Kafkaesque: Lawless loophole lets wind company endanger human lives
Another Kafkaesque industrial wind turbine nightmare in Ontario. A regional airport (Collingwood), with an aerodrome close by (Stayner), and eight 500’ (152 metres) air-space-invading industrial wind turbines (wpd Canada’s Fairview Wind Project) to be wedged between both airfields, posing grave danger to pilots and their passengers—and the whole thing approved by the Ontario Liberal government.
What could possibly go wrong when pilots, flying visually without instrumentation (as is the case in over 90% of the flights at these two airports), have to negotiate a safe take-off or landing through a blur of Georgian Bay fog, or lake-effects snow, and an indiscernible phalanx of gigantic 50-storey-tall white windmills?
All eight of the planned wind turbines will “penetrate” the safe arrival and departure airspace mandated by Transport Canada standards.
The Collingwood-Stayner airspace is a no-man’s-land of regulation, a lawless vacuum with respect to wind turbine installations. Ontario’s Green Energy Act deliberately has no safety provision for wind turbine setbacks near airports. All eight of the planned wind turbines will “penetrate” the safe arrival and departure airspace mandated by Transport Canada standards, as prescribed by the International Civil Aviation Organization.
If the turbines are built, and they thereby are found to create an unsafe situation, Transport Canada could shut the airports down.
However, here is the kicker. Transport Canada has no jurisdiction over where wind turbines are located with respect to the air space of registered, uncertified airports such as the Collingwood Regional Airport and the Clearview Aerodrome in Stayner. But, when the turbines are built, and they thereby are found to create an unsafe situation, Transport Canada could shut the airports down. The airports, not the wind turbines!
In this case, there is a dangerous jurisdictional vacuum. Neither Transport Canada, nor the Ontario government, nor the local governments, which the Liberals’ Green Energy Act stripped of their planning powers, have any legal say over the aeronautically-safe siting of wind turbines at registered, uncertified airports.
Wind companies—often foreign-owned—pretty well get to do whatever they want.
Such is the looney landscape of Ontario’s sickly “green” wind energy program that wind companies—often foreign-owned—pretty well get to do whatever they want, aided, abetted, enabled, financially rewarded, and legally defended by the Ontario Liberals’ Green Energy Act and their kangaroo court of (hopeless) appeal, the Environmental Review Tribunal (ERT). Only two of the scores of wind turbine project appeals to the ERT have had partial success, with final outcomes still pending.
wpd Canada’s Fairview Wind Project between the Collingwood-Stayner airports is being appealed, with an ERT hearing scheduled for May 16, 2016 in Collingwood. What are the chances that the safety-minded appellants will prevail? The onus is on them to prove “serious harm” to human health. You’d think that this would be a no-brainer, logical, obvious. But the narrow terms of reference by which the ERT operates and the unfair burden of proof heaped on the appellants usually spell defeat.
For a mind-blowing overview of this particular Kafkaesque situation involving wind turbine approvals and appeals, watch the 30-minute media event held at Queen’s Park on April 21, 2016 (starting at 3:09). At the press conference, Simcoe-Grey MPP Jim Wilson, Kevin Elwood (the pilot owner of the Clearview Aerodrome), and Charles Magwood, area property owner, outlined chilling facts about the lawless loophole that could endanger the lives of pilots and their passengers, and potentially close down an economically vital airport and aerodrome for good.
The trio also discuss possible graft and corruption in this case: wpd Canada’s payments made to the Liberal party, followed immediately by government approvals for wpd Canada’s project, and wpd Canada’s creation of a shell company with no assets in order to evade liability for accidents and de-commissioning of wind turbines.
In Ontario: lawless loopholes, callous, criminal disregard for human health and safety, apparent bribes for wind project approvals, calculated liability evasion, democracy-robbing legislation—all for economically useless, environmentally-destructive, subsidy-sucking industrial wind turbines, ugly symbols of a bankrupt, immoral, dishonest, fake planetary climate emergency.
September 2017:
February 2018:
The same goes for Kevin and Gail Elwood, John Wiggins, and the residents’ group Preserve Clearview, after the Environmental Review Tribunal dismissed an application for costs related to their appeal of a decision to grant WPD a renewable energy application for the Fairview Wind Project.
Health Canada—in spite of itself!—finds a significantly harmful relationship between human health and wind turbine noise
See UPDATE further below.
From Health Canada’s November 6, 2014 news release of its $2.1 million Wind Turbine Noise and Health Study:
…the study did demonstrate a relationship between increasing levels of wind turbine noise and annoyance towards several features (including noise, vibration, shadow flicker, and the aircraft warning lights on top of the turbines) associated with wind turbines.
“Annoyance,” as a criterion within the context of a health study, is a recognized, significant health hazard:
A WHO epidemiology study assessed noise annoyance and documented significantly elevated relative risks exist both in the cardiovascular system, the respiratory system, and the musculoskeletal system as well as by depression. The study concluded that for chronically strong annoyance a causal chain exists between the three steps [of] health – strong annoyance – increased morbidity. Other symptoms associated with annoyance from various noise sources include: stress, sleep disturbance, headaches, difficulty concentrating, irritability, fatigue, dizziness or vertigo, tinnitus, anxiety, heart ailments, and palpitation. Chronic severe annoyance induced by noise must be classified as a serious human health risk.
The Health Canada report is only a summary:
A more detailed presentation of the results will be submitted for publication in scientific journals. Results should only be considered final following peer-review and publication in the scientific literature.
The finding of “a relationship between increasing levels of wind turbine noise and annoyance” should have been big, game-changing news and raised serious alarm bells in Ontario, where the Wynne Liberal government is intent on continuing to destroy farmland, rural communities, families, livelihoods, quality of life, wildlife, the environment, beautiful landscapes, and property values with thousands more of the useless industrial monsters, against the will of most of the people and the communities affected, and to the despair of urbanites knowledgeable about the subject. But no—the finding of annoyance, an important health indicator which has an established “causal chain” of “health – strong annoyance – morbidity,” did not make the headlines and was barely mentioned in most media reports, or was dismissed in the “colloquial” sense of the word “annoyance.” Instead, most of the mainstream media dutifully reported a contradictory finding of wind turbine noise (WTN) and human health, which in Health Canada’s summary was detailed first and was helpfully highlighted in a box so as not to be missed:
The following were not found to be associated with WTN exposure:
- self-reported sleep (e.g., general disturbance, use of sleep medication, diagnosed sleep disorders);
- self-reported illnesses (e.g., dizziness, tinnitus, prevalence of frequent migraines and headaches) and chronic health conditions (e.g., heart disease, high blood pressure and diabetes); and
- self-reported perceived stress and quality of life.
But further along in the summary, Health Canada does admit that:
- WTN annoyance was found to be statistically related to several self-reported health effects including, but not limited to, blood pressure, migraines, tinnitus, dizziness, scores on the PSQI, and perceived stress.
- WTN annoyance was found to be statistically related to measured hair cortisol, systolic and diastolic blood pressure.
Health Canada then qualifies these statistically significant findings of both self-reported health effects and objective, measured health indices with statements about how the same things were observed for road traffic annoyance, that the conditions may have pre-dated industrial wind turbine installations, and that community annoyance activities could play a role over and above WTN. Of course!
Health Canada’s study has been heavily criticized on a variety of aspects having to do with its design, methodology, and its unseemly hasty conclusions that favour the wind energy sector’s efforts to convince us that industrial wind turbines are safe and do not adversely affect human health. Find out how and why Health Canada’s Wind Turbine Noise and Health Study is deeply flawed:
- Denise Wolfe: Review of the Health Canada Wind Turbine Noise and Health Study
- Epidemiologist Joan Morris offers her thoughts on the Health Canada’s wind turbine and noise health study.
- Prof disputes wind turbine report
- Jane Wilson, President of Wind Concerns Ontario, describes her disappointment with the Health Canada report on the health effects of wind turbines.
- Dr. Robert McMurtry, the founding director of Wind Concerns Ontario, comments on the Health Canada Study of industrial wind turbines.
- Turbine health impact
UPDATE
- Get a sense of the extreme intrusion, disruption, and health havoc inflicted on rural people from the gut-wrenching video below of life amidst an industrial wind turbine plant in Ontario.
- Read Lawrence Solomon’s article, Ill winds blow from wind turbines, in the Financial Post.
- Read Wind Concerns Ontario’s expert analysis of the Health Canada study: Health Canada Study A Missed Opportunity To Find The Truth
Dirty secrets of the Ontario Liberals’ wind power scam: What you need to know from DownWind, the Sun News documentary
THE ONTARIO LIBERALS’ GREEN ENERGY ACT HAS DONE SERIOUS AND IRREVERSIBLE HARM TO PEOPLE, WILDLIFE, THE ENVIRONMENT
- Rural people in Ontario living in the midst of 50-storey-high industrial wind turbines have been badly hurt, even seriously and irreversibly harmed, with respect to mental and physical health and safety, property values (loss of 10-48% or even 100%), livelihood, way of life, community harmony. Some families have had to leave their homes on the advice of doctors.
- Farmers have noticed that wind turbines drive out earthworms due to electrical surge charges and vibrations. This reduces the quality of the soil. “Food production will go down.”
- The wind turbines’ 800-ton concrete bases, of which some of the material is toxic, go 50 feet down, far enough to hit aquifers.
- Livestock productivity, such as that of dairy cattle, is adversely affected.
- Birds are slaughtered by wind turbines.
THE LIBERALS HAVE PRESIDED OVER ABROGATION OF DEMOCRATIC RIGHTS AND BULLYING BY WIND COMPANIES
- “The provincial government wants these things and they’re going to come no matter what we do.”
- “(As high as) 140-50 storey buildings – you don’t even have that in Toronto. We’re talking 1,800 turbines up and down the shoreline (of Lake Huron), on some of the most productive farmland in all of Ontario. My God, what are you people thinking? Don’t tell us from your condo that the green thing is so great that we’re going to force it on you.”
- The Liberals’ Green Energy Act supersedes/overrides 21 pieces of legislation including the Clean Water Act, acts that protect the Niagara Escarpment and Oak Ridges Moraine, the Heritage Act.
- All Ontario government ministries have turned a deaf ear to complaints and concerns communicated to “every arm of the Ontario government when they asked for help. The wind companies do whatever they want.”
- The Liberals’ Green Energy Act strips municipalities of their planning powers. More than 80 communities have declared themselves to be unwilling hosts.
THE SYSTEM IS RIGGED AGAINST WIND TURBINE VICTIMS
- Wind turbines “are imposed on people and they are getting no choice. That begs the question of whether it’s Charter-compliant, whether it complies with constitutional principles to put these people through these things without being assured of a certain level of safety. No one should be subjected to a reasonable risk of harm.”
- There have been more than 20 Environmental Review Tribunal hearings of appeals and all of them were dismissed. One was allowed but appealed in Ontario Divisional Court where the wind developer prevailed. “The process they’ve created is so imbalanced and so weighted in favour of the wind turbine companies it’s as if they wrote the legislation. It’s embarrassing.”
LIBERALS GOT IN BED WITH GREEN NGOS, WIND INDUSTRY, BAY STREET LAWYERS TO WRITE THE GREEN ENERGY ACT
- “They all sat down and worked up the language they wanted in the legislation and built a campaign around it. You got the complete package: the PR side, the legislation drafting, the program to re-educate the public service, the whole momentum going, the Toronto Star editorial page cranking out a regular drumbeat – coal bad, wind good.”
WIND POWER IS FAR FROM CLEAN
- “When they talk about displacing coal-fire power plants in Ontario with wind, that’s not actually what happens. As they add wind capacity to the system, they are displacing nuclear and hydro and those are non-emitting sources. And you have to remember that whenever you see a wind turbine, there is a gas-fire power plant running in the background to balance out the load fluctuations. So it’s always a wind and gas combination. They’re replacing emissions-free hydro and nuclear with a combination of wind and gas and we’ll actually end up with higher emissions of pollution …”
- “So you’re paying for a wind turbine to turn, and you’re paying for a gas plant to idle. You’re paying double most of the time. It’s asinine.”
THE LIBERALS HAVE USED JUNK SCIENCE TO MISLEAD THE PUBLIC
- Air pollution levels in Ontario have declined steadily since 1974, but the Liberals claimed in 2009 when the Green Energy Act came into force that there was a rising air pollution crisis. “But they knew perfectly well that air pollution had been trending downward right across the board.”
- Most particulate matter emissions come not from coal power generation, as the Liberals claimed, but from construction, industry, agriculture, and most of all from dust from unpaved roads.
- “There’s no question that there’s been an effort to demonize coal.”
BILLIONS OF YOUR DOLLARS WASTED ON LIBERAL BOONDOGGLES
- Ontario electricity costs are the highest in North America as a result of the Liberals’ Green Energy Act.
- “Wind turbines don’t run on wind, they run on subsidies.”
- They replace power that costs 3-5 cents per kilowatt hour (kwh) with wind power that costs 13.5 cents per kwh to generate.
- “Nobody was building wind turbines in Ontario until the government started throwing money at it. It’s not cost effective. Wind turbines can’t compete on a wholesale market without a lot of government support.”
- Wind companies get 20-year contracts to sell wind power at far above market rates.
- “The system has to buy power whenever wind companies produce it” whereas standard power producers (nuclear, hydro) have to compete on the wholesale market.
- Ontario lost $1 billion selling excess power in 2013 to neighbouring jurisdictions – “How stupid is that?”
- The cost of the Green Energy Act to date is $4-5 billion, or 70 times the cost of retrofits recommended in 2005, to get equivalent environmental benefits. (Some estimates say the Green Energy Act costs so far are closer to $8 billion.)
- Before the Green Energy Act, Ontario had a few large power plants with the grid optimized to source the power. Now we have “tiny, little unreliable” wind facilities that required a new grid, putting an “extra cost to get something we already had – it increased the costs of having what you had before.”
- “There were far smarter ways of creating energy. If we had done nothing except put the most advanced scrubbers on our coal plants we would actually have had as clean air as we do today.”
THE LIBERALS FAILED TO PERFORM DUE DILIGENCE, OR UPHOLD THEIR FIDUCIARY DUTY
- The Liberal government has to date done no cost benefit analysis, and no health study.
- The much-anticipated Health Canada two-year, $2 million research study of the adverse health effects of wind turbines is due in December of this year. However, it will apparently not establish causation or have conclusive results.
- The 550-metre set-back for siting industrial wind turbines from homes, established by the Ontario government, is arbitrary and was not based on any research.
HYPOCRISY, DISHONESTY
- In her current election campaign ads, Liberal leader Kathleen Wynne says she believes “government should be a force for good in people’s lives.” In her campaign she claims “I believe there is only one good reason to enter politics, and that is to help people,” yet the documentary showed her not to have had the basic decency to stop to listen when she was approached by industrial wind turbine victim Norma Schmidt.
FLAGRANT CONFLICT OF INTEREST – LIBERAL FRIENDS CASHING IN
- Mike Crawley, erstwhile president of the Ontario Liberal party, a former senior aide to former premier Dalton McGuinty, was at the same time CEO of a major wind developer that was proposing four or five projects in Ontario. In 2004 he was awarded a contract worth $475 million, in addition to others.
FEAR AND COWARDICE – INDUSTRY INSIDERS ARE AFRAID TO SPEAK OUT
- People in the system have not dared to speak out.
- “There were people in the power generation sector who understood that the government numbers were not correct and did not add up, but they were effectively muzzled. The people that work in the power sector know that this is a crazy system. These wind farms are displacing hydro-electricity, which is just a waste on every level. The hydro-electricity plants don’t generate any air pollution emissions. They give us reliable, predictable base load power and now we let (them) sit idle.”
- “So people who work in the sector, they can see what is going on and they know that this is a waste but for understandable reasons they are not about to make a big noise about it because they could lose their jobs if they do.”
- “Our electricity system, to the people that run it, has become a joke, and they dare not raise a finger to oppose it.”
- “The electricity industry professionals will see the wasted generation … and their response is ‘so long as we have a blank cheque to keep the lights on, it’s all good.’ “
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There is much, much more to learn and be alarmed and outraged about in this documentary film, which runs 1 hour, 36 minutes and may be purchased for $9.99 and downloaded.
UPDATE: The full documentary Down Wind is now available on YouTube. Click here.
THE LIBERALS “HAVE GOT TOO MUCH INVESTED TO ADMIT THE ERROR”
In the upcoming Ontario election on June 12, any vote for the Liberals would appear to be one in favour of propping up a government that has proven itself to be working to enrich its cronies with the province’s treasure, not one that is interested in the welfare of the people it is mandated to serve, or in nurturing the economic health of the province.
Progressive Conservative leader Tim Hudak has promised to repeal the Green Energy Act if elected.
Industrial wind turbines and human health: Whitewash for the white coats
“Don’t tell me about the science” – Wind Turbines and Human Health: An Emotional Topic
You already knew from the cavalier seminar title where this presentation was going to be heading. However, in his introduction, the presenter promised a balanced discussion on the issue of wind turbines and human health so that health care practitioners and academics could have informed dialogue. Mmmm. Really?
The seminar/webinar was hosted in Toronto by Public Health Ontario on March 20, 2014, and was given by Loren Knopper Ph.D., an environmental health scientist and co-lead of Intrinsik Environmental Science’s Renewable Energy Health Team, with stated expertise in industrial wind turbines and human health.
Knopper failed to offer a disclaimer that “a number” of his clients are wind developers (unless he stated it when the webinar’s sound failed for two brief periods). This information came to light in the question period following his presentation. It’s a very important point because the wind industry denies, despite some good evidence, that industrial wind turbines can cause adverse health effects. Obviously, one would not want any inconvenient truths alienating clients with deep, government-guaranteed, subsidy-enhanced pockets.
Knopper started out by asserting that, “Generally, public attitude favours the idea of wind energy.” It was interesting that this Ph.D. scientist who insisted heavily on research rigour in his critique of the research studies later on, was in this instance not presenting any empirical evidence to support his statement. Instead, he showed a slide of a silly HSBC ad depicting splayed banana skins stood upright to look like wind turbines with the tagline: “In the future, there will be no difference between waste and energy.” The same slide had a photo of a U.S. Environmental Protection Agency window with a small picture of wind turbines in it, meant to support his claim that there is general public acceptance of wind energy. Of course, neither of these organizations’ displays reflect public attitude, but rather self-interested propaganda for what is actually a green energy disaster. But never mind. Knopper did admit that his version of public favour does not mean local acceptance of wind projects. No surprise there.
Scientific merit depends on the objectivity and scientific rigour of the beholder
Knopper’s seminar was essentially a look at the issue of industrial wind turbines and human health, an overview of the scientific literature on the subject, and his conclusions of the weight of evidence based on studies he deemed to have scientific merit.
In judging any scientific study, it’s imperative to go to the original work and evaluate the soundness of the methodology and analysis the researchers used. In his presentation, Knopper did not hesitate to allege statistical and other deficiencies that he thought negated the results of key studies that have concluded that industrial wind turbine operations do cause adverse health effects. He also emphasized that “many” of these studies were published in one journal, The Bulletin of Science Technology & Society, and stated more than once that their authors were on the advisory board of the Society for Wind Vigilance, an obvious attempt to imply that these facts tainted their work.
As we have already mentioned, Knopper failed to disclose his close business association with wind developers until he was asked the question after the presentation, and he certainly did not mention it when he talked about his own published research. And in fact, some people in the audience noted that in at least one case, the research he himself conducted in collaboration with his colleagues had serious problems of its own (Projected contributions of future wind farm development to community noise and annoyance levels in Ontario, Canada). Critics in the audience took exception to the fact the data Knopper used were derived from computer models that came from wind turbine developers’ asessments of noise for proposed or approved projects, not data from actually operating wind turbines. He also had to admit that he could not “speak exactly to what the developers and their consultants have been measuring or modelling” (with respect to which type of decibel). His knowledgeable audience critics questioned why he was showing them this study if he could not identify, consider or control for an important variable in the data he analyzed.
So while Knopper seemed keen to allege deficiencies in studies showing that there are health problems associated with the operations of wind turbines, he avoided any such analysis of studies that come to the opposite conclusion. Amongst others, he mentioned an often-cited study from New Zealand purporting to show that psychological expectations explain health complaints due to wind turbines. In fact, the flawed study merely confirms that there is such a thing as suggestibility and says nothing credible about wind turbine health problems per se. But wind proponents and their supporters love to refer to it as support for the notion that adverse health effects relating to wind turbines are not real, just in people’s suggestible-prone heads.
Weight of scientific evidence is heavily biased
Knopper concluded, not surprisingly, that “based on the findings and scientific merit” (his emphasis) of the available studies, the weight of the evidence indicates that wind turbines are not connected to adverse health effects, when sited properly. But do we even know what “sited properly” means? (Not that these useless and destructive industrial monsters should be sited anywhere.) In Ontario, the 550 metre set-back for industrial wind turbines is an arbitrary standard drawn out of thin air. No government health study was conducted to come up with this measure.
Knopper went on to support his conclusion with reference to government statements to the same effect, that is, governments that had or have a vested interest in removing all conceivable obstacles to the implementation of their misguided green energy programs. He also cited legal proceedings such as 19 Ontario Environmental Review Tribunal (ERT) hearings, and an Ontario Divisional Court appeal. What he failed to mention is that in those arenas, the rules ensure that the odds are stacked against being able to prove that industrial wind turbines cause adverse health effects. Under the unfair stipulations of Ontario’s Green Energy Act and the ERT, appellants have to achieve the impossible feat of proving that there will be serious health effects from a project that has not yet been built. He also did not mention that some wind companies have violated the mandatory setbacks, and when they do in Ontario, the Ministry of the Environment and the Ministry of Health reportedly do next to nothing to enforce the standard, such as it is. What effect does that have on people’s safety?
Indeed, don’t tell me about the (biased, compromised) science!
Human health denied
Human health was given short shrift in the recent Environmental Review Tribunal (ERT) hearing that saw Blanding’s Turtle singlehandedly win the day and save Ostrander Point on Prince Edward County from being turned into the industrial wind factory that had been approved by the Ontario Ministry of the Environment.
The Prince Edward County Field Naturalists advocated successfully for the turtle, but their arguments that birds, bats, Monarch butterflies, and alvars, “naturally open areas of thin soil over flat limestone or marble rock” would also suffer “serious and irreversible harm”, the legal test demanded by the Tribunal, were rejected.
And the Alliance to Protect Prince Edward County (APPEC) did not succeed in making its case for protecting human health, failing to sway the ERT that the approved wind factory project would cause serious harm to people’s health.
In a July 4, 2013 news release, APPEC said it was “baffled by the ERT’s decision on human health.” APPEC went on to suggest that the ERT process was “fundamentally flawed.” In order to succeed, APPEC would have had to provide scientific evidence to the ERT that human health was going to be harmed through “direct effects (i.e., audible noise) or indirect effects (i.e., infrasound, low frequency sound, severe annoyance, or by some other mechanism)” caused by the proposed wind factory in question when it was being operated in accordance with the Renewable Energy Approval (REA). APPEC rightly complains that “citizens are required to undertake acoustical and epidemiological research” in order to have any success in making their case to the ERT.
The Ontario government and wind power proponents don’t bother themselves with any such scientific rigour. The REA’s 550-metre residential setback appears to be an arbitrary distance without any scientific basis. Furthermore, the Ministry of Health has conducted no studies on the health effects of industrial wind turbines. This does not stop Ontario’s Chief Medical Officer of Health from asserting that the “weight of the evidence does not support any direct health effects associated with wind turbines if they are appropriately placed, and that is with a minimum of a 550-metre set-back.” But even that paltry set-back concession to protecting human health is routinely nullified by wind companies in the agreements they present to Ontario landowners.
The ERT heard, and acknowledged in its decision, information given by Dr. Cornelia Baines about a University of Auckland study that purports to show that adverse health effects from wind turbines are due to suggestibility. This questionable study has been hauled out ad nauseam, including by David Suzuki, to bolster the notion that adverse health effects of wind turbines are all in the head. The researchers conclude that “psychological expectations could explain the link between wind turbine exposure and health complaints”, when really all their study does is confirm that there is such a thing as suggestibility, period.
The lead author of the study, doctoral candidate Fiona Crichton, states in her abstract that 54 (or 60, depending on which of her reports you want to believe) participants were involved in a “sham-controlled double-blind provocation study” where they were presented with information “designed to invoke either high or low expectations that exposure to infrasound causes specified symptoms.” Lo and behold, the high-expectation group reported more symptomatic changes than the low-expectation group. In this study, which is completely useless insofar as health effects of wind turbines are concerned, you could substitute the infrasound with any non-wind turbine sound and posit high-expectation symptoms of your choice to the subjects and get the same result – a demonstration of suggestibility.
If there is any invocation-of-high-expectations-leading-to-false-beliefs going on, it’s the wind power lobby that has the McGuinty/Wynne government convinced that wind energy is useful, reliable, harmless, economically feasible, environmentally attractive, green, when it really isn’t any of that.
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