December 12, Re: Niagara Region Wind Farm Wind Turbine Specifications Report EBR Registry Number Ms.

Transcription

1 December 12, 2013 Ms. Garcia-Wright Director - Environmental Approvals Access and Service Integration Branch 2 St. Clair Avenue West Toronto, Ontario M4V 1L5 Re: Niagara Region Wind Farm Wind Turbine Specifications Report EBR Registry Number Ms. Garcia-Wright, In my initial review of some of the REA documents, I had identified some concerns related to the Wind Turbine Specification Report as prepared by Stantec in April of 2013 for the NRWC. Below you will find a Gap Analysis with additional information. Notably, a review of the WTSR has demonstrated a lack of accuracy and transparency in the REA documents shown to the public. A review of the Noise Guidelines for Wind Farms indicates that As a minimum, the information must include the sound power levels, frequency spectra in octave bands (63 to 8000 Hz), and tonality at integer wind speeds from 6m/s to 10m/s. (Section Wind Turbines Pg. 8). This is not demonstrated in the Test Reports from Kotter Consultant Engineers. There is an octave band spectra reported at 8.3m/s, but not for 6m/s-10m/s. In addition to this, the Kotter Test Reports do not take Audible Tonality into consideration as they have with the E82 Tests. The Tonality is shown to be 2dB in Table 2.1 (Enercon E101 & E82 Turbine Specifications). I also have noticed that the sound power level from the E82 Turbines is calculated up to 10m/s. In the Test Report for the E-101, it shows a sound power level up to 8.3m/s. Furthermore, I would argue that the Noise Assessment report as conducted by Stantec, was done under the wrong assumptions where worst case scenario of 106dB(A) has not been utilized in the noise modelling assessments. Gap Analysis WTSR MK December 12,

2 Item 13 Table 1 O.Reg 359/09 The Kotter Consultant Engineer Test Reports do not show Octave Band Sound Power Levels for the E- 101 Turbines throughout the frequency spectrum. In section Wind Turbines Pg. 8 Noise Guidelines for Wind farms, it states that: As a minimum, the information must include the sound power levels, frequency spectra in octave bands (63 to 8000 Hz), and tonality at integer wind speeds from 6m/s to 10m/s. It appears (as I am not sure since the E-101 Test Report is in German) that the Engineering Consultants who provided the Test Reports for the E-101 have not included the Tonal Audibility which is reported in Table 2.1: Enercon E101 & E82 Wind Turbine Specs shows a variation of 2dB. 1) Why wasn t the Tonal Audibility included in the Kotter Consultant Engineer Report for the E-101 Turbine when it is shown in the Test Reports for the E-82? 2) Why hasn t the Kotter Engineering Consultants demonstrated an Octave band from 6m/s to 10m/s for the E-101 Turbine Tests? They have reported this for the E82 Turbine. 3) Why is there not a Sound Power Level being used at 10m/s? Why does it stop at 8.3m/s? 4) Where is the Enercon E-101 Updated ISO Specification sheet? Why hasn t this been included? Since the Tonal Audibility is not shown for the various wind speeds, the Kotter Consulting Engineers Test Report for the E-101 should not be accepted since it is not complete. Furthermore, the wind speed is only calculated at 8.3 m/s which is not in accordance with the Guidelines for Wind farms which states it must go to 10m/s as a minimum. The Enercon E-101 ISO is public (for other wind projects that have E-101 s) and shows that at a 10m/s wind speed, the SPL of an E-101 is 106dB(A). The Kotter Consulting Engineers are not following the Enercon manufacturer specifications. Furthermore, I would argue that the Noise Assessment report as conducted by Stantec, was done under the wrong assumptions where worst case scenario of 106dB(A) has not been utilized in the noise modelling assessments. 5) What is the uncertainty value measurement for the tests conducted? It is not clear. WTSR MK December 12,

3 Pg. 7 Section 2.1 Specifications 1) What are the hub height constraints they are referring to from the noise assessment report? 2) Hub height is 135m for T18, 36, 45, 47, 53, 55, 60, 74 3 of these will be E82 or de-rated E- 101 Turbines. Why isn t this hub height used in the Kotter Test Reports for the E-101? 3) Selection of which will be determined through detailed design on condition the final selection meets noise limits in NAR? Where is the detailed design? Have they still not figured this out? Pg. 8 Turbine Specifications WTSR MK December 12,

4 1) Why are they using a 2dB tonality and not 3dB? Where do they get this information from? It is not show on the Kotter Test Reports. 2) Sound Power Levels says maximum power is db(a), but below, paragraph states it is for 95%. 3) What is the Sound Power Level at 10m/s? Pg. 8 Sec 2.2 1) Specific size and design of each foundation Has this been confirmed yet? Where are the geotechnical investigations? 2) Piles will only be used as required what determines if the subsurface conditions require one? 3) Sand is near the Lowbanks area and surrounding the coast, are piles proven to hold in this type of land? Pg. 8 & 9 1) How will the pre-stressing tendons be connected to the foundations? WTSR MK December 12,

5 Pg. 9 Ice Throw 1) What would be considered an extreme weather event? 2) How would the turbine know there is an extreme weather event to shut down the turbine? 3) Recently the Lowbanks area had gusts of wind reaching over 80km/hour, how do we know that the turbine blades can withstand this wind? 4) How do we know the wind blades can withstand high force winds? 3.0 Closure Pg11 Data presented in this report are in accordance with Stantec s understanding of the Project as presented at the time of reporting 1) Has Stantec even seen the Enercon E ISO specifications which show that at 10m/s, wind speed the Sound Power Level is 106dB(A)? WTSR MK December 12,

6 Pg. 18 Enercon WEC Characteristics of an E-101 1) If the Cut out wind speed is at m/s wind speed, why does the sound power level not include noise at those speeds? 2) What is Survival wind speed? Does this imply the wind speed that the turbine would catastrophically fail? 3) What is the likelihood of a 59.5 m/s wind speed? WTSR MK December 12,

7 Pg. 19 Kotter Consulting Engineers 1) It is in GERMAN, you must provide an English version. 2) It appears the hub height is which this E-101 being tested on is only 99m high. How can this Test Report be used when the Hub Heights are not similar to the currently proposed project? The WTSR MK December 12,

8 SPL in the Kotter Test Reports for the E-101 should not be used 124m or 135m hub heights are being used in this project. 3) In section 2.1 of this report It states that the Noise Assessment report has caused specific constraints. If the lower hub height was used in this Kotter Engineering SPL information, the 104.8dB(A) should not have been used by Stantec in their Noise Assessment. 4) Why have they stopped measuring the wind speed at 8.3m/s? They are using the 8.3m/s wind speed and our reports which have been shown using the ISO report from Enercon shows it 10m/s the SPL is actually 106dBA. 5) Tonality is not shown; yet, it is noted in Table 2.1 at 2dB. Why haven t they included the test results with tonality? 6) They are missing the frequency spectrum from 6m/s 10m/s (minimum as per the Noise Guidelines for Wind Farms) Enercon Sound Pressure Levels at 135m hub heights (Not included in the WTSR; however, is widely available on the internet for the E101 Turbine. 1) Why wasn t this Enercon Manufacturer Specification included in the WTSR when it is widely available? 2) Why aren t they using the sound power level of 106dBA as shown above? 3) Can Enercon & the NRWC respectively provide a written guarantee that the E-101 does not have a sound power level of 106dBA? WTSR MK December 12,

9 CONCLUSION: Specifications of the E101 and E82 turbines are summarized in the Wind Turbine Specifications Report. Both wind turbine models have been assessed with two hub height options (124m and 135m) in the REA application to provide operational flexibility. Here are the facts on the discrepancies: The ISO Wind Turbine Specifications Report has not been provided by the manufacturer in accordance with the Noise Guidelines for Wind Farms. The Enercon E-101 ISO is not shown in the WTSR; however is available on the internet for other projects utilizing the Enercon E-101. The Test Reports provided by Kotter Consultant Engineers does not include 2dB for Tonality as demonstrated in Table 2.1. The Test Reports provided by Kotter Consultant Engineers does not include for the E101 Turbines, at a minimum (Noise Guidelines for Wind Farms) the sound power levels, frequency spectra in octave bands (63 to 8000 Hz), and tonality at integer wind speeds from 6m/s to 10m/s. It does include it for the E82 Turbines. Wind Speeds for the E101 Turbine Test Results are only shown to a maximum of 8.3m/s wind speed. This is not worst case scenario and should be calculated to a minimum of 10m/s. Hub Height used on the Kotter Test Reports is for 99m hub heights. The project is committed to a hub height of 124m or 135m. This report is not an accurate representation of the E-101 Sound Power Level. Ms. Garcia-Wright, clearly the Wind Turbine Specifications Report is deficient in the instance of the E- 101 Turbine Sound Power Levels, as well as the additional deficiencies previously identified. The Wind Turbine Specifications Report and the Noise Assessment Report should be returned to the proponent as incomplete. Please advise us as to your decision regarding the above. Regards, Marianne Kidd 3 Hutchinson Rd Lowbanks, Ontario N0A 1K0 WTSR MK December 12,