Miraloma Park Wind Power Installation Challenged400 Teresita

The Facts The owner of the house at 400 Teresita Boulevard (corner of Reposa) has applied for a permit to install a 35-foot small wind generator (SWG) tower at 400 Teresita, a 21- foot tall home on a block with homes of similar height. The SWG would be installed four feet from the front wall of the house, and would support a swivel head with three six-foot long rotating blades forming a circle 12 feet in diameter. The Miraloma Park Improvement Club, supported by many of the nearby neighbors, requested Discretionary Review (DR) of this project on the following bases: (1) the proposed structure would compromise the architectural character of the block-face and would set a precedent for further erosion of neighborhood character; (2) the proposed site for this turbine does not meet manufacturer’s specifications, so the turbine would be inefficient at this site—poor compensation for the significant loss of neighborhood character and visual appeal in this attractive neighborhood; and (3) the proposed SWG would adversely affect quality of life by introducing noise and light/shadow pollution, creating a strobe effect that would be a traffic hazard at the busy intersection of Teresita and Reposa. The MPIC does not oppose wind-generated power, and we look forward to the development of SWGs suited to urban residential sites. But we oppose installation of this particular model because of its unsuitability to the proposed site and to the built environment, an older section of Miraloma Park. Our commitment is to preservation of the architectural heritage of our older neighborhood, as embodied in Proposition M, which gave rise to the practice and requirement of design review and to the publication and mandated use of the City’s Residential Design Guidelines.windmill-skystream

Manufacturer’s literature for the proposed Skystream 3.7 SWG recommends placement of the unit on at least a one-acre lot, 20 feet higher than the nearest obstruction and 275 feet from the nearest building for maximal power generation. The proposed site is about 2/3 acre, and the installed unit would have a horizontal clearance of 4 feet and a similar vertical clearance. Placement so close to a structure will severely reduce the power delivered. Also, the unit will not deliver more than about a third of rated power in winds averaging less than 12 mph, and 29 mph winds are required for optimal power production. The SF Urban Wind Power Task Force Report and Recommendations state that “Wind energy experts agree that assessing a site’s wind resource—including wind velocity, pressure, direction and turbulence—is a critical first step in evaluating whether a site is a good candidate for wind.” The owner stated at the Pre-Application meeting that he has made no measurements of wind at the proposed site; however, a wind turbine engineer and member of the SF Urban Wind Power Task Force, Todd Pelman, advises that the wind at 400 Teresita and in Miraloma Park generally is gusty rather than relatively consistent and laminar (as recommended), and estimated it to average 8 to 12 mph. This factor and the proximity of the unit to the house will result in significant underperformance. Mr. Pelman said in a letter to the Planning Department that “in my opinion the technology selected for this particular build does not meet the criteria for appropriate wind turbine technology in an urban environment as it has been designed for customers who reside in less densely populated areas where both wind quality and aesthetics are not a prime concern.”

In fact, the same model SWG installed one-half mile away at 167 Hernandez (Forest Hill Extension) provided only 1/6 the rated power. Neighbors of this SWG owner complained repeatedly about noise and “strobe effect” from light reflecting off of the blades, which are commonly, reported adverse effects of SWGs. The owner of the Hernandez home has stated that he does not recommend the unit and wants to remove it. The Task Force Report urges demonstration sites in SF, and this one quite close to the proposed Teresita site demonstrates many negatives and no positives. Note also that the Teresita installation would be within 12 to 15 feet of a major intersection, potentially distracting drivers by its size, motion, strobe effects, noise, and novelty, a clear traffic hazzard.

To promote safety and to avoid adverse sound and light effects on neighbors, a publication of the American Wind Energy Association (AWEA), a strong proponent of SWGs, emphasizes that “good practice requires that a turbine in a residential district be ’set back’ from a property line some given distance . . . [which] most commonly translates to the tower height plus the length of one blade.” [AWEA, How and Why to Permit for Small Wind Systems] In the case of the SkyStream 3.7, this recommended setback would be a total of 47 feet. The actual planned setback at the proposed site would be about 6 feet. This publication further asserts that “The best sites for turbines are those where the wind is least obstructed . . . the bottom of the turbine rotor should clear the highest wind obstacle (rooftop, mature tree, etc.) within a 500 foot radius by at least 30 feet. Doing so ensures the turbine reaches consistent, fast wind speeds and prolongs the life of the turbine by avoiding stressful air turbulence.” This requirement will not be met at the 400 Teresita site, where the rotor bottom will be a few feet above the roof and 4 feet from the home’s front wall. The AWEA goes on to advise that “The aesthetic impact of wind turbines may be unacceptable in areas with historic significance where aesthetics play a role in a districts long-established character.” In a neighborhood 80 years old, like Miraloma Park, visual consistency with existing architecture is highly important. In Wind Energy FAQs: “What do I need to know to purchase a residential wind turbine? the AWEA comments that a turbine rated in the range of 5 to 15 kilowatts is recommended “to make a significant [energy] contribution.” According to the Skystream specifications, the proposed model has a rated capacity of 2.4 kw. The AWEA further states that except for turbines with rotors one meter or less in diameter, on very small towers, property size should be 1 acre or more. According to the Skystream specifications, rotors on the proposed model have a diameter of 3.72 meters. In the opinion of Sue Kirkham, a veteran real estate broker who specializes in sales of property in the Miraloma Park, neighborhood property values would be adversely affected by the installation of the SWG. Not only would the turbine interfere with vistas and air spaces, which are important to prospective buyers in this neighborhood, says Ms. Kirkham, but property owners in the vicinity of the SWG would be required to disclose to prospective buyers all of its negative impacts, including, but perhaps not limited to, the noise and light effects of the SWG. Owners of the SWG would be required to disclose these facts, as well as any underperformance of the equipment.

The History In 2009, the San Francisco Urban Wind Power Task Force, constituted by Mayor Newsom to investigate the potential use of wind power in SF, published its Report and Recommendations. This document was quite positive about the prospects of wind-generated energy in some areas of San Francisco, but clearly advised further research into wind speeds at specific locations and into bird flight patterns. If the Planning Department has done these studies, they have not made known their availability to the public. The cover letter of the Task Force’s report to Mayor Newsom (dated 9/21/2009) states, “We are in the very early stages of identifying the potential role ‘urban wind’ might play in the City’s renewable energy future.” Yet, on the basis of this admittedly preliminary investigation, the Mayor issued an executive order directing the Department of Building Inspection and Planning Department to expedite permitting and minimize costs for wind power in the city. The new directive is focused on residential as well as commercial and municipal projects.

The Mayor’s desire to advance wind-derived energy, though laudable for its environmental conservation aims, was a general directive that did not consider one important fact: that SWG technology is nascent and has not yet developed units that are small enough to be efficient yet compatible with modest, close-set homes on small lots. The Mayor delegated these implementation-related considerations to the Planning Department. The Department, however, has waived all design review of these units. But design review is required by the SF Planning Code and is in fact the law. The Department apparently feels that the Mayor’s directive gives it the power, in the interest of “expediting” SWGs, to ignore Code-mandated design review and to approve a permit to place an out-of-scale, 35-foot tall system with rotating blades 12 feet in diameter 4 feet in front of a 21-foot tall house, on a block with other houses of similar height: all of this in a neighborhood designed 80 years ago to maximize front vistas and minimize obstructive clutter by placing all utilities in the rear.

The Planning Department’s design review team declared that the City’s residential design guidelines and the Miraloma Park Residential Design Guidelines (MPRDG), by which such a structure is clearly inappropriate to and out of scale with the house and the block-face in which it is sited, were inapplicable to this project because these Guidelines did not mention wind power turbines! Of course they didn’t, because the Guidelines, the MPRDG adopted by the Planning Commission in 1999 and the City’s antedated the existence of urban SWGs. But that doesn’t mean the Guidelines don’t apply, or that the Department is not still mandated by Code to perform the design review that ought to have led them to reject this project out of hand. In fact, the MPIC would assert that the 35-foot additional structure 4 feet in front of this 21-foot house should be considered part of the structure of the house, a component of the façade which will no longer be viewable from the sidewalk and street without the intrusion of the SWG. The permit application itself defines this proposal as an “alteration” and “new construction”—rightly treating it as though it is part of the structure—and as such out of scale and proportion.

The Code does require design review as part of the permitting process, and it is in the spirit of the Code, with its strong orientation towards preserving residential neighborhood character deriving from Proposition M, if not the letter of the law, that MPIC has requested that the MPRDG be applied. Further, in Appendix D of the SF Wind Power Task Group Report is a memorandum from a senior planner that explicitly requires design review of SWG permits, as follows: “The project sponsor should balance SWG placement decisions that maximize power production with consideration of visual and noise impacts from the installation. Generally, the Department will encourage placement to minimize visibility of the installation from public rights of way, and minimize architectural, noise, and other impacts on the surrounding structures and neighborhood character.” Clearly, the Planning Department has ignored its own advice in failing to perform design review of the proposal for an SWG at 400 Teresita.

Dan Liberthson lives in Miraloma Park. Article is reprinted from Miraloma Life, the newsletter of the Miraloma Park Improvement Club. This article has been edited. The full text is available at www.miralomapark.org

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November 2010