 

(T1) Assuming that the claimed 2km minimum distance between housing and the nearest turbine becomes a legal requirement, to obviate the potential noise disturbance, this will have an effect on the land coverage of this and other similar wind farms. Are the resident households in the area aware of this problem, and that it has become a factor in more developed Wind Farm markets?

(T2) It has been stated that the particular positioning of this Wind Farm, with regard to the wind parameters in the specific area, will allow an improved electricity generation performance compared to the normal 25% - 30% load factor. What is the anticipated range and distribution of usable wind speeds? In addition, is there any pattern to the incidences of wind conditions being too low for power generation, in terms of season, day/night, other cycle etc? Will we be granted access to this wind data, subject to signing of a non-disclosure and confidentiality Agreement?

(T3) Because electricity from wind energy cannot yet be stored, and nor can its generation at a particular time be assured, because of the natural variability and unpredictability of wind, is it possible to replace any base load plant at all, bearing in mind its very slow response (several hours)? If so, how much can be replaced?

(T4) Similarly, taking into account the better response times, what amount of peaking power can be replaced with generated wind power?

(T5) Following the same argument as above, how responsive is base load power output control in relation to smaller but still significant changes in wind power generation? In other words, how much fuel (coal etc) can be saved per Gigawatt-hour by controlling the power stations to match? What is the financial value of this?

(T6) Furthermore, as the relative proportion of generating capacity that derives from wind power significantly increases, it is evident that grid dependence on this extra capacity will also increase, to the extent that a sudden drop in wind across a large area can de-stabilise the grid enough to get a cascading effect and blackouts. What level of backup does Eskom consider suitable and what is the cost effect? The UK grid's target is to maintain instantly accessible backup power equal to 20% of peak demand.

(T7) Is the REFIT contract such that any wind energy generated electricity, surplus to demand at the time, still has to be taken at full cost?

(T8) How will utilisation of both the pumped storage power stations at Palmiet and Steenbrass (580 MW) alter with the new Berg River scheme in full operation? How much change will there be in their availability to meet peak power generation needs?

(T9) What are the manufacturers’ names and model Nos. of the turbines, where are they already in use, what Standards do they comply with, and what particular factors governed their selection?

(T10) What is the nominal electrical consumption of the machines when running up to the lower cut-off wind speeds, and when feathered above the maximum operation wind speeds? Is this power taken into account in the contract with Eskom?

(T11) One of the major quoted benefits from local generation of electricity, from Wind Farms for example, was the reduction in transmission losses because the generators and users are in the same area. Losses of about 1.5% are normal in the main supergrid lines, whereas it is in the existing local distribution lines where the losses are typically 5%-9%. Plugging in extra sources of power throughout the Cape, where the wind is supposed to be, but where the users are mostly not, would mostly incur increased losses. Perhaps, the Consultants can explain otherwise?

SPECIFIC ENVIRONMENTAL QUESTIONS REQUIRING ANSWERS FROM THE EIA PROCESS

(E1) The claim is made of a significant reduction in the carbon footprint of a 100 MW (gross) wind farm. Why does this assume a pro rata replacement of coal burning plant and then also ignore the essential need for standby plant?

(E2) Assuming an optimum position for each turbine tower, in terms of electricity generation, what level of output reduction will be acceptable to mitigate the visual impact of the total farm?

(E3) How is it possible to effectively ignore all the threats to wildlife in the area, and to destroy the views that create such a rich visual experience for local people and tourists, just in order to construct a factory where there is no need for one, to produce electricity at an unacceptable cost?

(E4) Will the contractual arrangements with the farmers allow permanent and regular access for post-installation environmental monitoring of all the Wind Farm areas to accredited experts and organisations in order to assess any threats or damage to any aspect of the flora and fauna system and for their findings to be made freely available to the public?

(E5) Can it be confirmed just exactly how much visual 'evidence' of the Wind Farm will be permitted to remain after decommissioning – for example, the temporary hard standings, roadways, and the tower foundations? Where will the spoil be dumped?

(E6) Reference is made to policy, specifically for the development of Wind Farms in the TWK Municipal area, being included in the SDF and IDP. Will details of these policies be included in the EIA, together with evidence of satisfactory public participation?

(E7) As part of the public education and participation process, will the Consultants produce a series of large and accurate photo simulations of the different views of individual turbines and of the overall farm sections from various typical viewing distances, say 200m, 500m, 2km, 5km, 20km? As far as possible additional simulations should be attempted showing the cumulative impact of this and other known projects in the vicinity.

SPECIFIC FINANCIAL QUESTIONS REQUIRING ANSWERS FROM THE EIA PROCESS

(F1) How much of the tower, turbine and control equipment would be manufactured in SA? How many jobs?

(F2) How many of the estimated 20,500 new jobs, that will arise from meeting the 2013 target of 10,000 Gigawatt-hours of renewable energy, will come specifically from the Wind energy sector in South Africa? Can these figures be substantiated?

(F3) What is the current Government capital subsidy per MW installed? Are there any other subsidies or grants etc available for Wind Farms?

(F4) What would be the increase in base load costs per generated KWh for the following, and will this data be used to compare with Wind Farm costs:

1. Using a higher quality grade of coal?

2. Using the standard fuel gas purification processes currently available?  (F5) The 2009 Eskom annual report revealed a large operational loss, created because of special pricing contracts with a number of large industrial users. Can the implications of these low prices on local and national employment be quantified and confirmed?

SPECIFIC COMMERCIAL QUESTIONS REQUIRING ANSWERS FROM THE EIA PROCESS

(C1) What is the design and manufacturing expertise and experience of BioTherm Energy (Pty)?

(C2) The investment by Denham Capital (USA) suggests that there could at some time be benefits, for example from some form of Tradable Renewable Energy or Carbon Certificates/Credits, that could accrue to parties outside of South Africa. How can the SA taxpayers be assured that this does not happen to their disadvantage?

(C3) How is it intended that the full costs of the decommissioning stage will be guaranteed by BioTherm Energy? Will the procedures be included in an Environmental Management Plan that will be agreed as part of the EIA process?

(C4) The DSR suggests that tourism will benefit, for example from visitors directly interested in Wind Farms. The Visitor Record for the Darling site (several hundred people, from schools, Government Departments, Eskom, etc) really does not encourage much optimism. What evidence exists to suggest the contrary?

(C5) Property prices in the Overberg, especially for those in the Tourism industry, will certainly be affected by the visual impacts and also by the current situation whereby the expectation throughout the area of more Wind Farms to be constructed will grow hugely. Can the Government Departments produce a plan for place and size of all the potential Wind Farms in the planning stages in the Overberg? Will a total limit be set?

(C6) Will Eskom have to upgrade any local substation and infrastructure for this project? If so, what commitments have been made by Eskom and what value?

CONCLUSIONS

The EAP Consultants have not acted in a proper fashion to ensure widespread consultation with interested and potentially affected persons or institutions, such as Eskom, NERSA, Western Cape Provincial Government, Department of Energy etc.  Alternatives, in their widest sense, have been ruled out and ignored. The preferred activity has been stated to be this particular Wind Farm in an already designated area and the No-Go alternative has been defined quite simply as not having this Wind Farm, therefore not being able to meet the Government objectives. This approach seems somewhat simplistic and naïve and unfortunately suggests considerable accord between EAP and applicant.  There are public views that suggest that the EIA process is not yet properly geared to such strategic assessments and comparisons that stem from something as large and complicated as the renewable energy project. Nevertheless, the Department of Environmental Affairs has been mandated by Government to be the prime decision maker for this process. The EAP surely has to take the responsibility to ensure that their part in the process is carried out properly and accurately.

The huge number of current and pending applications for large Wind Farms, primarily in the Western Cape, if approved, could have major implications:

• The targets for renewable energy for 2013 and 2020 will be hugely exceeded, which may not be sustainable.

• Such an accelerated rate of over-development of prime agricultural land and tourism destination areas will prejudice future economic growth of the Overberg.

• The alternative activities of Demand Management Systems, solar water heating and solar power may receive less attention and less funding, which will significantly impact on their socio-economic and employment benefits (which do not apply to Wind Farms).

• An overall concern is that there does not appear to be a holistic oversight of this and many other projects for large Wind Farms in the pipeline by the National and Provincial Departments of Environment and the Department of Energy. The resulting cumulative negative environmental impacts are likely to be very much more significant than the sum of the individual projects.

• Our final plea is to put a hold on all applications for commercial Wind Farms in the Western Cape until:

1. The Wind Data is fully completed and detailed, to allow confirmation of the most suitable places for the location of Wind Farms, from a technical and environmental point of view.

2. There is a full technical and economic understanding of electricity generation from Wind Farms and its control within the grid system.

3. There is full understanding of the economics of wind energy in replacing conventional plant generating capacity, and consequently reducing the consumption of carbon fuels.

4. There is therefore a better basis for alternative decisions to be made on possible redirection of funds to areas, for example, with more sustainable societal benefits such as water heating where electricity savings are huge.

5. Until there has been sufficient time, preferably two years, for professional and independent baseline faunal and avifaunal studies of the facility area to be completed and analysed.

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