| Comment Number: | 533254-00016 |
| Received: | 1/16/2008 12:38:26 PM |
| Organization: | |
| Commenter: | Ruth Matilsky |
| State: | NY |
| Agency: | Federal Trade Commission |
| Rule: | Guides for the Use of Environmental Marketing Claims; Carbon Offsets and Renewable Energy Certificates |
| No Attachments |
Comments:
To Whom It May Concern: I am writing about two wind companies -- UPC, with projects in Prattsburgh, Cohocton and Italy, New York, and Ecogen LLC with a project that straddles Yates and Steuben County in New York State. Both of these companies will be eligible for Renewable Energy Credits when their wind projects are up and running. However, neither of these companies has proven that their projects will supply enough renewable energy to be worth the environmental cost, let alone worth the RECs. I, along with members of Advocates for Prattsburgh and Cohocton Windwatch, have watched the SEQR (State Environmental Quality Review) process for both these companies over the past five years and they have consistently refused to divulge the results of their meteorological studies. They and their lead agent, the Steuben County Industrial Development Agency (SCIDA) have turned a deaf ear to evidence that these wind projects are in areas where the intermittency of wind as well as icing conditions will reduce the viability of the wind turbines. IN as study done by GE Energy which was commissioned by NYSERDA (New York State Energy Research and Development Authority) it is stated that inland wind turbines work at ten percent of their rated capacity due to the intermittency of wind and the inability of wind to coordinate production with peak load demand. This does not even take into account the times in the winter when icing conditions in New York State (which are the most severe in the nation) will require that the machines be shut down. For these companies to be eligible for RECs is a travesty. In Denmark, they have solved the problem by exporting electricity to Sweden, which uses the wind electricity to move underground water supplies into reservoirs where it awaits use by hydroelectric facilities. In New York there is no such possible arrangement. Because the wind companies have so much invested in public relations campaigns, it has been impossible to get those in public office to pay attention to this situation. Frankly, most people do not understand the technical aspects of wind energy and they rely for information on the American Wind Energy Association, a trade group whose mission is to promote wind energy, not to look out for the public interest. I could write volumes on this subject and would be happy to answer questions if you want any further information. Very truly yours, Ruth Matilsky