Dear Mr. Marhamati,
I am a 5th generation occupant of my family's property on Roxbury Pond. The proposal to put 22 turbines, all within line of sight to Roxbury Pond, on the ridge overlooking the pond, has been a source of outrage, anxiety, depression, and fear for many members of my family and many of the families who own property on Roxbury Pond. There was a nearly unanimous vote of the property owners' association to oppose this project in the permitting process. The spectre of wind projects destroying the viewshed, polluting the nighttime soundscape, devaluing our property and forever altering the mountain with blasted cuts and massive fills for access roads is a heavy burden for Roxbury Pond property owners to bear. However, if these are insufficient grounds for the DOE to reject the application, there are more important reasons that reach far beyond the concerns of the affected community.
The application of Record Hill Wind LLC for a DOE loan guarantee should be rejected because the applicant has provided evidence to the State of Maine that they do not need the loan guarantee to construct and operate the project since they have $127 million in the bank and the ability to self finance the project. In a filing with Maine Dept of Envioronmental Protection, Robert Gardiner, President of Record Hill Wind LLC provided required evidence that Record Hill Wind LLC had the financial capacity to construct the wind project. In the cover letter to James Cassida, Gardiner said, "Record Hill possesses sufficient funds to complete construction without any additional source of capital." As evidence of these funds Record Hill LLC provided documentation showing $127 million on deposit at Mascoma Bank of Lebanon NH. (See attached copy of DEP submission).
As a taxpayer I am appalled that the DOE would consider using my money to provide collateral for this project. Not only does RHW LLC have the money it needs to construct the project, by admission eliminating the need for the loan guarantee, it has partnered with the Yale Endowment Fund. US taxpayers should under no circumstances be asked to assume the investment risk for the Yale Endowment Fund, which reportedly has assets of more than $8 billion.
I also question the "load control" technology that forms the basis for RHW LLC to qualify for a loan guarantee in the first place. What evidence has been provided that allows DOE to conclude that there is anything groundbreaking about the turbine controller in these Siemens turbines? GE also boasts "load control" technology for its turbines. What is the difference between the two? Is it fair to ask the US taxpayer to subsidize the research and development efforts of either of these companies? Shouldn't their shareholders take the risk for the success of their products?
There are other technoloogies which are far more deserving of government support. Projects which involve electric storage technologies, reduce the cost of solar power, develop more efficient heating and cooling processes, improve the environental impacts of hydrofracking for natural gas, make coal more environmentally friendly, etc should have a higher priority than wind power. Wind projects, without a storage solution, are of little use to the electric grid. The Record Hill Wind project with an installed capacity of 50 MW, will only generate about 12.5 MW on average at a 25% capacity factor. This small amount of electricity may easily be absorbed by the grid without any effect whatsoever on grid operation, since the ISO-NE grid operates with a 125 MW tolerance for supply and demand imbalance. It is well understood that wind generation, because of its unpredictability and intermittent production, must be "followed" with sufficient spinning reserves to regulate the constantly changing output.
The ISO-NE wind integration study is clear that accurate wind forecasts, grid scale storage, and massive and very expensive transmission construction are all necessary to allow wind generation to be effectively utilized. Since none of these necessary components of wind generation are in place, and likely won't be during the lifetime of any turbines now being constructed, it is premature at best to encourage wind power, especially in Maine and other places with high value landscapes. The cost to the taxpayer, to the residents of rural communties subjected to the impacts of wind turbines, and to future generations who will never have to opportunity to appreciate the unspoiled natural beauty of Maine's mountain landscapes far outweigh the perceived benefits of Maine's rush to wind power.
For these reasons the Record Hill Wind LLC application for a US taxpayer backed federal loan guarantee should be denied.
PO Box 345
Oquossoc, ME 04964