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Diamond and Plotnik Benefits of Wind April 8, 2010 1 Alternative Energy for New Jersey: The Benefits of Wind Power Development Over the Long Term by Kimberly E. Diamond 1 and Deborah Plotnik I. Introduction There is a long-term upside for investment in wind turbines on both the utility-scale level and on the small wind/community wind level. This paper explores the nature of these advantages, advocates for the rapid deployment and implementation of wind turbines in New Jersey, and provides an overview of commercial, utility scale wind turbines - both onshore and offshore - in terms of (1) wind power’s positive features relative to global warming, (2) the life expectancy of a turbine, (3) a turbine’s economic efficiency, including cost, grid transmission, and grid interconnection issues, (4) physical efficiency, including examples from European markets, (5) political viability, (6) ecological compatibility, in terms of environmental impacts, (7) time required to bring turbines on-line, and (8) reliability. It also contains a section discussing issues specifically relevant to small/community wind. II. Global Warming Issues and Wind’s Ecologically Positive Features There has been growing concern over the last few decades about the use of non-renewable fossil fuel for the production of energy, especially in the U.S. According to the World Watch Institute, “[f]ossil fuels made the modern economy and all of its material accomplishments possible. But building a low-carbon economy is now the central challenge of our age. Meeting that challenge will require restructuring the global energy industry through technological, economic, and policy innovations that are as unprecedented as the climate change it must address.” 2 Analyzing how the use of non-renewable fossil fuels affects global warming has propelled the use of other forms of renewable energy sources into the discussion. It is widely believed among the scientific and environmental community that global warming is a direct result of the burning of non-renewable fossil fuels - such as coal and natural gas - for the production of energy for industry (i.e., in coal- producing energy plants). Increased concern about global climate change has caused a push to utilize renewable energy sources. Using wind energy is one of the many viable alternatives to the continued burning of non-renewable fossil fuels for purposes of energy generation. Wind energy is the fastest-growing energy source today, and likely the most accessible source of renewable energy available. Wind energy, when properly harnessed, may have an enormous impact on the reduction of the use of fossil fuels that have contributed to global warming.
Transcript
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Diamond and Plotnik Benefits of Wind

April 8, 2010

1

Alternative Energy for New Jersey: The Benefits of Wind Power Development Over the Long Term

by Kimberly E. Diamond1

and Deborah Plotnik

I. Introduction There is a long-term upside for investment in wind turbines on both the utility-scale level and on the small wind/community wind level. This paper explores the nature of these advantages, advocates for the rapid deployment and implementation of wind turbines in New Jersey, and provides an overview of commercial, utility scale wind turbines - both onshore and offshore - in terms of (1) wind power’s positive features relative to global warming, (2) the life expectancy of a turbine, (3) a turbine’s economic efficiency, including cost, grid transmission, and grid interconnection issues, (4) physical efficiency, including examples from European markets, (5) political viability, (6) ecological compatibility, in terms of environmental impacts, (7) time required to bring turbines on-line, and (8) reliability. It also contains a section discussing issues specifically relevant to small/community wind. II. Global Warming Issues and Wind’s Ecologically Positive Features There has been growing concern over the last few decades about the use of non-renewable fossil fuel for the production of energy, especially in the U.S. According to the World Watch Institute, “[f]ossil fuels made the modern economy and all of its material accomplishments possible. But building a low-carbon economy is now the central challenge of our age. Meeting that challenge will require restructuring the global energy industry through technological, economic, and policy innovations that are as unprecedented as the climate change it must address.”2 Analyzing how the use of non-renewable fossil fuels affects global warming has propelled the use of other forms of renewable energy sources into the discussion. It is widely believed among the scientific and environmental community that global warming is a direct result of the burning of non-renewable fossil fuels - such as coal and natural gas - for the production of energy for industry (i.e., in coal-producing energy plants). Increased concern about global climate change has caused a push to utilize renewable energy sources. Using wind energy is one of the many viable alternatives to the continued burning of non-renewable fossil fuels for purposes of energy generation. Wind energy is the fastest-growing energy source today, and likely the most accessible source of renewable energy available. Wind energy, when properly harnessed, may have an enormous impact on the reduction of the use of fossil fuels that have contributed to global warming.

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Today, wind turbines create one of the cleanest ways to produce energy. As more national governments adhere to international agreements on the environment (such as the Kyoto Protocol, the international agreement linked to the United Nations Framework Convention on Climate Change (“UNFCCC”)3) and maintain high domestic standards for environmental protection, then using wind to generate energy for domestic energy needs will play an increasingly prominent role as an alternative energy source. This is because wind energy neither generates pollution or waste, nor contributes to greenhouse gas emissions in the earth’s atmosphere – the major source of global warming. Consequently, using wind energy is an effective means to reduce greenhouse gas (“GHG”) emissions and help address global warming. According to the British Wind Energy Association (“BWEA”), a single utility-scale, modern wind turbine will prevent over 4,000 tons of the greenhouse gas carbon dioxide (“CO2”) from being emitted into the atmosphere annually.4 To illustrate the reduced emissions in GHGs annually from the use of wind energy, compared to using coal, note the following example. An average U.S. household that uses 100% coal-generated electricity requires 10,950 pounds of coal per year, which releases 21,900 pounds of CO2 into the earth’s atmosphere.5 For every pound of coal burned, an average of 2.0 pounds of CO2 is released. The average U.S. household uses 10,950 pounds of coal per year for electricity. When renewable energy, such as wind, produces the same amount of kilowatt hours needed for an average household (900 kWh per month), 21,900 pounds of CO2 is prevented from being released into the atmosphere annually. III. Life Expectancy

A. Wind Turbine System Components

To better understand the life expectancy of a wind turbine, one must first understand a wind turbine’s component system and design. To determine the optimal height, control system, and blade numbers and shapes for a given location and proposed turbine site, aerodynamic modeling is used.6 There are five main parts to a traditional, horizontal axis wind turbine, as follows7:

(1) The Tower. The tower constitutes the structural support component, and typically looks like a gigantic pole that extends vertically from the ground to the nacelle.8 The tower, is typically made of steel plates and sections which are welded together.9

(2) The Nacelle. The nacelle is a cover that houses the energy generating components, such as the gearbox (which converts the low-speed incoming wind rotation to high-speed rotation that is suited to generating electricity), control electronics (electricity switchboards), drive train, rotor shaft, transformer, generator, and brake assembly.10 As an example of the materials constituting certain of these parts, the generator is typically made from steel and copper.11 Offshore wind turbines generally use more copper than onshore turbines, due to offshore turbines’ larger transmissions.12 Generally, the nacelle is

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aerodynamically designed and is made of composite material, such as various types of plastics, with its main foundation being made of cast iron.13

(3) The Blades. The blades include the actual turbine blades themselves, in addition

to a rotor component to which the blades are attached. When the blades turn, the kinetic energy from the wind causes the drive shaft connected to the rotor to turn.14 The blades are made of approximately 40% epoxy and 60% glass fiber.15

(4) The Foundation. For offshore turbines, the turbine itself is mounted on a

foundation that is generally made of reinforced concrete and steel that is covered in corrosion prevention material, such as aluminum, so that the foundation can have a projected lifetime of 30 years.16 The foundation for onshore turbines is similar to that of offshore turbines, but does not use corrosion prevention material.17 In recent years, there have been new developments in the types of foundations used for offshore turbines in particular. For instance, today, there are three common foundation types: (i) the mono pile (consisting of a steel pole that is anchored approximately 30-65 feet into the seabed); (ii) the gravity foundation (consisting of a large concrete or steel base that rests on the seabed, with the turbine relying on gravity to stand erect); and (iii) the tripod foundation (modeled after the foundations used in the offshore oil and gas industry, this technology is used at deeper depths (50-200 meters, which is considered deep water)) which, while having tremendous potential, has not been used on many projects to date.18 Notably, Deepwater Wind, based in Hoboken, New Jersey, has proposed using “jacket” foundation technology which is the standard used in the offshore oil and gas industry, and which can be used in waters approximately 300 meters, or 1,000 feet, deep.19 Turbines with this type of foundation have already been deployed at the Beatrice offshore wind farm in Scotland.20 Use of Deepwater’s jacket foundation technology will enable Garden State Offshore Energy (as further defined herein), to successfully construct its turbines approximately 13 miles off the southern New Jersey coast.21

(5) The Cables. Cables are needed to connect the power generated from the

individual wind turbines to a transformer station, which relays the energy to the existing energy grid.22 Generally, cables are made of copper.23

(6) Offshore Transformer Station (for offshore wind turbines only).24 For electricity

to be transmitted to consumers, offshore wind turbines have two transformer stations. The first is an offshore transformer station, where the cables from the offshore wind turbines connect. From the offshore transformer station, sea cable is used to transmit the energy to a cable transmission station, which in turn relays the energy via external land cable to the second, online transformer station for interconnection into the existing grid.25

B. Overall Life Cycle

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According to a 2006 life cycle assessment (“LCA”) of offshore and onshore wind farms conducted by Vestas,26 there are key differences between the life expectancy of an average onshore turbine compared to that of an offshore turbine.27 Generally, an LCA factors the following to determine turbine longevity: (i) manufacturing and production of the turbine’s foundations, towers, nacelles, and blades, as well as the manufacture of parts connecting the turbine to the energy grid; (ii) transportation via truck (and escorting cars, if necessary) in the case of onshore turbines or via boat in the case of offshore turbines; (iii) construction costs involved in erecting the turbine; (iv) operational and maintenance costs (including the costs of oil changes for gears); and (v) dismantling and scrapping of parts (including the costs of transport from the site to the place of final disposal, including the energy used to shred and otherwise recycle parts).28

C. Projected Lifetime and Servicing

Generally, turbines are constructed to last a “lifetime” of a minimum of 20 years.29 Offshore wind turbines technically have an operational life of up to 30 years, as wear over time has less of an impact on offshore turbines than on onshore turbines.30 Nevertheless, presuming a 20 year lifetime, over the course of this period, it is expected that a turbine will undergo a reconditioning of half of its gearbox or generator, including the replacement of its bearings.31 At a minimum, servicing of a turbine includes changing of the turbine’s oil and lubrication of its gearbox and generator.32 Whether the turbine is an offshore or onshore turbine will determine the frequency of servicing it receives. In the case of an offshore turbine, servicing is expected to occur approximately four times a year – three times by helicopter and one time by boat.33 For onshore turbines, servicing is expected to occur approximately twice a year, where both the turbine and its internal cables are inspected.34

D. Component Recycling

Wind turbines’ component parts may be recycled, with a high percentage recovery of the original materials. For instance, with respect to the following items used in wind turbine construction, it is estimated that approximately 90% of the product can be recycled and recovered, with the remaining 10% being used for landfill: steel, cast iron, stainless steel, high-strength steel, copper, and aluminum.35 Vestas and others, including H.J. Hansen Genvindingsindustri A/S, are now able to harness the energy content from recycled turbine blades through incineration with heat recovery.36 IV. Economic Efficiency (Cost and Maintenance) When evaluating whether investment in utility-scale wind power for New Jersey is efficient from an economic perspective, one must do so with a long-term view. If analyzed in a vacuum, short-term start-up costs may appear cost prohibitive. However, when one analyzes the amount of cost and energy savings that may be realized over the long term from investment in wind, the advantages substantially outweigh the disadvantages. This is particularly true in the area of offshore wind farm development.

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A. General Cost Overview 1. Costs – Overall Costs and Up-Front Costs

According to the American Wind Energy Association (“AWEA”), the cost of wind energy decreased by approximately 90% from 1985 to 2005.37 Although the installation of a wind turbine facility has considerable up-front costs, such as the manufacture of the turbines, the construction of electrical conversion stations and transmission lines from the wind turbine facility to population centers where the demand is located, the long-term financial savings from using wind generated energy production outweighs the up-front, sunk costs. Statistics from the BWEA support these assertions. As stated by the BWEA, an average wind farm effectively pays back the energy consumed during its manufacture within three to five months of such wind farm’s operations.38

2. Turbine’s Size Impacts Cost, as Do Location and Efficiency Factors

The size of the wind turbine affects cost efficiency. The larger the wind turbine, the greater amount of energy that can be produced at a lower cost. Turbine location is an important factor. Locating the wind turbine on a site with a minimum of wind disturbances and a maximum amount of wind flow will maximize its efficiency. The height of the tower is another significant factor. A higher tower reduces obstructions and increases energy output.39 The higher the tower, the greater the wind speed. Higher wind speeds significantly increase the energy a turbine produces, which in turn diminishes the amount of time whereby the investment can be recovered.40 A tower shorter than required is not more cost effective, as it does not produce enough energy and has a reduced life span.41

B. Utility-Scale Wind: Comparative Component Costs of Onshore Versus Offshore Turbines

The cost allocation for turbine components has a different percent allocation for offshore turbines than for onshore turbines. For instance, the four largest costs percentage-wise for the overall cost of an offshore wind turbine are (i) the cost of the turbine itself (33%), (ii) the turbine’s foundation (24%), (iii) the operation and maintenance of the turbine (23%), and (iv) the connection to the grid (15%), with decommissioning of turbine parts (3%), management (2%), and roads and buildings (0%) comprising the balance of overall costs.42 In contrast, for an onshore wind turbine, the percentage allocation is much different. For an onshore turbine, the four highest costs are (i) the cost of the turbine itself (68%), (ii) grid connection (14%), (iii) the turbine’s foundation (9%), and (iv) roads and buildings (8%), with management (3%), operation and maintenance (0%), and decommissioning of turbine parts (0%) comprising the balance (See Table 1).43 Interestingly, the overall percentage costs associated with grid connection for both offshore turbines and onshore turbines are almost identical.

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[Remainder of Page Intentionally Left Blank] Table 1

Percentage of Overall Component Costs

Offshore (%) Onshore (%) 1. Turbine Cost 33 68 2. Foundation 24 9 3. Operation and Maintenance 23 0 4. Grid Connection 15 14 5. Decommissioning of Parts 3 0 6. Management 2 3 7. Roads and Buildings 0 8 A more telling cost overview, though, may be obtained by analyzing the life cycle assessment (“LCA”) of offshore wind turbines compared to onshore wind turbines.

C. Insufficient Grid Capacity, Grid Interconnection, and Transmission Issues Should Not be a Deterrent, Due to Wind Power Potential

Grid transmission and restructuring of the energy grid is a central issue regarding transmission of alternative energy, including energy generated from wind power. A significant issue confronting the electrical industry today is transmission and integration into the electric grid, or, rather, how to deliver the electrical energy generated from wind turbines to where the demand is located. Wind energy is produced when the kinetic energy from wind is transformed into electrical energy. This energy can be harnessed and used by homes or businesses, or transferred via electrical power transmission lines and connected to traditional transmission line cables to the grid used by local utilities company. The infrastructure needed for a wind farm includes not only the wind turbines, but also the infrastructure needed to transfer the wind energy from the wind turbine station to where the demand for wind power is located: transmission lines and, in some cases, electrical conversion substations. When a new wind turbine system does not connect to existing electric transmission lines, this means that new power transmission lines will need to be built from such source of energy generation to the demand centers where energy is needed.44 Things that need to be considered in advance of siting and building new transmission lines include community values, recreational and park areas, historical and aesthetic values, environmental integrity, and

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jurisdictional authority to build in particular areas on certain lands (such as municipal authority-owned land).45 New Jersey currently lacks power lines sufficient enough to support large-scale, meaningful wind power development. This insufficient power line situation is not unique to New Jersey. For instance, in the Texas Panhandle, which, according to Barry T. Smitherman, the Chairman of the Public Utility Commission of Texas, boasts “some of the best wind resources in North America,” the lack of power transmission lines are hindering the ability to develop and transmit wind power to constituents.46 According to a 2009 issue of MIT’s Technology Review (the “Technology Review article”), there are a total of 164,000 miles of high-voltage transmission lines that criss-cross the nation and more than 5,000 local distribution networks.47 The Technology Review article further states that tens of billions of dollars will be needed in order to construct approximately 12,650 miles of new transmission lines to connect wind farms into the electric grid and to help balance their output with other electricity sources and consumer demand.48 The reason for the need for such extensive development of transmission lines, despite the immensity of the already-existing electrical grid network, is because the transmission line network is not located in areas that best take advantage of wind energy sources. The areas of the country that are potentially the best sources of onshore wind energy are located on the “ . . . gusty plains of the Midwest . . .” away from the points of demand that most need it.49 The amount of time that will be needed to upgrade the national electrical grid that includes alternative sources of energy, such as wind energy, may be substantial. Notably, the current energy grid was not originally designed or built with the vision that one day, power from multiple renewable energy sources would flow through transmission lines, need to be connected to the grid at the source of generation, and potentially produce a surplus amount of energy. As a result, transmission and load capacity are not currently suited for an influx of energy on a large scale from alternative energy sources. In fact, renewable energy sources, including wind, are forcing other renewables off the energy grid, due to the grid’s lack of capacity.50 Currently, in other places around the country where utility-scale wind turbines and wind farms are located, curtailment - the situation when the wind power produced from utility-scale wind turbines exceeds the capacity that the current grid line can handle – is a significant issue.51 All states have the ability to enter into long-term contracts for purposes of obtaining a future supply of energy generation from locally-generated alternative energy sources.52 This energy may either be distributed to in-state New Jersey residents, thereby decreasing transmission and delivery costs between the generation source and the ultimate place of power consumption, or can be sold to out of state purchasers. As energy transmission organization statistics illustrate, wind energy has significant potential for powering New Jersey. New Jersey, twelve (12) other states, and the District of Columbia (the “PJM States”) are served by PJM Interconnection (“PJM”), a regional transmission organization

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(“RTO”) that coordinates the movement of wholesale electricity in all or parts of these areas, covering approximately 164,260 square miles of territory.53 Of the active generation in the PJM Interconnection Queue as of September 2009, approximately 44,500 Megawatts (“MW,” or one thousand times one watt) of energy generation – more than half of the total amount of energy generation in the grid interconnection queue - was from wind power, with natural gas (approximately 23,000 MW), coal (approximately 7,800), and nuclear energy (approximately7,500 MW) respectively being the second, third, and fourth largest energy generators.54 As these statistics illustrate, wind power comparatively dwarfs the other sources of energy types in terms of production supply, generating more energy by itself than all other aforementioned energy sources in PJM combined.55 Wind energy’s potential for contributing large amounts of clean energy into the energy grid should not be underestimated, particularly insofar as a number of states, including New Jersey, have set state Renewable Portfolio Standards (“RPS”) targets to utilize wind and other renewable energy sources to meet increasing total energy demand.56 As New Jersey’s RPS Target is 22.5% use of renewable energy by 2021, based on the aforementioned statistics, incorporation of a greater percentage of wind energy into the overall New Jersey energy mix makes logical sense. The problem, though, is that due to the current grid transmission system, a tremendous amount of alternative energy – including wind energy – is imported into New Jersey from land-based sites in the Midwest, where this energy is generated. In fact, there is an immense amount of west-to-east flow of alternative energy across the transmission system. According to PJM’s transmission projections, to provide energy to local New Jersey consumers, New Jersey will be importing a vast of amount of wind energy from the following land-based generation points: wind farms located in North Dakota, South Dakota, and Nebraska.57 Factor the cost of building and maintenance of transmission lines for thousands of miles across the country, through at least seven or more states for each transmission line constructed. The costs are considerable. For instance, the cost of grid interconnection alone is so enormous that billions of dollars will need to be invested into transmission infrastructure to make a cross-country, interconnected grid viable.58 This does not even take into account the economic costs of grid interconnection, delivery, servicing, and workers’ salaries associated with upkeep of such line. This also does not take into account that there are currently no renewable energy deliverability requirements.59 Moreover, when weight is given to all of the vehicles and machinery involved in the transportation and construction process for such an expansive transmission system, the overall carbon footprint created by the use of such vehicles, machinery, equipment, the harvesting, processing, and transportation of the raw materials involved in creating such a Midwest-East Coast transmission system, the relative size of the overall carbon footprint created is enormous. Consideration must be given to whether over the long-term, the “all-in” costs of such transmission lines are an optimal proposition, or if there is another more viable solution.

D. New Jersey Offshore Wind Development Makes Sound Economic Sense Over the long term, the all-in costs of grid transmission installation, interconnection, and delivery would be substantially less for an intra-state delivery system than for transmission lines that run half-way across the country. Therefore, it makes more sense economically for New Jersey to take measures to minimize its reliance on Midwest-generated wind power and to

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generate and deliver wind energy locally from sources in New Jersey, such as offshore wind farms, to New Jersey consumers. It is established in the wind industry that the interconnection points for wind transmission play a major role in the ability to integrate wind energy into the electric grid, even before significant transmission constraints are encountered.60 In fact, according to a January 2010 by the Environment New Jersey Research & Policy Center, installing offshore turbines along the New Jersey coast would minimize the amount of energy lost during transmission due to the energy generation points being relatively close to their delivery points.61 It is perhaps because the potentiality of offshore wind energy has not played a prominent role in the mainstream public consciousness thus far that projections for use of renewable energy in the overall energy mix delivered to New Jersey and the other PJM States is only estimated as being 8% of such mix by 2015.62

V. Physical Efficiency For wind energy, physical efficiency may be gauged in terms of how much energy can be produced by one or more utility-scale commercial wind turbines. Evidence from other countries around the world, in addition to research and findings from U.S.-based organizations and other entities, illustrate that wind turbines, particularly offshore wind turbines, can be quite efficient at converting wind power into vast amounts of electricity. Although they are more expensive than land-based wind farms, offshore wind farms are more efficient because they can harness the power of stronger, steadier coastal winds.63

A. Examples from Other Markets Globally While utility scale wind power is a relatively new concept for many Americans, Europeans have embraced wind power – particularly offshore wind power – as a tremendous source of energy generation. As reported by the European Wind Energy Association, the United Kingdom led all other European countries in 2009 by its installation of 84 offshore wind turbines with a generating capacity of 285 MW last year alone. Other European countries such as Denmark were not far behind in terms of offshore wind turbine installation.64 Specifically, in 2009 Denmark installed 98 offshore turbines with 230 MW of generating capacity.65 Comparatively, in terms of offshore turbine installation, Sweden installed 10 offshore turbines, Germany installed six, and Norway installed one.66 Overall, the total offshore wind power installations in Europe last year totaled approximately 577 MW of power generating capacity, all of which was connected to the European grid.67 This reflects a 57% growth level increase in offshore wind installations compared to those made in 2008.68 The extent to which offshore wind has gained credibility in Europe is further evidenced by the nearly 100 GW of wind farms in Europe currently being planned by project developers and utilities.69

1. Offshore Installations in the United Kingdom Generally, and Scotland in Particular

Residents of the United Kingdom and Scotland in particular have come to embrace offshore wind power and its potential. As illustration, in early January 2010, The Crown Estate, the entity responsible for renewable energy development in the United Kingdom’s surrounding waters,

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announced the successful developers/bidders for nine (9) offshore wind farm zones in Round 3 of its offshore wind licensing program.70 All developers have currently signed exclusivity zone agreements for the respective zones in which they each will be installing wind turbines.71 It is anticipated that this offshore wind program will deliver approximately 32 Gigawatts (GW) - or, rather 32,000 MW - of energy, enough to generate one quarter of the entire United Kingdom’s electricity needs by 2020, and create approximately 700,000 jobs in the process.72 Prime Minister Gordon Brown endorsed this effort, noting that the United Kingdom’s policies in support of offshore wind energy “put [the United Kingdom] ahead of every country in the world” and “will make a significant and practical contribution to reducing [the United Kingdom’s] CO2 emissions . . . .”73 Scotland, in particular, has gained global recognition from the strides it has made toward reaching its goal of generating approximately 30% of its electricity by 2011 and 50% of its electricity by 2020 from renewable energy, primarily in the form of wind power.74 To date, several large offshore wind turbine installations have been made in Moray Firth, a triangular inlet in the North Sea, with additional turbine installations to be forthcoming under the aforementioned Crown Estate wind power expansion plan.75 Together with the upcoming installations in the Firth of Forth, where Scotland’s River Forth flows into the North Sea, approximately 5,000 MW of wind energy is expected to be generated and transmitted for consumer consumption.76 These installations and proposed installation sites, not surprisingly, lend credibility to the findings of a Stanford Department of Civil and Environmental Engineering global wind power study that concluded, among other things, that areas of the world with the strongest wind power potential include Northern Europe along the North Sea, and the northeastern coast of the United States.77

2. Offshore Installations in Denmark Denmark continues to be a global leader in the area of offshore wind power generation. This is not surprising as, since 2007, approximately 20% of Denmark’s energy production comes from wind power.78 Proportionally, this is higher than any other country in terms of wind power integration and usage.79 Denmark, a relatively small country that is 43,000 square kilometers in size, has limited space on its land for wind farms.80 Yet, Denmark has set a goal of having 75% of its energy needs met by wind power by 2025.81 Denmark’s Energy Minister, Flemming Hansen, has previously stated that “[Denmark’s] future belongs to offshore wind turbines and we have to bank heavily on that even if they are expensive.”82 Birger T. Madsen, an expert on renewable energies from BTM Consult (an independent consultant firm that specializes in services relating to the commercialization of renewable energy) noted that, in the context of offshore wind construction in Denmark, “Offshore energy has a future, especially in densely populated countries. It is more expensive (than land-based turbines), but more efficient, as the wind (at sea) is stronger, the turbines are more powerful and they disturb less people.”83 Notably, in 2007, Denmark built its eleventh offshore wind farm (which was also the world’s largest wind farm) in the North Sea, Horn’s Reef (located approximately 10 miles off Denmark’s

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westernmost point, Bladvanshuk), which annually produces 160 MW of energy.84 In September 2009, construction was completed on Horn’s Reef 2, a second neighboring wind farm that generates 209 MW.85 Collectively, both Horn’s Reef projects produce enough energy to power approximately 350,000 homes annually with electricity.86

3. Implications of the Global Financial Crisis on European Offshore Wind Farm Financing

The global financial crisis in 2009 seriously impacted the European offshore wind sector. Of the two sectors most active in the development of offshore wind farms, utilities and independent project developers, the latter were most severely impacted.87 This is because the conservative approach and risk-adverse lending policies many banks have adopted has resulted in a dearth of available project financing for independent project developers.88 Because offshore wind farms and the offshore wind industry generally do not have a long track record, the lack of historical precedent for lending and repayment history in this sector has curtailed banks’ risk appetite for lending in this industry, resulting in banks’ reluctance to undertake syndicated loans necessary for financing large offshore wind farms.89 The European market in this area, therefore, remains constrained by a lack of committed banks and funding, even with funding from development banks.90 Fortuitously, the European Union’s European Economic Recovery Plan helped give the European offshore wind industry a much-needed capital injection of €255 million for six offshore wind farms.91 As a result, government involvement and funding support remains a crucial factor for the further development of the European offshore wind industry. Currently, the European Investment Bank (“EIB”) is playing another critical role in the success of offshore wind farms.92 Specifically, the EIB is lending a total of €600 million in interconnection financing. The first loan is a €300 million loan to Irish TSO Eir Grid for an East-West 256 km transmission cable between Ireland and Wales, the construction of which will begin in 2010 and end in 2012.93 The second loan is a €300 loan for the construction of the electricity transmission cable between the United Kingdom and the Netherlands called the BritNed Interconnector, the construction of which began in 2008 and is scheduled to conclude in 2011.94

B. New Jersey

1. Optimal Wind Speeds Off the New Jersey Coast Make Offshore Wind Development for New Jersey a Lucrative Investment

The examples of Great Britain, Denmark, and Europe generally are instructive for New Jersey and its residents. New Jersey is comparatively small relative to other states in the U.S.; with a total area of 8,722 square miles and measuring approximately only 150 miles long and 70 miles wide, New Jersey is physically the fourth-smallest state in the nation.95 Similar to Great Britain and Denmark, New Jersey has its population densely packed into its relatively small space. Irrespective of other factors, this means that constructing large wind farms close to major

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transmission and distribution centers in New Jersey is relatively unfeasible. Like Great Britain and Denmark, New Jersey has the ability to capitalize on its access to sea winds and the potential wind power they offer through the construction of offshore wind turbines. As noted above, similar to winds in the North Sea, winds off of New Jersey’s Atlantic coastline are conducive to offshore wind farms. According to the National Renewable Energy Laboratory’s Wind Energy Resource Atlas of the United States (the “U.S. Wind Atlas”), offshore wind speeds along and parallel to the New Jersey coast are optimal areas for offshore wind power development.96 As background, the U.S. Wind Atlas contains wind resource maps for various states and areas around the country. Each wind resource map estimates the amount of wind power available in terms of seven “wind power classes,” with Class 1 being the lowest class level and Class 7 being the highest class level.97 Each class spans two ranges of mean wind power density (in units of W/m2).98 Areas with a Class 3 or higher class level designation are suitable for most wind turbine applications, whereas Class 2 areas are marginal. Looking at the U.S. Wind Atlas map for New Jersey, in terms of wind classes, wind development potential off the New Jersey coast is generally twice as great as New Jersey’s onshore wind development potential.99 This is because the majority of New Jersey is rated a “Class 2” in terms of its on-land wind power potential; only a small area extending from Cape May to Atlantic City (approximately 5 miles by 50 miles) in the southern tip of the state and two relatively small bands of areas at the northwestern tips of the state (approximately 10 miles by 50 miles and 7 miles by 30 miles, respectively) are rated “Class 3”, where the wind power density range is between 150 and 200, where wind speeds average between 11.5 and 12.5.100 In contrast, all areas in the Atlantic Ocean immediately offshore of the New Jersey coastline - from Cape May at the southern tip of the state stretching continuously to Sandy Hook at the tip of the northeast shoreline – have a Class 4 wind power rating.101 This means that the offshore wind speed potential has a wind power density range between 200 and 250, where wind speeds average between 12.5 and 13.4 mph.102 This differential in offshore wind potential versus onshore wind potential is significant, as it bears dramatically on the amount of energy that can be converted into electricity. Wind’s energy content and the power that can be derived from it is proportional to the cube of the wind speed.103 This means that wind in an area with an average Class 4 wind speed of 13 mph could theoretically generate 30% more electricity than an area with an average Class 3 wind speed of 12 mph, as the cube of 13 (13x13x13 = 2,197) is approximately 30% greater than the cube of 12 (12x12x12 = 1,728).104 Consequently, even relatively small differences in the wind speed can have a substantial impact on the amount of energy available for electricity production. As these calculations illustrate, the potential amount of energy that can be generated by offshore wind turbines - where wind speeds are greater than land-based turbines – is considerably greater than land-based turbines. The findings of a 2006 life cycle assessment (“LCA”) of offshore and onshore wind farms conducted by Vestas105 illustrate the differential between how much energy a commercial, utility-scale onshore wind turbine produces, versus that of an offshore turbine. According to this study, an onshore wind turbine’s annual production ranges between 6,900 and 9,100

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MWh/turbine, presuming that the turbine is sited in a good location for wind.106 Contrast such amount to the annual production range between 11,300 and 14,800 MWh/turbine of an offshore wind turbine.

2. Implications of the Global Financial Crisis on New Jersey’s Potential for Offshore Wind Farm Project Financing

Similar to the European wind industry, during 2009 and the first quarter of 2010, the U.S. wind industry witnessed first-hand the severity of the impact that access to financing plays in determining how successful the launching of a utility scale wind power project will be. Unfavorable market conditions resulted in wind power project construction to dip in 2009 to levels substantially lower than in 2008, with the 5,000 MW of construction in fourth quarter 2009 being approximately 38% lower than the over 8,000 MW of construction that occurred during fourth quarter 2008.107 This is largely because banks’ appetite for risk has decreased in the current economic climate. As a result, available liquidity in the financial markets is scarce, as banks generally are not willing to take on the project risk as lead arranger in an underwritten deal. Club deals, where banks collectively take on the risk of a single project, are not meeting with great success due to concern such banks have about taking on counterparty risk from the other club members.108 In the U.S., like Europe, federal government funding and programs are a crucial lifeline presently for the funding and further development of domestic wind farm projects. There are currently two federal programs available for wind farm projects. First, there is the U.S. Department of Treasury’s Section 1603 grants program. Through this program, created through a provision in the American Recovery and Reinvestment Act of 2009 (“Recovery Act), wind farm developers who receive payments for property used predominantly in the U.S. in a trade or business used for the production of income under Section 1603 of the Recovery Act can elect to forego production tax credits (“PTCs”) or investment tax credits (“ITCs”) under Sections 45 and 48 of the Internal Revenue Code (“IRC”) with regard to such property for the taxable year in which the payment is made, or any subsequent taxable year.109 Eligible applicants for these grants, though, must have their wind farm originally placed in service between January 1, 2009 and December 31, 2010 (irrespective of when project construction began), or have started construction on the project during 2009 or 2010, with the project being placed in service after 2010 but before January 1, 2013.110 Second, the Department of Energy (“DOE”) is offering a federal loan guarantee program called the financial Institutional Partnership Program (“FIPP”), a new program under the Energy Policy Act of 2005111 (as per amendments from Section 406 of the Recovery Act) created to hasten the deployment of renewable energy projects, related manufacturing facilities, and electric transmission projects, as well as other items.112 The DOE is planning to make approximately $750 million available under the Recovery Act to pay the credit subsidy cost of loan guarantees made for commercial technology renewable energy generation projects.113 After the DOE engages in a rigorous evaluation of applicants who have submitted, among other things, their

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projected sources of finance, project sponsor’s capabilities, permit approvals required, engineering plans, environmental reports, and other information, only those applicants whose projects are the most likely to commence construction on or before September 30, 2011 will be viable for consideration of receipt of a DOE FIPP loan guarantee.114 Additionally, to encourage development of the domestic wind power sector, the Internal Revenue Service (“IRS”), through Announcement 2009-69, made more attractive the prevailing project financing structure for commercial wind farms – the partnership flip structure (where there is a partnership between a wind farm project developer and a tax equity investor, and the latter receives income, PTCs, and losses up to an agreed-upon internal rate of return on the cash investment in the project, and the former receives the majority of the project’s upside; once the tax equity investor’s internal rate of return is reached, the structure “flips” so that the developer then receives the project’s income, PTCs, and losses).115 VI. Political Viability

The endorsement of commercial-grade wind power installations has been, and still is, politically viable for New Jersey. New Jersey’s political receptiveness to the installation of wind farms is evidenced by its installation in December 2005 of the Jersey-Atlantic Wind Farm, an onshore, five-turbine, 7.5 MW wind farm - the first coastal wind farm in the United States and New Jersey’s first (and, currently, only) wind farm - located in Atlantic County at the Atlantic County Utilities Authority (ACUA) Wastewater Treatment Plant, just a few minutes drive from Atlantic City.116 Today, on a state and federal level, the adoption of alternative energy for New Jersey and wind power in particular is an issue that has transcended political affiliations. As illustration, in October 2008, former New Jersey Governor Jon Corzine announced his administration’s Energy Master Plan for New Jersey.117 At the time of such announcement, Corzine stated the following: “I’m pleased to say that today is the first day of New Jersey’s energy future. With . . . potentially the country’s first offshore wind project in the works, our participation in the Regional Greenhouse Gas Initiative, and the most aggressive greenhouse-gas emission reduction targets in the nation, New Jersey has already taken the lead.”118 The goal of the Energy Master Plan is to ensure that New Jersey consumers receive a reliable supply of electricity and heating fuels at a reasonable price, and to set goals and action items that will enable New Jersey to develop the clean energy industry as a key part of the state’s economy.119 In fact, the April 17, 2008 draft of the New Jersey Energy Master Plan Implementation Strategies: A Companion Document to the Draft New Jersey Energy Master Plan” (hereafter, “Implementation Strategies”) contains two entire sections dedicated to wind development in New Jersey: one for onshore wind, and the other for offshore wind.120 The offshore section discusses a strategy of developing a 350 MW offshore wind pilot project (which would produce an estimated 1,000 GWh (gigawatt hours, the equivalent of one billion watt hours) of electricity annually), and the eventual development of 1,000 MW of offshore wind capacity (which would produce an estimated 2,800 GWh of electricity annually), based on ongoing feasibility studies.121 Notably, the New Jersey Board of Public Utilities (“BPU”) awarded this 350 MW project (the “350 MW Project”), located approximately 16 miles off the New Jersey coast (southeast of Atlantic City), for development to

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Garden State Offshore Energy (“GSOE”), a joint venture between Deepwater Wind and PSEG Renewable Generation.122 GSEO is presently continuing to evaluate the 350 MW Project’s environmental impacts, to conduct wind quality assessments, and to proceed with the required federal and state permitting processes.123

Governor Chris Christie, a Republican who took office in January 2010 and who, during his campaign, vowed to be “New Jersey’s #1 clean energy advocate” if elected governor, is continuing to forge ahead with his Democratic predecessor’s vision of supporting offshore wind development in New Jersey.124 This resolve is illustrated in Governor Christie’s Transition Team’s Energy and Utilities Subcommittee (the “Energy Subcommittee”) Report, dated January 11, 2010, on the status of energy in New Jersey ( the “Transition Team Report”).125 The Transition Team Report focuses on how operational and strategic modifications to the BPU’s policies and structure will enable the BPU to more readily be able to play a significant role in New Jersey’s energy industry and overall economic growth.126 According to the Energy Subcommittee, the BPU, which oversees approximately $1 billion in programs including management of the $500 million Clean Energy Program, needs to undergo a structural reorganization to enhance its relationships with the Federal Energy Regulatory Commission (“FERC”) and PJM, improve allocation of Clean Energy Program funds, and focus on the federal government’s role in energy policy issues, as well as the state-wide need for new transmission line siting.127 In addition, the Transition Team Report recommends the creation of a new Energy Master Plan and updated Strategic Plan to better reflect the Christie Administration’s policies.128 One such policy the Transition Team Report mentions is taking an aggressive approach to wind energy, pushing for the development of wind turbine manufacturing, construction, and maintenance in New Jersey, and utilizing New Jersey’s port facilities to encourage offshore wind development, so that the cost of wind energy over the long term will decrease.129 This is significant because unlike smaller 3.6 MW offshore turbines that are generally manufactured elsewhere and transported to a port accessible to the turbine site, larger, 5 MW – 9 MW turbines are so enormous that there is a need to manufacture such turbines at such port.130 Notably, a 3.6 MW turbine in a Class 4 or higher wind area can produce approximately 10,800,000 kWh of energy per year – enough to power over 1,200 homes annually.131 Governor Christie’s goal of having New Jersey ports dedicated to facilitating the manufacture of turbines is in line with a trend that sets companies that engage in such port facility manufacturing far ahead of their competition.132 The Energy Subcommittee further suggests that to stimulate offshore wind development, (i) a renewable portfolio standard (“RPS”) carve-out could be created for offshore wind turbines, (ii) a fairly priced offshore renewable energy credit (“OREC”) be developed as a revenue mechanism, (iii) tax incentives be offered to offshore wind developers who launch offshore wind manufacturing and support services in New Jersey, and (iv) federal and state authorities will need to work together to streamline the time involved in the permitting process.133 In keeping with the goals articulated in the Transition Team Report, on March 1, 2010, Governor Christie stated at a meeting in Trenton with New Jersey Congressional members that he is going to seek the federal government’s assistance in expediting permits for the 350 MW Project, so that the estimated seven-to-10-year review period for receiving the permits for offshore wind farms is

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cut in half.134 Notably, construction on a wind farm project cannot be launched until all applicable permits are received. Even in the case of medium-sized onshore wind farms, bureaucracy and regulatory delays prevent the timely approval of wind turbine applications. There could be a three-year wait for an application to be approved to connect a medium-sized wind farm to existing electrical transmission lines in order to be connected to the regional grid.135 For instance, a wind farm containing between nine and 12 wind turbines, capable of generating 18 MW of wind energy located only 1.5 miles from a transmission line substation may have to wait years to receive grid connection approval, despite its proximity to the grid.136 Permitting, therefore, is a significant component in determining whether and when a wind farm project will be built. According to Christie, “[e]verybody agrees that the number [of years for permitting review] needs to come down. . . .[New Jersey is] going to have one of the most aggressive clean-energy programs on the East Coast.”137 Additionally, Christie and a bipartisan group of 29 governors from across the U.S. have formed the Governors’ Wind Energy Coalition (the “Coalition”), which published in March 2010 its 2010 Wind Energy Recommendations.138 Included among these recommendations to the Obama Administration were proposals to streamline the permitting process for offshore and onshore wind projects, develop new electric transmission infrastructure allowing access to onshore and offshore sources of renewable energy, and support deep water and offshore wind energy technology research and development.139 U.S. Senator Robert “Bob” Menendez, a Democrat from Hoboken, New Jersey, supports Christie’s proposal for expedited review of permit applications. Menendez has been quoted as saying that he will help push for the adoption of such a proposal, and will work “four-square” with Christie to increase renewable energy.140 Noting that New Jersey’s congressional delegation has a long history of working together on “New Jersey-specific issues,” Menendez stated that “[o]ffshore wind energy is a great opportunity for New Jersey to lead.”141 This support at the U.S. Congressional level is significant, insofar as Menendez is a member of the Senate's Committee on Energy and Natural Resources, including the Subcommittees on Energy, National Parks, and Public Lands and Forests, respectively, and he potentially can lobby his colleagues on such committee and subcommittees to support the shorter permitting review period.142 The above developments on the offshore wind development and permitting front are important for the advancement of offshore wind development in New Jersey, as New Jersey’s state government and the federal government need to take a coordinated approach to expedite the permitting process, thereby alleviating the time bottleneck for permit approval. Moreover, as the existing policy framework does not contemplate the transmission system that will need to be installed for large scale offshore wind farms, unified state and federal action supporting offshore wind development is a necessity. New federal legislation, such as the Recovery Act has earmarked approximately $8.5 billion to subsidize loans for renewable energy projects, $6 billion for renewable energy technologies and transmission technologies loan guarantees.143 Therefore, New Jersey’s Governor and state legislature have the opportunity to work effectively to facilitate New Jersey-based businesses

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taking advantage of the opportunities the Recovery Act offers. As a matter of public policy, the time appears ripe to raise and confront the obstacles currently hindering offshore wind development, so that the process for developing resources crucial to building such wind farms and connecting them to a grid transmission system that has sufficient capacity to handle the extra energy generated may be launched in the near future. From an operational perspective, it makes sound economic sense to address the permitting and transmission issues today, as doing so will be less costly in terms of both price and lost opportunity costs than waiting until years from now to do so. VII. Ecological Compatibility

A. Offshore Turbine and Onshore Turbine Environmental Impacts

In terms of the impact that offshore wind farms versus onshore wind farms have on the environment, the overall environmental impacts are relatively identical. However, in terms of hazardous waste and soil toxicity, onshore wind farms have a comparatively higher environmental impact, even factoring in the amount of zinc discharged from offshore wind turbine cables.144 Notably, toxicity modeling and results over the course of a wind turbine’s life cycle is difficult, due to other chemicals in the environment impacting the analysis.145 While an offshore wind turbine yields more electricity output than does an onshore turbine, offshore wind turbines, given their size and location at sea, require more resources than do onshore wind turbines in terms of their installation.146 For this reason, the global warming potential of offshore and onshore wind farms is relatively equal for each kWh produced.147 Significantly, a study conducted by the Energy Research Laboratory of the University of Massachusetts, in conjunction with the Massachusetts Technology Collaborative’s Renewable Energy Trust (the “ERL Study”), found that wind turbines can have a positive impact on avoided emissions.148 For example, depending on the individual turbine’s capacity factor (i.e., a percentage equal to the actual amount of energy produced in a given period, divided by the estimated maximum possible output (running at 100% all of the time)), a single turbine can assist in the avoided emissions of thousands of pounds of sulphur dioxide and nitrous oxide, and thousands of tons of carbon dioxide into the atmosphere annually.149

B. Aesthetics Issues While beauty may be in the eye of the beholder, wind farms tend to be substantially impacted by whose concept of beauty is being applied. In certain instances, wind farm construction has been delayed, postponed, or completely abandoned because of residents or locals who feel the visual impact of wind farms is detrimental to the preservation of the beauty of the landscape in its current form. This has been the case for the Cape Wind project, a 130-turbine offshore wind farm proposed to be located off the coast of Massachusetts in Nantucket Sound. Against that backdrop, certain advances have been made in how visible from the shoreline offshore wind farms can be. Depending on the turbines’ distance from the shoreline, offshore wind turbines can be virtually invisible to the onlooker.150 If offshore turbine visibility is a

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factor for turbine placement consideration, Clemson University’s South Carolina Institute for Energy Studies (“SCIES”) has engineered photo simulation software that can depict what offshore turbines will look like in terms of visibility from the shoreline, when they are placed at certain distances from the shoreline.151 While haze, lighting, and wind conditions can impact turbine visibility, it is evident that when wind turbines are sited further than 7 miles from the shoreline, they are almost non-detectable visually.152 Moreover, offshore wind farms could also become tourist attractions, as has occurred for certain wind farms in Europe.153

C. Ecosystem and Environmental Impacts, and the Role of Environmental Impact Statements

Siting of a wind farm may not be possible in optimal wind locations, due to one or more species of wildlife using the proposed wind farm location as its primary residence. Such species may have substantial difficulty relocating to another area that contains similar geographic and topographic resources to be an adequate replacement venue. As wind farm construction could adversely impact the habitat of federal or state-listed endangered species, regulatory approvals must be granted from various state and federal regulatory authorities before wind farm construction can begin. To the extent a wind farm is proposed for construction on public lands, approval from the United States Department of Interior (“DOI”), Bureau of Land Management (“BLM”) is required.154 Other federal regulations, specifically, the National Environmental Policy Act (“NEPA”), may require wind farm developers to complete an Environmental Impact Statement (“EIS”) for proposed wind farm sites, so that a full and fair discussion of the affected area, a range of alternatives, and an analysis of the impact of each alternative a wind farm may have on a particular area may be aired publicly.155 Native American tribes, state and federal agencies, and other interested groups and parties have the right to comment on an EIS, in terms of wildlife endangerment, historical preservation value, and the like. For offshore wind farms, a host of federal agencies are involved in the approval process. While the FERC and the DOI’s Minerals Management Service (“MMS”) previously disputed which competing agency had regulatory authority over offshore wind farms projected to be built on the Outer Continental Shelf (“OCS”), this dispute was resolved through a memorandum of understanding between the two agencies. Now, the MMS has exclusive jurisdiction to issue leases for wind farms on the OCS, and FERC has exclusive jurisdiction to issue licenses and exemptions for such projects. VIII. Time Required to Bring On-Line

A. Suitability of a Particular Area for Wind Turbine D evelopment

AWEA identifies important steps that need to be followed to construct a wind turbine facility.156 Individually and collectively, the steps AWEA describes can be very time consuming, depending on a number of factors. A lot of preliminary research is needed from all concerned parties to determine whether wind is the proper type of energy source suited for harnessing relative to the energy demand at a particular geographical location. When all preliminary research has been completed, the result may be that another type of energy source (or a combination of different

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types of renewable energy sources) is more suited to meeting the energy demands of residential, commercial, industrial, or public energy purchasers.

B. Siting and Wind Speed Considerations

The first and foremost factor to consider, according to AWEA, is the sources of wind itself. A key factor is whether the desired location for a wind turbine will provide enough wind to generate the minimal amount of power necessary for the wind turbine to operate. A wind turbine requires a minimum amount of wind power over a sustained period of time for it to be an effective alternative source of energy. To determine whether a site is conducive to wind turbines, preliminary research needs to be gathered, including data about the average wind speed at the proposed turbine location. Studies indicate that a minimum wind speed of 10 mph or more is the necessary wind force required to power a wind turbine.157 Wind speed data can be gathered from a number of sources. While the ideal situation is to gather at least a year of data, doing so may be unrealistic, very time consuming and expensive. Wind speed data can be obtained from both government and private consultants.

IX. Reliability

Wind is a reliable resource in terms of its availability and in terms of overall maintenance, energy generation, and integration into the grid. According to the ERL Study, commercial wind farms are relatively reliable, insofar as they are not turned off for maintenance or repairs very often.158 “Reliability” is distinguishable from “dispatchabilty,” as the latter refers to the ability of a power generation plant to be required to achieve a desired level of output quickly; wind farms and wind turbines are not dispatchable.159 Wind speeds tend to vary, depending on the location of a particular turbine. Over land, wind blows intermittently, and blows at different levels during the day than it does at night, due to differences in air pressure, caused by the heating and cooling of the earth at a given location.160 Because winds do not constantly blow, the percentage of time a turbine actually produces electricity is lower than its availability, as “availability” refers to the amount of time as a whole that the turbine is able to operate.161 In fact, the BWEA has indicated that while wind turbines generate electricity between 70-85% of the time, they typically only produce 30% of their theoretical maximum output annually.162 Improvements in wind forecasting have assisted in addressing the issue of wind intermittency. According to a 2006 Garrad Hassan (a global, independent renewable energy consultancy service)163 study on short-term wind energy forecasting, wind persistence predictions outperform similar weather predictions that rely on Numerical Weather Prediction (“NWP”) modeling for purposes of forecasting several hours ahead of the targeted time.164 One of the conclusions reached was that for more accurate predictions, more timely, local data received from a wind farm site only several hours in advance is necessary for improved predictions for a particular place and time.165 For purposes of wind forecasting, one-day-ahead predictions are largely tied to the NWP modeling and predictions.166 Forecast accuracy can also be improved by analyzing historical data from a particular wind farm, so that a power curve detailing the transformation

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from wind speed into power can be created and analyzed.167 It has also been suggested that using satellite-based sensor data in conjunction with off-site data close to the wind farms can improve forecast precision.168 Also, aggregating data from a number of wind farms (called the “portfolio effect”), rather than merely analyzing data from one particular turbine, wind farm, or region, can enhance prediction accuracy.169 Modeling, nevertheless, may necessarily need to be site-dependent at a certain level, as predictions for a simple turbine site may not translate to a more complex site, or to an offshore wind farm site.170 Improved forecasting can positively impact the integration of wind energy into the grid, as improved wind forecasting can assist grid operators in anticipating and managing fluctuations in wind energy so that they have improved information on which to base their operational decisions, resulting in wind intermittency having a less significant impact on the grid.171 X. Community Wind and Small Wind

A. Price/Expense

By first reviewing the energy use and finding ways of reducing the energy consumption as much as possible, the size of the turbine and height of the tower can be determined. The less energy needed, the less expensive the overall turbine will be (or the more energy that a larger turbine can produce to sell back to the grid).

B. Turbine Location - Other Factors to Consider for Small Wind Turbine

Installation

At the individual homeowner level, a number of factors must be addressed prior to deciding on the location of a wind turbine facility on one’s property. Besides wind-related factors, other factors, such as environmental, social, and neighborhood factors must be taken into account. For instance, soil type, obtaining permits, obtaining appropriate building or zoning approvals, and verifying what constitutes permissible underground wiring under local electrical codes may be necessary in advance of turbine installation 172 In addition, any concerns of the local community whose experience with wind turbines may be limited should also be addressed. Even if there is local community support for construction of a small wind turbine, determining what applicable laws govern the wind turbine may cause delays. As an example, determining whether a small turbine is a structure that is regulated by a town’s land use ordinance or instead is a tower that is not governed by such ordinance may cause procedural delays in the timing and ability to construct the proposed turbine.173 All these issues must be taken into account in order to guarantee a successful wind turbine project. The amount of time needed for all these issues is extremely hard to determine and depends on each individual case.174

C. Developer and Manufacturer Selection

Because wind turbines come in various shapes and sizes, wind project developers endeavor to select the turbine that matches a particular project. Homeowners should do the same in terms of their own turbine selection. How to select a wind turbine manufacturer depends on a lot of

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industry factors such as the quality and reliability of the system, the cost of the equipment, the efficiency of the turbine, the turbine’s performance at different wind speeds, whether the turbine system has battery storage or is connected to the grid, as well as the company’s reputation and responsiveness, especially with respect to the handling of servicing or warranty issues.175 The type of wind farm being contemplated for construction, such as an onshore wind farm versus an offshore wind farm, will determine the type of turbine and related manufacturer selected for such project. AWEA suggests that the wind turbine developer invest substantial time and energy to know what types of products each manufacturer is capable of producing, as developers will want the right manufacturer to supply the right turbine to best suit their project.176 Similarly, a homeowner will want to engage in this type of evaluation process when considering which type of turbine to purchase.

D. For Households – Small Wind - Costs

As with any other form of renewable energy, the first factors to investigate are how much energy will be needed for residential use, and whether the home’s location is suitable for a wind turbine.177 After analyzing the amount of energy consumed monthly or annually, reducing the actual consumption should be considered.178 By replacing low efficiency appliances with high efficiency appliances and at the same time implementing measures to conserve energy, the need for electricity can be significantly decreased, thereby reducing the amount of overall energy, including wind energy, necessary to meet energy needs. Reducing energy consumption means that a smaller, less costly turbine can be used.179 Moreover, the location of a home may not be conducive to supporting a wind turbine. To gauge whether a home is situated in an area that can support a wind turbine, long-term average wind speeds or historic climate data, rather than day-to-day weather patterns, need to be considered.180

E. Repairs and Maintenance

Even though small wind turbines are very cost effective, they have mechanical systems that require maintenance. Smaller wind turbines have an average life span of at least 20 years and will periodically require maintenance or repairs. When these maintenance and repair expenses are factored in from the beginning of the process, unexpected surprises can be avoided. Even though designs are improved every day, and have become simpler with more durable materials and finishes, some financial resources should be allocated for maintenance and repairs. Mick Sagrillo from Sagrillo Power and Light suggests allocating “about 1% of the installed cost of the wind system for operation and maintenance expenses over the life of the system.”181 In his example, for a $40,000 installed system, $400 per year should be allocated for operation and maintenance expenses. According to Sagrillo, “This amount would be accrued over the life of the system. What this means is that you will not necessarily spend $400 every year, but you need to plan for that amount annually.”182 Other cost considerations a homeowner should consider include: (1) how much electricity is offset by the wind system; (2) net metering (or, rather, the method of metering the amount of energy a home or business consumes, where such home or business has a wind turbine or other renewable energy generation source; with net metering, if a wind turbine produces excess electricity, the home or business’s electricity meter will spin backwards, so that such excess electricity is effectively “banked” for the consumer) or

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sold back to the utility183; (3) cost of equipment and reliability; (4) installation costs; (5) insurance; and (6) revenue gained from excess generation.184

F. Consumer Economic Rebates and Incentives New Jersey’s Clean Energy Program (“NJCEP”), in coordination with the New Jersey Board of Public Utilities (“BPU”) provides financial incentives and assistance for renewable energy projects, such as wind projects, in New Jersey.185 A report by the NJCEP states that of the 5,189 of the renewable energy projects statewide that were installed from 2001 to January 31, 2010, the NJCEP has supported the installation of 27 wind projects across the state, supplying a total of 7,802.0 kW of sustainable energy and providing a total of $4,418,207 in rebates.186

Other NJCEP Innovative Wind Technology Incentives include the following:

• “2010 Program Plan includes the continuation of the performance based incentives (EPBB187) for wind projects;

• Currently 33 turbines are approved through the NJCEP; • There are 7 Pre-applications for 3.8 MW; • Currently 24 Approvals representing 1.52 MW;

• Another 8 Projects in various stages for .120 MW; • 10 completed projects representing 7.68 MW; and • RPS 188 Goal of 200 MW by 2020” 189

XI. Conclusion Implementation of a new technology is never simple. As the above discussion illustrates, there are many hurdles the wind industry, the New Jersey state government, and federal rule makers must work together to overcome. True, there may currently be a lack of developed infrastructure for connecting utility-scale wind turbines to the grid, and a lack of manufacturing and assembly plants at New Jersey ports for offshore wind farm parts assembly. However, failure to make an investment in wind power now could have a detrimental impact in the future. As demonstrated through examples of offshore wind farms in Europe, wind farms, particularly offshore wind farms, hold the promise of significant energy generation and energy independence. Because wind is bountiful, clean, reliable, and emissions free, and because of the savings in energy cost and GHG reductions wind offers, New Jersey will benefit in the long run by investing in wind turbine construction for its clean energy future today.

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1 Kimberly E. Diamond and Deborah Plotnik are members of the Berkeley Heights, New Jersey Environmental Commission (“BHEC”). The views expressed in this article are the authors’ and do not necessarily represent the views of the BHEC or the New Jersey League of Women Voters. 2 The World Watch Institute, “State of the World 2008: Innovations for a Sustainable Economy,” 25th Anniversary Edition, p. 75. 3 See http://unfccc.int/kyoto_protocol/items/2830.php. 4 “Wind Energy: Top Myths About Wind Energy” at http://www.bwea.com/energy/myths.html (hereafter, “BWEA Top Myths About Wind Energy”). 5 To calculate the CO2 generated by your utility, use the Environmental Protection Agency web site: http://www.epa.gov/cleanenergy/powerprofiler.htm Enter your zip code, and the program calculates your CO2 emissions based on your utility’s electrical generation fuel mix. (Sagrillo, Mick, “Small Turbine Column: The Environmental Benefits of Your Wind System” Windletter, The Monthly Newsletter of the American Wind Energy Association, Volume 26, Issue No.6, 2007). 6 “Wind Turbine: Turbine Design and Construction,” at http://en.wikipedia.org/wiki/Wind_turbine (hereafter, “Turbine Design and Construction”). 7 7 Vestas Wind Systems A/S, “Life Cycle Assessment of Offshore and Onshore Sited Wind Power Plants Based on Vestas V90-3.0 MW Turbines,” June 21, 2006 (hereafter, “Vestas Offshore and Onshore Wind Life Cycle Assessment”), at 16. 8 Turbine Design and Construction. 9 Id.; Vestas Offshore and Onshore Wind Life Cycle Assessment, at 19. 10 “Nacelle: Other Uses” at http://en.wikipedia.org/wiki/Nacelle; 10 Vestas Wind Systems A/S, “Life Cycle Assessment of Offshore and Onshore Sited Wind Power Plants Based on Vestas V90-3.0 MW turbines,” June 21, 2006, at 20. 11 Vestas Offshore and Onshore Wind Life Cycle Assessment, at 20. 12Id., at 40. 13 Id., at 20-21; “Nacelle: Other Uses” at http://en.wikipedia.org/wiki/Nacelle; Turbine Design and Construction. 14“Turbine” at http://en.wikipedia.org/wiki/Rotor_%28turbine%29; Turbine Design and Construction. 15Turbine Design and Construction; Vestas Offshore and Onshore Wind Life Cycle Assessment, at 21. 16 Vestas Offshore and Onshore Wind Life Cycle Assessment, at 12, 23-24. 17Id., at 23. 18 “Offshore Wind Turbine Foundations – Current & Future Prototypes” at http://offshorewind.net/Other_Pages/Turbine-Foundations.html (hereafter, “Offshore Turbine Foundation Prototpyes”). 19 “Deepwater Wind: The Technology” at http://www.dwwind.com/technology.htm; Offshore Turbine Foundation Prototpyes. 20 Id. 21 “New Jersey Projects” PowerPoint presentation slide, courtesy of Deepwater Wind. 22 Vestas Offshore and Onshore Wind Life Cycle Assessment, at 15, 16. 23 Id., at 24. 24 Id., at 16. 25 Id., see diagram at 13. 26 See http://www.vestas.com/ 27Vestas Offshore and Onshore Wind Life Cycle Assessment, at 10. 28 Id., at 10. 29 Id., at 10. 30 Id., at 42. 31 Id., at 12. 32Id., at 12. 33 Id., at 13. 34 Id., at 15. 35 Id., at 18. 36 Id., at 36.

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37 The Economics of Wind, American Wind Energy Association, at http://www.awea.org/pubs/factsheets/EconomicsOfWind-Feb2005.pdf. 38 See BWEA Top Myths About Wind Energy. 39

“The rule of thumb used in siting a home-sized wind turbine is that the entire wind turbine rotor should be at least 30 feet (10 meters) above anything within 500 feet (150 meters) of the tower.” (Mick Sagrillo, SmallTurbine Column, “Considerations for Wind Generator Towers,” Windletter, The Monthly Newsletter of the American Wind Energy Association, Volume 24, Issue No.11, November 2005 (hereafter, “Sagrillo – Wind Tower Considerations”)). 40Id. “The power equation for determining the amount of energy that a wind turbine can generate states that P=1/2dAV3, where P is the power available at the turbine rotor, d is the density of the air, A is the swept area of the rotor, and V is the wind speed. At a given location, we have no control over air density, so for any given wind generator with a given rotor diameter, the only real variable is V, wind speed. Therefore, we can rewrite the equation to say P~ V3…[where]the V3 portion of the power equation means that there is not a one-to-one relationship between increasing wind speed and increasing electrical generation. Doubling the wind speed does not result in a doubling of potential energy (a 100% increase), but an 800% increase, all because of V3.” 41Id. 42 “Resource_and_Economics: 3 Economics,” at http://www.offshorewindenergy.org/ca-owee/indexpages/Resource_and_Economics.php?fin. 43 Id. 44 AWEA News, January 26, 2010, “Inexpensive and Predictable,” http://www.awea.org/blog/index.php?mode=viewmonth&month_no=01&year=2010 (See “Guest Column – Smitherman: Let the Wind Blow in Texas,” Jan. 24, 2010, at http://www.amarillo.com/stories/012410/opi_15606399.shtml). 45 Id. 46Id. 47David Talbot, “Lifeline for Renewable Power,” Technology Review, January/February 2009. www.technologyreview.com/energy/21747, at 43. 48 Id., at 44. 49 Id., at 43. 50 “Regional Differences in Wind Development In PJM, New York and New England,” Energy Bar Association, Three-Way Simulcast Presentation in New York, NY; Washington, D.C.; and Boston, MA, February 3, 2010 (hereafter, “Energy Bar Program”). 51 Presentation by Jonathan Lowell, ISO New England – Market Development, “Integrating Wind Resources into New England Electricity Markets,” Energy Bar Program (hereafter, “Lowell Presentation”). 52 Presentation by Heather Hunt, Executive Director, New England States Committee on Electricity (“NESCOE”), at the Energy Bar Program. 53 See, “About PJM: Highlights – Who We Are” at http://www.pjm.com/about-pjm.aspx; Presentation by Steven R. Herling, Vice President, Planning of PJM Interconnection, “Wind Integration in PJM,” Energy Bar Program, presentation materials (hereafter, “PJM Herling Materials”), p. 2. 54 Id. 55 In addition to natural gas, coal, and nuclear, other alternative energy sources, including solar, hydro, biomass, and wood were included in the overall statistical calculation. 56 Presentation by Kenneth A. Schuyler, Senior Strategist, Market Services, PJM Interconnection, “Wind Integration into PJM Markets,” Energy Bar Program, presentation materials (hereafter, “PJM Schuyler Materials”), at 2. 57 PJM Herling Materials, p. 8. 58 Lowell Presentation. 59 Id. 60 PJM Schuyler Materials, at 11. 61 Travis Madsen, Matthew Elliott, and Dena Mottola Jaborska, “Toward a Clean Energy Future: The Vision, the Track Record, and the Challenge Ahead for New Jersey’s Leaders,” January 2010, at 18. 62 PJM Schuyler Materials, at 1.

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63 “Denmark Banks on Offshore Wind Power,” May 10, 2007, at http://www.iol.co.za/index.php?set_id=1&click_id=143&art_id=nw20070510100509344C164104&page_number=2 64 John Bradbury, “Britain and Denmark Lead Offshore Wind,” Offshore Energy, The North Sea Observer, January 18, 2010, at http://www.offshore247.com/news/art.aspx?id=15820. 65Id. 66Id. 67 European Wind Energy Association, “The European Offshore Wind Industry – Key Trends and Statistics” at http://www.ewea.org/index.php?id=1861. 68 European Wind Energy Association, “The European Offshore Wind Industry – Key Trends and Statistics, January 2010: Executive Summary” at http://www.ewea.org/fileadmin/emag/statistics/2009offshore/pdf/offshore%20stats%2020092.pdf. 69 Id. 70“Crown Estate Names Round 3 Offshore Wind Partners,” New Energy Focus: Wind News, January 8, 2010, located at http://newenergyfocus.com/do/ecco/view_item?listid=1&listcatid=143&listitemid=3406. 71 Id. 72 Id. 73 Id. 74 See http://en.wikipedia.org/wiki/Wind_power_in_Scotland (hereafter, “Wind Power in Scotland”). 75 “Wind Power in Scotland”; http://en.wikipedia.org/wiki/Moray_Firth. 76“Wind Power in Scotland”; http://en.wikipedia.org/wiki/Firth_of_Forth. 77 “Evolution of Global Wind Power,” by Cristina L. Archer and Mark Z. Jacobson, Journal of Geophysical Research – Atmospheres (2005) (abstract available at http://www.stanford.edu/group/efmh/winds/global_winds.html). 78 Wind Power in Denmark, at http://en.wikipedia.org/wiki/Wind_power_in_Denmark. 79 Id. 80 “Denmark Banks on Offshore Wind Power,” May 10, 2007, at http://www.iol.co.za/index.php?set_id=1&click_id=143&art_id=nw20070510100509344C164104&page_number=2. 81 Id. 82 Id. 83 Id.; http://en.wikipedia.org/wiki/BTM_Consult. 84 Id. 85 Horns Rev: Offshore Wind Parks, at http://en.wikipedia.org/wiki/Horns_Rev#Offshore_wind_parks. 86 Id. 87 European Wind Energy Association, “The European Offshore Wind Industry – Key Trends and Statistics, January 2010: Financing Highlights and Developments” at http://www.ewea.org/fileadmin/emag/statistics/2009offshore/pdf/offshore%20stats%2020092.pdf. 88 Diamond, Kimberly E., “Federal Loan Guarantees, Grants, Tax Law Modifications, and the Economy’s Impact on Wind Power Project Financing,” Energy Committees Newsletter, Vol. 7, No.2, January 2010, at 12 (hereafter, “Diamond Article”). 89 European Wind Energy Association, “The European Offshore Wind Industry – Key Trends and Statistics, January 2010: Financing Highlights and Developments” at http://www.ewea.org/fileadmin/emag/statistics/2009offshore/pdf/offshore%20stats%2020092.pdf. 90 Id. 91 Id. The wind farms that were designated to receive funds from the European Economic Recovery Plan are as follows: BARD1; Global Tech 1; Nordsee Ost; Borkum West II; Aberdeen Offshore Wind Farm; and Thornton Bank. 92 The EIB’s shareholders consist of the 27 member states of the European Union, with each member state being eligible for financing from the EIB. See http://www.eib.org/about/structure/shareholders/index.htm. 93 European Wind Energy Association, “The European Offshore Wind Industry – Key Trends and Statistics, January 2010: Offshore Supergrid Developments” at http://www.ewea.org/fileadmin/emag/statistics/2009offshore/pdf/offshore%20stats%2020092.pdf. 94 Id.

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95New Jersey: The Geography of New Jersey, at http://www.netstate.com/states/geography/nj_geography.htm. 96See National Renewable Energy Laboratory’s Wind Energy Resource Atlas of the United States at http://rredc.nrel.gov/wind/pubs/atlas/. 97 See National Renewable Energy Laboratory’s Wind Energy Resource Atlas of the United States, Chapter 1, Map Descriptions at http://rredc.nrel.gov/wind/pubs/atlas/chp1.html#map. 98See National Renewable Energy Laboratory’s Wind Energy Resources Atlas of the United States, Table 1-1 Classes of wind power density at 10 m and 50 m(a) at http://rredc.nrel.gov/wind/pubs/atlas/tables/1-1T.html (hereafter, NREL Table 1-1”). 99 Wind Energy Resources Atlas of the United States, Chapter3 Regional Summaries, The Northeast Region, Map 3-24, “New Jersey Annual Average Wind Power”, at http://rredc.nrel.gov/wind/pubs/atlas/maps/chap3/3-24m.html (hereafter, “NJ Annual Average Wind Power”). 100 Id.; NREL Table 1-1. 101 NJ Annual Average Wind Power. 102 NREL Table 1-1. 103 Danish Wind Industry Association, “The Power of Wind: cube of Wind Speed,” http://www.talentfactory.dk/en/tour/wres/enrspeed.htm; American Wind Energy Association, Resources – Wind Energy Basics: “How Much Electricity Can One Wind Turbine Generate?” at http://www.awea.org/faq/wwt_basics.html (hereafter, “How Much Electricity Can One Wind Turbine Generate?”). 104 “How Much Electricity Can One Wind Turbine Generate?”. 105 See http://www.vestas.com/. 106 Vestas Offshore and Onshore Wind Life Cycle Assessment, at 38. 107 Diamond Article, at 10, citing AWEA News Release at http://www.awea.org/newsroom/releases/10-20-09_AWEA_Q3_market_report.html. 108 Id., at 13. 109 Id., at 10. 110 Id., at 11, citing http://www.treas.gov/recovery/1603.shtml; http://www.reas.gov/recovery/docs/guidance.pdf. 111 22 U.S.C. 16511-16514, as amended. 112 Diamond Article, at 11. 113 Id. 114 Id. 115 Id., at 14. 116 “New Jersey Wind: The 7.5 MW Jersey-Atlantic Wind Farm” at http://www.njwind.com/project.html. 117 “Corzine Unveils State’s Energy Master Plan,” Cape May County Herald.com, Oct. 22, 2008, at http://www.capemaycountyherald.com/article/36546-corzine-unveils-state039s-energy-master-plan.. 118 Id. 119State of New Jersey Energy Data Center, “Energy Master Plan: State of New Jersey,” at http://policy.rutgers.edu/ceeep/eds/masterplan/. 120 Draft New Jersey Energy Master Plan Implementation Strategies: A Companion Document to the Draft New Jersey Energy Master Plan, April 17, 2008, at http://nj.gov/emp/docs/pdf/strategies.pdf (hereafter, “Implementation Strategies”). 121 Id. at 29. 122 See “PSE&G: Developing Renewable/Alternative Energy – Harnessing Wind Power: at http://www.pseg.com/environment2008/wwd/renewable/renewable.jsp; “Deepwater Wind: Projects” at http://www.dwwind.com/projects.html; Terrence Dopp, “N.J.’s Christie Seeks Faster Approvals for Offshore Wind Power,” Business Week, March 1, 2010, at http://www.businessweek.com/news/2010-01-01/n-j-s-christie-seeks-faster-approvals-for-offshore-wind-power (hereafter, “Dopp Article”). 123 PSE&G: Developing Renewable/Alternative Energy – Harnessing Wind Power: at http://www.pseg.com/environment2008/wwd/renewable/renewable.jsp. 124Michael Rispoli, “N.J. GOP Governor Candidate Chris Christie Outlines Energy Plan,” The Star-Ledger, July 6, 2009, at http://blog.nj.com/ledgerupdates_impact/print.html?entry=/2009/07/gop_candidate_chris_christie. 125 “Transition New Jersey: Energy and Utilities Subcommittee Report,” January 11, 2010, at http://www.state.nj.us/governor/news/reports/Energy & Utilities.pdf (hereafter, “Transition New Jersey”). 126 Id., at p.1

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127 Id., at p.1-2, 4, 7, and 12 128Id., at p. 2 129 Id., at p. 3, 14 130 Rikki Stancich, “Executive Viewpoint: Advanced Offshore Solutions: Breakaway Ideas for Offshore Turbine Installation,” October 25, 2009, at http://social.windenergyupdate.com/qu/advanced-offshore-solutions-breakaway-ideas-offshore-turbine-installation (hereafter, “Executive Viewpoint”). 131 “FAQs: Wind Systems – How Many Homes Can One Off Shore Wind Turbine Supply?” at http://www.njcleanenergy.com/renewable-energy/technologies/wind/faqs. 132 Executive Viewpoint. 133 Transition New Jersey, at p. 14. 134 Dopp Article; Andrew Kitchenman, “Christie, Congressmen Discuss Wind Power, Unemployment Benefits,” The Daily, March 1, 2010, at http://www.njbiz.com/article-multiple/80648-christie-congressmen-discuss-wind-power-undemployment-benefits (hereafter, “Kitchenman Article”). 135 David Talbot, “Lifeline for Renewable Power,” Technology Review, January/February 2009. www.technologyreview.com/energy/21747, at 44. 136 Id. 137 Dopp Article. 138 Great Expectations: U.S. Wind Energy Development, Governors’ Wind Energy Coalition 2010 Wind Energy Recommendations, March 2010, at http://www.governorswindenergycoalition.org./assets/files/10GWEC-003_GreatExp_324_lores.pdf. 139 Id. 140 Dopp Article; Bob Menendez at http://en.wikipedia.org/wiki/Bob_Menendez (hereafter, “Menendez Article”). 141 Kitchenman Article. 142Menendez Article. 143“American Recovery and Reinvestment Act of 2009” at http://en.wikipedia.org/wiki/American_Recovery_and_Reinvestment_Act_of_2009. 144 Vestas Offshore and Onshore Wind Life Cycle Assessment, at 32, 34. 145 Id., at 42. 146 Id., at 32. 147 Id., at 32. 148 “Wind Power: Capacity Factor, Intermittency, and What Happens When the Wind Doesn’t Blow,” p.4, at http://www.ceere.org/rerl/about_wind/RERL_Fact_Sheet_2a_Capacity_Factor.pdf . 149 Id., p.1, 4 150 Offshore Wind Turbine Foundations – Current & Future Prototypes” at http://offshorewind.net/Other_Pages/Turbine-Foundations.html. 151 “Santee Cooper Releases Offshore Wind Turbine Simulation Photos, at http://www2.scnow.com/scp/news/local/grand_strand/article/santee_cooper_releases_offshore_wind_turbine_simulation_photos/85210/. 152 Id. 153 Id. 154 “Record of Decision: Implementation of a Wind Energy Development Program and Associated Land Use Plan Amendments,” December 2005, at http://www.windeis.anl.gov/documents/docs/WindPEISROD.pdf. 155 “Environmental Impact Statement: The NEPA Process,” at http://en.wikipedia.org/wiki/Environmental_impact_statement. 156 American Wind Energy Association. Wind Energy Fact Sheet: 10 Steps in Building a Wind Farm. http://www.awea.org/pubs/factsheets/10stwf_fs.pdf. 157 If yours is "…a remote system utilizing batteries rather than the utility grid, then you can actually do with less wind than the minimum cost-effective grid intertie system. Any renewable source of energy is more cost effective than running, maintaining, and fueling a gas or diesel generator for several decades.”; “In the case of a utility intertie system, a ten mph average annual wind speed is usually considered the cut-off. Below ten mph, the wind generator cannot be justified on a purely economic basis compared to purchased utility power. With a stand-alone system, wind generators are certainly cost effective in the nine mph and even the eight mph average wind speed ranges.”

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Mick Sagrillo. Site Analysis for Wind Generators, Home Power Magazine #40, p.86. Ashland, OR, www.homepower.com. 158 Capacity Factor, at p.4 159 Id., at p.4 160 “Wind: Cause” at http://en.wikipedia.org/wiki/Wind. 161 Capacity Factor, at p. 4 162 BWEA Top Myths About Wind Energy. 163 “Garrad Hassan: Company Profile” at http://www.garradhassan.com/corporate/profile.php. 164 “Short Term Wind Energy Forecasting: Technology and Policy,” Garrad Hassan and Partners Limited, 2006, Executive Summary, at http://www.canwea.ca/images/uploads/File/Resources/FinalGHReport.pdf . 165 Id., at Executive Summary. 166 Id. 167 Id. 168 Id., at p. 32 169 Id., at p. 15 170 Id. 171 Id. 172Mick Sagrillo, Windletter: The Monthly Newsletter of the American Wind Energy Association, Volume 21, Issue No. 9, September 2002. http://www.renewwisconsin.org/wind/Toolbox-Homeowners/Installing%20your%20own%20wind%20system.pdf. 173 Federal Grant Fully Funds Small Turbine Installation at Maine Senior Housing Complex, Wind Powering America Distributed Wind Case Study, at http://www.windpoweringamerica.gov/pdfs/small_wind/2008/grant_senior_housing.pdf . 174 Id. 175 Mick Sagrillo and Ian Woofenden, “How to Buy a Wind-Electric System,” Home Power, 122. December 2007 & January 2008, pp. 29-31, www.homepower.com. 176 Mick Sagrillo and Ian Woofenden, “Wind Turbine Buyer’s Guide,” Home Power, 119, June & July 2007, p. 38, www.homepower.com. 177 Mick Sagrillo, “FAQs: What You Need to Understand About a Wind Turbine for Your Home,” Windletter, July 2008, at http://www.awea.org/smallwind/sagrillo/wind_turbine_for_your_home.html. 178 Id. 179 Id. 180 Mick Sagrillo, SmallTurbine Column, “Wind System Operation and Maintenance Costs,” Windletter, The Monthly Newsletter of the American Wind Energy Association, Volume 21, Issue No.12, November 2005. 181 Id. 182Id. 183Resources, Wind Energy FAQ, What are “Net Billing and “Net Metering,” at http://www.awea.org/faq/netbdef.html. 184Mick Sagrillo, Small Turbine Column, “Investment Considerations for Wind Systems,” Windletter, The Monthly Newsletter of the American Wind Energy Association, Volume 26, Issue No.9, 2007. 185 “Installation Summary by Technology,” New Jersey Clean Energy Program, at http://www.njcleanenergy.com/renewable-energy/project-activity-reports/installation-summary-technology/installation-summary-technology, last visited on March 11, 2010. 186 Id. 187 “EPBB is a methodology for calculating a CORE rebate which is based on the expected kWh output of a specific wind turbine at a specific site.” “The EPBB methodology is designed to provide greater incentives to systems that have a higher expected kWh output. This new approach calibrates the rebates more closely to the goals defined in the Renewable Portfolio Standard, and Energy Master Plan, which are based on energy output (KWH).” http://www.njcleanenergy.com/files/file/Renewable_Programs/CORE/FAQforwindEPBBrev080805.pdf 188 “A renewable portfolio standard is a state policy that requires electricity providers to obtain a minimum percentage of their power from renewable energy resources by a certain date. Currently there are 24 states plus the District of Columbia that have RPS policies in place. Together these states account for more than half of the

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electricity sales in the United States.” New Jersey has an RPS policy administered by the Board of Public Utilities to provide 22.5% renewable energy by 2021. See http://apps1.eere.energy.gov/states/maps/renewable_portfolio_states.cfm#map. 189 New Jersey Clean Energy Program, PowerPoint Slide Show, at http://mail.njcleanenergy.com/pipermail/smallwind/attachments/20091006/ba91918e/attachment-0001.ppt.


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