Wind Energy – Kansas Chapter Position February 2010

Background
Seven major wind farms have been built in Kansas, and currently a number of wind farms are in various stages of planning.  While the Kansas Chapter of the Sierra Club believes that energy conservation is the top priority, we are strongly supportive of wind energy development in the state of Kansas.  The cornerstone of our support is that wind power is a clean, renewable source of electricity generation which can significantly reduce our dependence on fossil fuels, especially coal, a major source of greenhouse gases and other pollutants.  Furthermore, wind energy can help preserve precious resources such as natural gas and help limit the further development of nuclear energy.

However, nothing humans do is without environmental consequences, so the concept of “zero impact” is not realistic.  This applies to wind energy.  Nonetheless, as more sites are proposed for development, we need appropriate safeguards to ensure that wind farms do not cause undue harm to ecologically sensitive areas.

Why wind energy?
One need only read the publications of the Intergovernmental Panel on Climate Change (IPCC) to comprehend the seriousness of global warming.  In the last 150 years we have modified our atmosphere with increasing emissions of the greenhouse gases: carbon dioxide, methane, and nitrogen oxide.  It is especially shocking that atmospheric carbon dioxide has increased 38% above levels that we know have been steady for over a thousand years (280 ppm).  The IPCC states that wind power is an important mitigation opportunity that can offset projected growth of global GHG emissions or even reduce emissions below current levels.

It behooves all of us to think of our children, and our children’s children, as we look for sustainable energy sources and lifestyles changes.  This problem is serious enough that we may have to accept certain tradeoffs with respect to our economy and with respect to less serious environmental impacts related to land use.

Can wind energy make a difference?
Absolutely.  Only 5 wind sites with 80 – 2.5 megawatt turbines could produce a total of about 1000 megawatts at optimum wind speeds, or an annual average of 400 megawatts when accounting for typical net power production at good sites in Kansas (40% capacity factor).  A 100 megawatts rated wind farm would average 40 megawatts production during the year, and that is not small.  Kansas has numerous fossil fuel/internal combustion municipal power plants producing less than 10 megawatts.  For reference, the Wolf Creek nuclear power plant produces about 930 megawatts, and the Lawrence Energy Center about 450 megawatts.  Westar Energy, which supplies electricity to eastern and central Kansas, has a total capacity of 6500 megawatts and a typical average output of about 3400 megawatts.  So a relatively small number of wind sites could easily supply over 12% of Westar’s power production and reduce either coal or natural gas/fuel oil use.

Why develop wind energy in Kansas?
Wind speeds and reliability places Kansas as one of the top three states in North America.  In general the highest potential winds power regions are located in the southwest part of the state and in the eastern Flint Hills.  However, almost the entire state, with the exception of the extreme eastern region, has sufficient winds speeds to support wind farms.  In addition, certain landscape features in any region can significantly increase wind energy potential at a particular location.

Placement of Wind Farms.
The availability of high voltage transmission lines is a primary factor dictating the location of wind farms.  A majority of these lines are located in the eastern and south central part of the state, including several that run through the Flint Hills.  Unfortunately, there are no major lines in northwestern Kansas and those that do exist do not serve major population centers in eastern Colorado or eastern Kansas.  Due to the high cost of construction, up to a million dollars per mile, it will take a number of years to get new transmission lines in place.

The placement (siting) of wind farms in some areas of the state has been controversial.  Should sites only be allowed in western Kansas or should development be considered for the entire state?  Do we allow wind development in the Flint Hills region?

Potential Environmental Impacts.
Wind power is not new to the United States and has been especially prominent in California since the early 1980s.  We can learn from some of the mistakes in California and prevent poor site location such as the Altamont Pass area east of San Francisco Bay where significant raptor (Golden Eagle) kills have occurred.  Bird fatalities can be prevented if environmental assessments are completed prior to site selection that identifies critical wildlife habitat and breeding areas.  Recent data indicates that very few birds are killed by the newer designs of wind turbines, though a study in Kansas is ongoing at several wind farms.

There is little evidence that controlled development of wind sites in Kansas will cause irreparable harm outside of the actual footprint of the facility.  However, because of its widely appreciated scenic values and iconic status, the Kansas Chapter supports the Governor’s ban on utility scale wind farms in the “Heart of the Flint Hills” area.  We disagree, however, with wind farm opponents that wind farms should be kept out of other scenic regions of Kansas.  In fact our study of this question (see Analysis of Governor’s Wind Power Goals) shows that even if all the wind farms envisioned by the Governor’s 2020 goal for renewable energy were placed in scenic regions such as the Flint Hills, Smokey Hills and Red Hills, only 2% or less of the land would be affected.

It is conceivable that wind development may help preserve scenic areas by giving farmers, ranchers and rural communities needed income and an economic alternate to CAFOs, and other undesirable agricultural practices.  It is no secret that the major threat to the wildlife in the Flint Hills is the practice of annual, early spring burning followed by double stocking of cattle through the summer.  What does the future hold for the Flint Hills and other scenic areas as global warming encompasses the planet?

Wind power in Kansas can be a positive force in our efforts to fight global warming.  With close monitoring, wind farm siting can be done in an environmentally acceptable manner.  In any case some people will find wind turbines visually unappealing.  However, beauty is in the eye of the beholder.  As one environmentalist said, “Wind towers are not ugly—in fact they give many of us hope in this otherwise dreary eco-political landscape.”

Chapter’s Position on Wind Farm Siting in Kansas

General criteria for site selection.
Aside from the area designated by the Governor as the “Heart of the Flint Hills” we think that all regions of Kansas should be open to wind power development provided proper safeguards are taken to ensure that environmental impacts are limited.  However, whenever possible, wind farms should be located where human development has already significantly disturbed the site.  Evidence of existing development can be:  the proximity of state and federal highways, an extensive network of local paved and gravel roads, power transmission lines and telephone poles and lines, regularly used rail lines, communications towers, oil and gas production and transportation facilities, rock quarries and mines, commercial and industrial buildings including food processing facilities and grain elevators, feedlots/CAFOs, large farm buildings along with a high density of fenced fields, and crop lands in use.

We also consider pastures that have suffered excessive range burning and overgrazing to be disturbed areas.  In fact, unplowed ground used as cow pastures is not equivalent to original or functioning prairie if they are not managed to maintain native wildlife habitat.  On the other hand if such practices are stopped, then this land can be restored.

Mitigation.
When a wind farm is proposed in a relatively undisturbed area outside of the “Heart of the Flint Hills” that potentially could be restored to support grassland birds, then the Chapter would find acceptable such a site only if the developer agrees to a mitigation plan intended to restore a comparable area of land outside of the footprint of the wind farm or elsewhere in the Flint Hills.  Such a mitigation plan must address and prohibit excessive burning of rangeland and overstocking of cattle in accordance with recommendations of independent scientists who are expert in that field.  These criteria may also be applied to other Kansas regions at sites that are potentially wildlife habitat, though excessive burning and grazing are usually not a problem outside of the Flint Hills.

Critical habitat.
Critical habitat, such as Cheyenne Bottoms and Quivira National Wildlife Refuge, should be avoided, and turbines should be kept five miles away from significant water bird resting sites along flyways/migration routes.

Viewscape.
Wind farms should be set back 8 to 10 miles from officially designated scenic byways.  However, opinions differ greatly about the appearance of wind farms, and this issue should be resolved through the local political process.

Project Development

Public communications.
Developers should hold meetings with neighbors and the public prior to the application for permits and zoning.  The developer/company should provide a history of current installations in the region and other states.  Officials and environmentalists in other states should be contacted to see if there are any ongoing problems with the sites.  All environmental commitments should be in writing from the appropriate officials.

Wind farm construction and maintenance
.
All site preparation should include an environmental impact study, especially including birds and bats.  Wildlife studies should be performed during all seasons and capture any diurnal fluctuations of animal populations.  The company should also continue bird impact studies during the life of the project.

There is plenty of land in Kansas.  Thus, turbines should be set back at least 2000 feet from residences unless permission is given by the resident for a shorter distance.

The footprint of the project should be as small as possible.  Towers should be arranged so as to minimize access roads, i.e. only one road should be necessary to service the towers.  Roads should not be built on terrain where erosion cannot be controlled.  Access roads should be narrow (no more than 10 to 12 feet) and the power cables should be buried right next to the road.

Towers should be plain with no advertisement or company logos.  Tower aviation lighting should be white and arranged to be as unobtrusive as possible.  Lighting should be arranged so that it faces upwards and is not as visible from ground level.

Site buildings should be constructed of native materials so as to blend in with the surrounding environment.

Site clean-up should be well defined.  Lay-down areas for tower assembly should be small and completely restored once construction is complete.  Once the site is operational it should be kept clean of construction debris, discarded parts, and any other material that makes the site resemble an industrial complex.  The exact composition and application rate of grass seed and vegetation should be clearly defined.

Decommissioning of the turbines.
Before site construction begins the developer should be bonded so as to require site clean-up and turbine clearance upon decommissioning.

A clear threshold should be defined to determine when a site is no longer active and remediation is to begin.  For example, a site may contain 50 towers of which only one is kept active.  In many cases a lone tower might legally define the entire site as active so as to skirt any environmental remediation.

When a site is declared to be abandoned or inactive the towers must be disassembled and transported from the site.  Foundations must be removed down to plow depth or greater.

 

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