Zoning Board must make positive findings that there will be no adverse environmental impacts resulting from the two Wind Turbines

Two utility scale wind turbines with a blade tip height of approximately 410 feet are proposed for land near a National Wildlife Refuge, and State, Tribal and Private Conservation Areas in Charlestown. The Charlestown Zoning Board will conduct a hearing for a special use permit to build and operate the two wind turbines on Tuesday, May 21, at 7 p.m. at Charlestown Elementary School.

In their decision, the Zoning Board must make positive findings. One of those findings must be that there will be no adverse environmental impacts resulting from the proposal. We do not believe they can make this positive finding.

In November 2011, John Matuza, the town’s building and zoning official, ruled that the Whalerock proposal was not complete. Among the reasons in his ruling were that the application did not include potential adverse impacts to wildlife. The Superior Court has now sent this to the Zoning Board despite the incomplete environmental assessment. The Zoning Board still needs to assess environmental impacts and comply with the wind section and Special Use Permit section of the Zoning Ordinance.

The wind ordinance contains the following language:
Wildlife. The potential adverse impacts to wildlife must be identified by the applicant and shall be minimized through appropriate facility siting and design. The best available mitigation techniques should be utilized to minimize bat mortalities and other known wildlife impacts.

The Best available mitigation technique at this time to reduce bat kills is to have a higher cut in speed. The wind speed at which turbines begin generating electricity to the power grid is known as the cut-in speed. Wind turbines with a low cut-in speed run more frequently than those set at higher cut-in speeds since they begin rotating at lower wind speeds.

By raising the cut-in speed to roughly 11 mph, bat fatalities can be reduced by as much as 93 percent, with an annual power loss of less than one percent. That is, programming the turbines to rotate only when the wind reaches approximately 11 mph or higher causes the turbines to rotate less frequently and, therefore, kill significantly fewer bats.

The site proposed in Charlestown is in a relatively low wind area. The turbine proposed is designed to operate at low wind speeds and will have a low cut in speed known to have the greatest bat mortalities.

In earlier hearings the applicant proposed ultrasound broadcasts to reduce bat fatalities. The effectiveness of ultrasonic deterrents as a means to prevent bat fatalities at wind turbines is limited by the distance and area that ultrasound can be broadcast; ultra sound attenuates quickly and is heavily influenced by humidity. It is broadcast from the nacelle, but has less effect farther out the length of the blade.

The Rhode Island Renewable Energy Siting Partnership also describes higher cut in speeds as the best available mitigation technique to minimize bat mortalities.

The wind ordinance requires “the best available mitigation techniques should be utilized to minimize bat mortalities“. The Whalerock application is proposing cut in speeds too low to minimize bat mortalities.

Bird mortalities can occur from collisions with wind turbines, but compared to collisions with buildings, power lines and automobiles, bird collisions with wind turbines are relatively low. Wind turbine siting issues for birds have more to do with habitat fragmentation and avoidance behavior. Studies have shown some species decline in areas with wind turbines, and that some species directly avoid wind farm areas by maintaining a certain distance around turbines. Charlestown’s National Wildlife Refuge and other nearby protected land is critical to the annual bird migrations along the Atlantic coast. If turbines are sited to cause birds to avoid a stop at the refuge, fewer birds may survive the migration.

The National Wildlife Refuge in Charlestown contains critical wildlife habitat and species listed as federally or state endangered or threatened. The Rhode Island Renewable Energy Siting Partnership recommends that wind turbines should not be placed closer than 1 kilometer to these lands. A kilometer is 3,281 feet. Most of the land on the proposed site is within one kilometer of National Wildlife Refuge land.

Land on the proposed site is within one kilometer of Watchaug Pond, which is part of the Burlingame State Wildlife Management Area. Critical wildlife areas such as Watchaug Pond are also recommended for a one kilometer buffer distance by the Rhode Island Renewable Energy Siting Partnership.

Land on the proposed site is also within one kilometer of conservation land of the Narragansett Indian Tribe.

Because of the extreme height of the turbine blades, the Federal Aviation Administration requires that wind turbines be lighted at all times to avoid impacts with aircraft. Charlestown contains the Frosty Drew Observatory, an astronomical education and science center. Frosty Drew Observatory was recently named by Yankee Magazine as the best location for stargazing in New England. If the lighting of the turbine interferes with astronomical observations, this is not an appropriate location for a very tall turbine.

The above is not meant to replace a detailed environmental assessment of the impacts of siting two utility scale wind turbines at this site. But based on proximity to federal, state and tribal wildlife conservation areas and using the guidelines established by the Rhode Island Renewable Energy Siting Partnership this is not an appropriate site for wind turbines of this size. The Charlestown Zoning Board cannot make a positive finding that “there will be no adverse environmental impacts” from this proposal.


Residents who cannot attend the Zoning Board hearing should send their thoughts and testimony to the Zoning Board by email at building@charlestownri.org or by postal mail to:
Charlestown Zoning Board
4540 South County Trail
Charlestown, RI 02813