EDP Renewables SH Project GP Ltd. · EDP also adjusted the project to be developed in two phases. 4. EDP proposed to change the turbine model from a Vestas V136 turbine to an Enercon

Decision 24401-D01-2019

EDP Renewables SH Project GP Ltd. Sharp Hills Wind Project Amendments December 20, 2019

Alberta Utilities Commission

Decision 24401-D01-2019

EDP Renewables SH Project GP Ltd.

Sharp Hills Wind Project Amendments

Proceeding 24401

Applications 24401-A001 and 24401-A002

December 20, 2019

Published by the:


Eau Claire Tower

1400, 600 Third Avenue S.W.

Calgary, Alberta T2P 0G5

Telephone: 310-4AUC (310-4282) in Alberta

1-833-511-4AUC (1-833-511-4282) outside Alberta

Email: [email protected]

Website: www.auc.ab.ca

The Commission may, within 30 days of the date of this decision and without notice, correct

typographical, spelling and calculation errors and other similar types of errors and post the

corrected decision on its website.

Decision 24401-D01-2019 (December 20, 2019) i

Contents

1 Decision summary ................................................................................................................. 1

2 Introduction ........................................................................................................................... 1 2.1 Amendment application description .............................................................................. 1

2.2 Hearing process .............................................................................................................. 2 2.3 The Commission’s consideration of the applications .................................................... 2 2.4 Issues raised in this proceeding ...................................................................................... 3

3 Views of the parties on the noise-related aspects of the amendment applications .......... 3 3.1 Views of EDP and the Clearview Group ....................................................................... 3

3.1.1 Applicable version of Rule 012 ........................................................................ 4 3.1.2 Determination of ambient sound levels ............................................................ 5

3.1.3 Representative conditions for the measurement of ambient sound levels ........ 6

3.1.4 Rule 012 compliance and noise impacts on interveners ................................... 8 3.1.5 Post-construction comprehensive sound level surveys ..................................... 8

3.2 Commission findings ..................................................................................................... 9

3.2.1 The development of Rule 012 and its applicability .......................................... 9 3.2.2 Determination of ambient sound levels .......................................................... 12

3.2.3 Representative conditions for the measurement of ambient sound levels ...... 13 3.2.4 Rule 012 compliance and noise impacts ......................................................... 14 3.2.5 Post-construction comprehensive sound level surveys ................................... 15

4 Other factors considered .................................................................................................... 16

5 Conclusion ........................................................................................................................... 16

6 Decision ................................................................................................................................ 17

Appendix A – Proceeding participants ..................................................................................... 18

Appendix B – Oral hearing – registered appearances ............................................................. 19

Decision 24401-D01-2019 (December 20, 2019) 1


Calgary, Alberta

Decision 24401-D01-2019

EDP Renewables SH Project GP Ltd. Proceeding 24401

Sharp Hills Wind Project Amendments Applications 24401-A001 and 24401-A002

1 Decision summary

1. In this decision, the Alberta Utilities Commission considers whether to approve

applications from EDP Renewables SH Project GP Ltd. for amendments to a power plant and

substation, collectively designated as the Sharp Hills Wind Project. After consideration of the

record of the proceeding, for the reasons outlined in this decision, and subject to the specified

conditions, the Commission finds that approval of the proposed amendments to the project (the

project, as amended) are in the public interest.

2 Introduction

2.1 Amendment application description

2. EDP Renewables SH Project GP Ltd. (EDP), pursuant to Approval 22665-D02-2018,1

and Permit and Licence 22665-D03-2018,2 has approval to construct and operate the

Sharp Hills Wind Project in the New Brigden and Sedalia areas.

3. On March 8, 2019, EDP filed applications with the Commission for approval to amend

the Sharp Hills Wind Project, including alterations to the Sharp Hills Wind Farm and the

Sedalia 363S Substation. Specifically, EDP applied for amendments including a change in

turbine model. As a result, 12 turbines were removed from the original project layout and

adjustments were made to the collector system, access roads and transformers in the

Sedalia 363S Substation. EDP also adjusted the project to be developed in two phases.

4. EDP proposed to change the turbine model from a Vestas V136 turbine to an Enercon E-

138 EP3 E2 turbine. The new turbine has a nameplate capacity of 4.2 megawatts, a hub height of

128 metres, and a rotor diameter of 138.6 metres. The maximum tip height of the Enercon

turbine is 2.7 metres lower than the Vestas turbine.

5. As a result of the proposed changes, the total size of the project is reduced from 298.8 to

298.2 megawatts: Phase 1 of the project would consist of 59 turbines for a total generating

capability of 247.8 megawatts, while Phase 2 would consist of 12 turbines for a total capability

of 50.4 megawatts. Sedalia 363S Substation was previously approved to contain two 169-

megavolt ampere transformers; EDP is now proposing one 288-megavolt ampere transformer for

Phase 1, and one 58-megavolt ampere transformer for Phase 2.

1 Power Plant Approval 22665-D02-2018, Proceeding 22665, Applications 22665-A001 and 22665-A002,

September 21, 2018. 2 Substation Permit and Licence 22665-D03-2018, Proceeding 22665, Application 22665-A003,

September 21, 2018.

Sharp Hills Wind Project Amendments EDP Renewables SH Project GP Ltd.


6. In Proceeding 24819, EDP also submitted an application to review and vary a condition

of approval for the Sharp Hills Wind Power Plant. Because the two proceedings deal with the

same project, have been processed according to similar timelines and were considered by a

common Commission panel, the Commission has released this decision concurrently with its

decision on EDP’s review and variance application, Decision 24819-D01-2019.

2.2 Hearing process

7. The Commission provided notice of the applications in accordance with

Rule 001: Rules of Practice, and received statements of intent to participate from the

Clearview Group, Larry and Lorretta Oxamitny and the Bar X Ranch, all of whom indicated

that they were part of the Clearview Group, and from Viola Olsen. The Commission granted

standing to certain members of the Clearview Group, namely Cory and Nicole Blair,

Kristine Fossum, Randy Hayworth, Darren and Kathy Simpson, and Lloyd Wagstaff, but limited

the scope of their participation to addressing potential increased noise impacts as a result of the

proposed amendments.3

8. A public hearing to consider the noise-related aspects of the applications was held from

October 21, 2019 to October 23, 2019, in Calgary, Alberta.

2.3 The Commission’s consideration of the applications

9. Relevant to the Commission’s consideration of the applications are sections 11, 14, 15

and 19 of the Hydro and Electric Energy Act. In accordance with Section 17 of the

Alberta Utilities Commission Act, the Commission must assess the social, economic,

environmental and other effects of the project, as amended, when deciding if its approval is in

the public interest.

10. In applications such as this one, where the proponent requests to amend its previously-

approved project, the AUC’s public interest assessment focuses on the incremental effects

associated with the proposed amendments. An amendment application does not re-open

consideration of the project as a whole. Accordingly, in this proceeding, the Commission must

consider any incremental effects resulting from a change in turbine model and corresponding

changes to the project layout, collector system, access roads and transformers in the

Sedalia 363S Substation.

11. The Commission considers that the public interest will be largely met if an application

complies with existing regulatory standards and the public benefits of the project, as amended,

outweigh its negative impacts.4 The Commission must take into account the purposes of the

Hydro and Electric Energy Act and the Electric Utilities Act5 and cannot consider the need for

the project or whether it is the subject of a renewable electricity support agreement under the

Renewable Electricity Act. The Commission must also determine whether an applicant has met

the requirements of Rule 007: Applications for Power Plants, Substations, Transmission Lines,

Industrial System Designations and Hydro Developments and Rule 012: Noise Control. In

3 Exhibit 24401-X0049, Ruling – Standing on amendment application, September 4, 2019. 4 EUB Decision 2001-111: EPCOR Generation Inc. and EPCOR Power Development Corporation 490-MW

Coal-Fired Power Plant, Application 2001173, December 21, 2001, page 4. 5 Hydro and Electric Energy Act, RSA 2000 c H-16, ss 2, 3.; Electric Utilities Act, SA 2003, c E-5.1.



addition, an applicant must obtain all approvals required by other applicable provincial or federal

legislation.

2.4 Issues raised in this proceeding

12. The Commission’s recent amendments to Rule 012 came into effect on August 1, 2019.

One of the amendments found in the current version of Rule 012 is a new section (Section 2.6)

that expressly addresses ambient sound levels (ASLs). This decision marks the Commission’s

first opportunity to interpret those amendments.

13. In this decision, the new version of Rule 012 is referred to as “the current version of

Rule 012” whereas the version of Rule 012 that it replaced is referred to as the “previous version

of Rule 012.”

14. The previous and current versions of Rule 012 gave applicants two options for

establishing ASLs and permissible sound levels (PSLs) at receptors:

• If the assumed ASLs and PSLs set out in Table 1 of Rule 012 are representative of the

project study area (at receptors), an applicant may use those assumed values.

• If the project area is located in a pristine area or an unusually noisy area and the assumed

ASLs and PSLs set out in Table 1 of Rule 012 are not representative of the project study

area (at receptors), an applicant can rely on measurements to determine the ASL. Where a

measured ASL is used, a Class A2 adjustment (also called an ambient monitoring

adjustment) is established based on the measured ASL and then applied to the PSL.

15. The primary issue raised in this proceeding is whether it was reasonable for EDP to use

an assumed nighttime ASL of 35 dBA (based on Table 1 of Rule 012) when calculating the PSLs

at various receptors in the project area. EDP submitted that the assumed nighttime ASL was

representative of the project study area. The Clearview Group disagreed and argued that its

measurements demonstrated that ASLs for certain receptors in the project area were lower than

the assumed nighttime ASL.

3 Views of the parties on the noise-related aspects of the amendment applications

3.1 Views of EDP and the Clearview Group

16. EDP retained RWDI AIR Inc. to prepare a noise impact assessment (NIA) for the project

reflecting the proposed amendments (the project NIA). The project NIA was completed on

February 11, 2019,6 and updated on May 3, 2019.7 EDP retained Teresa Drew from RWDI and

Payam Ashtiani from Aercoustics Engineering Ltd. to provide evidence on the noise impact and

noise-related issues associated with the project, as amended. Ms. Drew was the primary author of

the project NIA, prepared reply evidence8 in response to issues raised by the Clearview Group,

and testified at the hearing. Mr. Ashtiani prepared evidence9 in response to issues raised by the

6 Exhibit 24401-X0015, Attachment LOE-K Noise Impact Assessment. 7 Exhibit 24401-X0015.01, Attachment LOE-K Noise Impact Assessment. 8 Exhibit 24401-X0056, RWDI Reply Evidence SHWF 1603477 - October 11, 2019. 9 Exhibit 24401-X0055, AERC001 - SHWF Payam Ashtiani Evidence - October 11, 2019.



Clearview Group, focusing specifically on representative ASLs and Class A2 adjustments.10

Mr. Ashtiani also testified at the hearing.

17. The Clearview Group retained Mr. Henk de Haan of dBA Noise Consultants Ltd. to

review the project NIA and related noise documents. Mr. de Haan authored a report summarizing

his review of the project NIA and other noise-related evidence and developed a model to predict

noise impacts at the five intervener residences: Receptor A (Cory and Nicole Blair), Receptor B

(Kristine Fossum), Receptor C (Randy Hayworth), Receptor D (Darren and Kathy Simpson), and

Receptor E (Lloyd Wagstaff).11 Because these five residences (collectively, the intervener

residences), are located more than 1.5 kilometres from project turbines, they were not included in

the project NIA prepared by RWDI. Mr. de Haan measured ASLs at four of the intervener

residences: Receptor A, Receptor B, Receptor C and Receptor E.12 Mr. de Haan also testified at

the hearing.

3.1.1 Applicable version of Rule 012

18. EDP submitted that the project NIA is grandfathered under and complies with the

previous version of Rule 012, in effect from July 4, 2017 to July 31, 2019, on the basis that the

project NIA was completed and applications were submitted prior to the current version of

Rule 012 coming into effect on August 1, 2019.13 In EDP’s view, applying the current version of

Rule 012 to the project NIA would be inconsistent with the fundamental principles of procedural

fairness, including the right to know the case to be met.14

19. EDP stated that the project NIA did not explicitly justify the use of assumed ASLs in

Table 1 because the requirement to do so did not appear until the current version of Rule 012,

which came into effect after the submission of the project NIA. Ms. Drew testified that while a

discussion of this process was not incorporated in the text of the NIA report, in practice, the

existing ambient environment was considered prior to using Table 1 to identify representative

ASLs for the project NIA.15 EDP further stated that the Commission did not request an

explanation or justification for the ASLs used in the project NIA during the application review

process.16

20. In response, the Clearview Group submitted that it is not an NIA that may or may not be

grandfathered but the facility itself; 17 and as a result, the current version of Rule 012 should

apply because the facility has not yet been constructed. 18

21. In the Clearview Group’s view, RWDI was aware of the impending revisions to Rule 012

when it filed the February 11, 2019 version of the project NIA, and the current version of

Rule 012 was released on April 16, 2019, prior to RWDI’s filing of the May 3, 2019 version of

the project NIA.19 Nevertheless, EDP did not seek clarification on which version of Rule 012

10 A Class A2 adjustment is an adjustment to the permissible sound level for locations where the measured ASL is

not representative of the assumed ambient sound environment based on Table 1 of Rule 012. 11 Exhibit 24401-X0052, Sharphills Amendment Application Review A. 12 Exhibit 24401-X0053, H.17.444.01-B, ASL Survey Sharp Hills – B. 13 Exhibit 24401-X0056, RWDI Reply Evidence SHWF 1603477 - October 11, 2019, PDF page 5. 14 Transcript, Volume 2, page 180, lines 3-6. 15 Transcript, Volume 1, page 38, line 25 to page 40, line 24. 16 Transcript, Volume 2, page 177, lines 15-20. 17 Transcript, Volume 2, page 202, lines 10-14. 18 Transcript, Volume 2, page 204, lines 12-18. 19 Transcript, Volume 2, page 203, line 17 to page 204, line 6.



applied.20 The Clearview Group disagreed with EDP’s argument that applying the current version

of Rule 012 raises a potential procedural fairness issue. Instead, it suggested that EDP made its

own decision to not seek guidance on the regulatory requirements applicable in the

circumstances.21

22. The Clearview Group argued that the current version of Rule 012 requires an applicant to

assess ambient sound as part of an NIA;22 however, “RWDI did not assess ambient sound levels,

nor did it explain in its NIA why the assumed ambient sound level is justified.”23 The

Clearview Group noted that although Ms. Drew testified that assumed ASLs are appropriate

because the proposed project is in rural Alberta, in an area with no major non-energy-related

noise sources, this was “clearly an after-the-fact explanation” and “does not constitute a true

assessment of ambient sound as is required by Rule 012.”24

23. In response to the Clearview Group’s submission that the current version of Rule 012

applies because the facility has not been constructed, EDP argued that every NIA filed with the

Commission between April 16, 2019 (when the current version of Rule 012 was released) and

August 1, 2019 (when the current version of Rule 012 became effective) would have to be

revised and refiled. In EDP’s view, this argument would be contrary to Commission practice and

the basic principles of statutory interpretation, and must therefore be rejected.25

24. With respect to the characterization of ASLs in different versions of Rule 012,

Mr. Ashtiani stated that “[a]n Assumed Ambient Sound Level of at least 35dBA and a

corresponding Permissible Sound Level of at least 40dBA has been used in rural Alberta for

decades with success.”26 In response, Mr. de Haan asserted that assumed ASLs were not

questioned in previous versions of Rule 012 because their use was mandated.27 EDP stated that

noise experts for both parties agreed that the use of assumed ASLs was generally not questioned

under previous versions of Rule 012.28

3.1.2 Determination of ambient sound levels

25. In its reply evidence, RWDI justified the use of Table 1 of Rule 012 to establish ASLs on

the basis that the project area has predominate agricultural and energy industry land use, which is

typical of rural Alberta, and that it has neither pristine nor noisy surroundings. 29 RWDI referred

to the definition of “pristine area” in Rule 012 and concluded that “[g]iven the level of local

development and absence of large industrial sound sources, the use of Table 1 from Rule 012 to

establish the ambient sound level in the NIA is well founded.”30

26. EDP submitted that granting a downward Class A2 adjustment in this case or future

analogous cases will have widespread adverse effects on industry in the province,31 including

20 Transcript, Volume 2, page 204, lines 7-11. 21 Transcript, Volume 2, page 207, lines 1-7. 22 Transcript, Volume 2, page 209, lines 18-20. 23 Transcript, Volume 2, page 209, line 25 to page 210, line 3. 24 Transcript, Volume 2, page 210, lines 9-19. 25 Transcript, Volume 2, page 230, line 17 to page 231, line 4. 26 Exhibit 24401-X0055, AERC001 - SHWF Payam Ashtiani Evidence - October 11, 2019, PDF page 7. 27 Transcript, Volume 1, page 133, lines 15-21. 28 Transcript, Volume 2, page 177, line 21, to page 178, line 3. 29 Exhibit 24401-X0056, RWDI Reply Evidence SHWF 1603477 - October 11, 2019, PDF page 5. 30 Exhibit 24401-X0056, RWDI Reply Evidence SHWF 1603477 - October 11, 2019, PDF page 6. 31 Transcript, Volume 2, page 187, lines 22-25.



possibly leading to approved and existing energy-related facilities falling out of noise

compliance.32 EDP also raised concerns with inconsistencies between AUC and Alberta Energy

Regulator (AER) noise regulations that could cause an uneven playing field for different types of

energy infrastructure.33 EDP also noted that Class A2 adjustments could lead to inconsistent

PSLs for neighbouring receptors in a common project area because ASL measurements may be

different at each individual receptor.34

27. The Clearview Group submitted that although the current version of Rule 012 allows for

the use of assumed ASLs in the absence of measured data, an applicant must nonetheless explain

why assumed ASLs are representative of the project area.35 In its view, RWDI failed to provide

adequate justification in this regard. Conversely, the Clearview Group submitted that

Mr. de Haan complied with the requirements of Rule 012 by first assessing the project area using

a desktop study and determining that actual ASLs could be significantly lower than the assumed

ASLs and then conducting measurements to determine representative ASLs for the project area.36

Mr. de Haan’s measurements indicated that the nighttime ASLs at the receptors range from 26 to

27 dBA (i.e., 8 to 9 dB less than the assumed ASLs used in the project NIA).37 The Clearview

Group submitted that “…a properly done ambient sound level survey yielding measured results

is more representative than an assumed value that is applied arbitrarily throughout the entire

[rural part of the] province….”38

28. Although Mr. de Haan agreed in cross-examination that there are oil and gas facilities

and agricultural developments in the project area,39 he opined that the area surrounding the

intervener residences is pristine, as defined in Rule 012. Mr. de Haan pointed out that pristine is

defined in Section 2.6 of Rule 012 as an area where nighttime ASLs might be less than 35 dBA.

He explained that this definition is in the main body of Rule 012 and that he took it as his

guiding principle in defining pristine.40

3.1.3 Representative conditions for the measurement of ambient sound levels

29. EDP argued that Mr. de Haan’s measurement data did not adequately establish

representative conditions on the basis that (i) there was insufficient data collected

(i.e., measurement duration was too short for a downward Class A2 adjustment) and

(ii) measurements were improperly transferred between receptors (i.e., data measured at

one receptor was used to support a Class A2 adjustment at another receptor, where

measurements were not collected).

30. Mr. Ashtiani stated that the measurement duration used to establish representative

conditions for ASLs and/or Class A2 adjustments is dependant on whether there is a nearby

noise source that is constant, reliable and predictable. He stated that short-term measurements

will suffice in circumstances where there is a relatively constant dominant sound source in the

vicinity of a receptor. Mr. Ashtiani submitted that in circumstances where there is an absence of

32 Transcript, Volume 2, page 189, line 19 to page 190, line 6. 33 Transcript, Volume 2, page 190, lines 9-15. 34 Transcript, Volume 2, page 190, lines 16-22. 35 Transcript, Volume 2, page 209, line 5 to page 210 line 19. 36 Transcript, Volume 2, page 210, line 22 to page 211 line 9. 37 Transcript, Volume 2, page 215, lines 13-23. 38 Transcript, Volume 2, page 214, lines 21-25. 39 Transcript, Volume 1, page 129, line 20 to page 130, line 3. 40 Transcript, Volume 1, page 127, line 8 to page 129, line 14.



industry or traffic noise, longer measurements (i.e., a minimum of two weeks) are necessary to

capture the typical variability in ASLs.41 Applying this reasoning to the project area,

Mr. Ashtiani submitted that the ASLs measured by Mr. de Haan over a relatively short period

(i.e., 24 hours) are not representative of the acoustic environment at the receptors.

31. Conversely, Mr. de Haan submitted that 24 hours of data is appropriate and supported by

Rule 012 and that measurement surveys longer than 24 hours are not required.42 He also

indicated that there are no industry standards for the duration of ASL measurements and that

Rule 012 does not set out a process for establishing representative conditions for ASL

measurements.43

32. In addition to disagreeing on the appropriate duration of an ASL measurement survey,

parties also disagreed on the appropriateness of Mr. de Haan’s use of measurement data collected

at Receptor C to establish a representative ASL for Receptor D. Using this approach, the

Clearview Group predicted that Receptor D would experience the largest exceedance of the

Class A2-adjusted PSL.44 In addition, Mr. de Haan testified that the residents of Receptor D

(Mr. and Ms. Simpson) expressed a sensitivity to noise.45

33. Commenting on the transferability of measured data between receptors C and D,

Mr. Ashtiani stated that “…ambient levels will vary significantly due to the proximity of trees,

the type and make up of foliage, the wind conditions prevalent and traffic patterns.”46 He

cautioned that measured ambient sound data from Receptor C may not be representative of

conditions at Receptor D due to differences in distance between receptors and shelterbelts and

the amount of vegetation and forested areas and their orientation from the prevailing wind

direction.47 Mr. Ashtiani concluded that there is insufficient evidence to suggest that the ASLs at

receptors C and D are transferrable.48

34. For his part, Mr. de Haan stated that applying measured data from Receptor C

to Receptor D is valid because the two receptors have similar sound environments. He

testified that ASLs at Receptor C and Receptor D are comparable because: (i) both Receptor C

and Receptor D are rural dwellings; (ii) they are in close proximity to each other

(i.e., 1.65 kilometres); (iii) both have shelter belts; and (iv) both are located similar distances

from the same road.49

35. Mr. de Haan stated that he selected Receptor C due to its availability and that it was

unnecessary to collect additional measurements at Receptor D given the similarities of the two

receptors.50

41 Exhibit 24401-X0055, AERC001 - SHWF Payam Ashtiani Evidence - October 11, 2019, PDF page 5. 42 Transcript, Volume 1, page 123, line 13 to page 124, line 13. 43 Transcript, Volume 1, page 164, line 21 to page 166, line 5. 44 Exhibit 24401-X0052, Sharphills Amendment Application Review A, PDF page 4. 45 Transcript, Volume 1, page 155, lines 4-13. 46 Exhibit 24401-X0055, AERC001 - SHWF Payam Ashtiani Evidence - October 11, 2019, PDF page 7. 47 Transcript, Volume 1, page 75, lines 14-20. 48 Transcript, Volume 1, page 76, lines 17-19. 49 Exhibit 24401-X0053, H.17.444.01-B, ASL Survey Sharp Hills – B, PDF page 2; Transcript, Volume 1,

page 122, line 17-23; Transcript, Volume 1, page 146, lines 11-16. 50 Transcript, Volume 1, page 159, line 21 to page 160, line 24.



3.1.4 Rule 012 compliance and noise impacts on interveners

36. Although EDP acknowledged that the proposed amendments will result in increased

sound levels at 23 receptors compared to the original version of the project, it argued that these

increases will be marginal (i.e., between 0.7 and 1.1 dBA).51 EDP referred to Mr. de Haan’s

testimony that a change of 3 dB is considered “just noticeable or barely noticeable”.52 Based on

his testimony, EDP submitted that noise impacts resulting from the requested change to the

project turbine model are minor and unlikely to be noticed by residents in the area. EDP

submitted that the project amendments will be compliant with the requirements of Rule 012, and

should therefore be approved.53

37. RWDI stated that the cumulative sound level at the intervener residences would comply

with the PSLs established based on Table 1 of Rule 012.54 EDP argued that the distance between

the intervener residences and the closest turbine is between 1.8 and 3.8 kilometres and the

predicted noise contribution from the project at those residences is too small to be measured.55 In

addition, RWDI predicted that the project noise contribution at Receptor D would be 24.6 dBA

under the project maximum operating conditions.56

38. Mr. de Haan submitted that during the nighttime period, A2-adjusted PSLs would be

exceeded by 0.5 dB at Receptor C and by 2.3 dB at Receptor D.57 He predicted that the project

noise contribution at Receptor D would be 24.8 dBA under the project maximum operating

conditions.58

3.1.5 Post-construction comprehensive sound level surveys

39. EDP confirmed that it would adhere to its previous commitment in

Decision 22665-D01-2018 to conduct a post-construction comprehensive sound level (CSL)

survey to demonstrate project compliance in accordance with Rule 012.59 EDP recommended

four receptors for the post-construction CSL survey: R19, R28, R32 and R35.60 Mr. de Haan

agreed that a post-construction CSL survey would be appropriate to verify Rule 012 compliance

and did not object to the four receptor locations recommended by EDP. Mr. de Haan also

recommended that ASL measurements be conducted before construction.61

40. During the hearing, noise consultants for EDP and the Clearview Group agreed that

post-construction CSL surveys should not be conducted at the intervener residences because the

project’s noise contribution at these locations would be too small to be isolated or determined

effectively, making it difficult to assess project compliance.62

51 Transcript, Volume 2, page 195, lines 1-5. 52 Transcript, Volume 1, page 141, lines 13-15; Transcript, Volume 2, page 195, lines 6-8. 53 Transcript, Volume 2, page 195, lines 18-21. 54 Exhibit 24401-X0056, RWDI Reply Evidence SHWF 1603477 - October 11, 2019, PDF page 6. 55 Transcript, Volume 2, page 232, lines 17-20. 56 Exhibit 24401-X0072, EDPR Sharp Hills LOE IR3 06NOV20191, PDF page 6. 57 Exhibit 24401-X0052, Sharphills Amendment Application Review A, PDF page 4. 58 Exhibit 24401-X0076, Memo re Comments on IR Response EDP-AUC-2019OCT25-001, PDF page 7. 59 Exhibit 24401-X0026, EDPR Sharp Hills LOE IR1 06MAY2019, PDF page 9. 60 Exhibit 24401-X0043, EDPR Sharp Hills LOE IR2 09JUL2019, PDF page 6. 61 Transcript, Volume 1, page 157, lines 6-14. 62 Transcript, Volume 1, page 100, line 22 to page 102, line 4; page 152, lines 8-12.



3.2 Commission findings

41. In the findings below, the Commission addresses the issues raised in this proceeding: the

applicability of Rule 012, the determination of ASLs and the representative conditions for their

measurement, Rule 012 compliance and noise impacts and, lastly, a post-construction CSL

survey. The Commission considers it helpful to begin by reviewing the history of Rule 012.

3.2.1 The development of Rule 012 and its applicability

42. Rule 012 has its origins in AER Directive 038: Noise Control. In fact, Rule 012 was based

on the February 2007 version of Directive 038, which remains in force today. Directive 038 sets

an assumed nighttime ASL of 35 dBA for rural areas and states, “[b]ased on research conducted

by the Environment Council of Alberta, the average rural ambient sound level in Alberta is about

35 dBA at night.”63

43. Directive 038 effectively allows applicants to establish ASLs by using an assumed ASL

or, where that is not representative of the project area, by using an ASL based on measurement

and establishing a Class A2 adjustment. Assumed ASLs are determined using Table 1 of

Directive 038.

44. Directive 038 defines a Class A2-ambient monitoring adjustment as follows:

The ambient sound level (ASL) is the average sound environment in a given area without

the contribution of any energy-related industry. An adjustment for an incremental change

to the BSL [basic sound level]64 is applicable only when BSLs (Table 1) are thought not

to be representative of the actual sound environment and when ASLs have been

measured. The only two cases where it may be necessary to determine the ambient sound

level are

• areas considered to be pristine (defined in Appendix 1), and

• areas with non-energy industrial activity that would impact the background noise

levels.65

45. The term “pristine area” is defined in Directive 038 as follows:

A pure, natural area that might have a dwelling but no industrial presence, including

energy, agricultural, forestry, manufacturing, recreational, or other industries that already

impact the noise environment.66

46. Based on a plain and ordinary reading, the effect of Directive 038 is that the default ASL

in rural Alberta for facilities regulated by the AER is 35 dBA and that adjustments to this ASL

can be made only in limited circumstances.

63 Alberta Energy Regulator Directive 038: Noise Control, February 16, 2007, page 7. 64 Basic sound level (BSL): The A-weighted Leq sound level commonly observed to occur in the designated land-

use categories with industrial presence. The BSL is assumed to be 5 dBA above the ASL and is set out in

Table 2 of Directive 038. 65 Directive 038: Noise Control, PDF page 12. 66 Directive 038: Noise Control, PDF page 35.



47. When the AUC was first established in 2008, it adopted Directive 038 for its own use. In

February 2009, the Commission sought stakeholder feedback on the then proposed Rule 012. In

a bulletin announcing that consultation, it stated:

This Rule mirrors the technical requirements of the Energy Resources Conservation

Board Directive 38 – Noise Control. However, some changes were made to tailor the

requirements to address facilities and operations under the jurisdiction of the

Commission.67

48. The first version of Rule 012 came into force on March 24, 2009. The AUC has amended

it six times since then. Like Directive 038, every iteration of Rule 012 has included a Table 2:

Class A Adjustments, which identifies the two situations where the use of an assumed ASL may

not be representative of the project area: (a) pristine areas (as defined in each version of the rule),

and (b) areas that have non-energy industrial activity that would impact the ASL.

49. Rule 012’s definition of the term “pristine area” is similar to that in Directive 038. It has

not materially changed since 2012:

a natural area that might have a dwelling but no industrial presence, including energy,

agricultural, forestry, manufacturing, recreational or other industries that affect the

noise environment.68 (emphasis added)

50. In summary, Directive 038 and the previous versions of Rule 012 allowed applicants to

use an assumed ASL unless the project area was characterized as pristine or unusually noisy.

However, neither Directive 038 nor any predecessor version of Rule 012 prohibited interveners

from challenging the use of an assumed ASL when determining PSLs in a project area.

51. Like the previous versions of Rule 012, the current version includes Table 2: Class A

Adjustments, in which the circumstances for deviating from an assumed ASL are identified.

Table 2 remains unchanged from the previous version:

Ambient monitoring adjustment is applicable if the measured ambient sound level is not

representative of the assumed ambient sound environment. The ambient sound levels may

be measured in areas considered to be pristine as defined in Appendix 1 or areas that

have non-energy industrial activity that would impact the ambient sound levels.69

(emphasis added)

52. However the current version of Rule 012 added a new section devoted exclusively to

ASLs. Section 2.6 reads as follows:

(1) The ambient sound level is a composite of different airborne sounds from many

sources, from far away and near the point of measurement. It does not include noise

from wind and must be determined without contribution from energy-related

facilities.

(2) The average nighttime ambient sound level in rural Alberta is approximately 35

dBA. Rule 012 does not require the use of a specific ambient sound level in a noise

impact assessment. Applicants must assess the ambient sound level as part of a

67 Bulletin 2009-03, Rule 012 – Noise Control, February 12, 2009. 68 Rule 012: Noise Control, PDF page 46. 69 Rule 012: Noise Control, PDF page 8.



noise impact assessment, particularly where either noisy (i.e., nighttime ambient

sound levels might be greater than 35 dBA) or pristine (i.e., nighttime ambient

sound levels might be less than 35 dBA) surroundings prevail.

(3) The ambient sound level must be determined under representative conditions that

portray typical conditions for the area, and not under extreme conditions (e.g. an

unusually quiet day). If the ambient sound level is established by means of an

ambient sound level survey, the maximum acceptable dwelling level wind speed is

three m/sec to exclude contamination from sounds caused by higher wind speeds.

(4) In the absence of measurement, the nighttime ambient sound level is assumed to be

five dB less than the basic sound level and the daytime ambient sound level is

assumed to be five dB less than the basic sound level plus the daytime adjustment.

(5) Applicants may use Table 1 to establish the ambient sound level. However, where

Table 1 is used, an applicant must explain why values in Table 1 are representative

of the project study area.

(6) In circumstances where applicants find that ambient sound levels from Table 1 are

not representative of the project area, measurements for Class A2 adjustments may

be considered.70

53. In the consultation documents attached to Bulletin 2018-19,71 the Commission stated that

Section 2.6 was being added to Rule 012 to “clarify approaches to defined ASLs.”72 In the

Commission’s view, the addition of Section 2.6 has not materially changed the requirements for

establishing ASLs, and subsequently PSLs, in an NIA. Rather, where the following were implicit

in the previous version of the rule, Section 2.6 expressly:

• Clarifies that Rule 012 does not require the use of a specific ASL in an NIA.

• Provides that, in the absence of measurements, the nighttime ASL is assumed to be five

dB less than the basic sound level defined in Table 1 of Rule 012.

• States that the minimum basic sound level is 40 dBA, and that substracting 5 dB from

this minimum basic sound level results in an assumed ASL of 35 dBA, which is the

average nighttime ASL in rural Alberta.

• States that where applicants decide to use the assumed ASL, they must be able to explain

why the use of an assumed ASL is reasonable.

54. As in previous versions of the rule, Section 2.6 emphasizes that an important factor to

consider in deciding to rely on an assumed ASL is whether the project is located in a pristine

area, which is defined as a natural area with no agricultural or industrial (including energy-

related or non-energy related) presence.

70 Rule 012: Noise Control, PDF pages 15 and 16. 71 Bulletin 2018-19, Changes to AUC Rule 012: Noise Control, December 19, 2018. 72 AUC Rule 012: Noise Control Commission responses to stakeholder comments, December 18, 2018, page 21,

http://www.auc.ab.ca/regulatory_documents/Consultations/2018-12-18-Rule012-StakeholderComments-

Responses.pdf.

http://www.auc.ab.ca/regulatory_documents/Consultations/2018-12-18-Rule012-StakeholderComments-Responses.pdf

http://www.auc.ab.ca/regulatory_documents/Consultations/2018-12-18-Rule012-StakeholderComments-Responses.pdf



55. Having regard to the foregoing, it is not necessary to determine which version of

Rule 012 applies in the circumstances of these applications because there are no substantive

differences between the previous and current versions of the rule that are material to the

Commission’s determination of the fundamental noise issues raised in these applications namely,

the proper ASLs (and resulting PSLs) for the 37 receptors potentially affected by the project

amendments and compliance with Rule 012 at those receptors.

56. It is evident from the express language of the previous and current versions of Rule 012

that an application for a Class A2 adjustment is available where there may be an issue as to

whether Table 1 values are representative of the ambient sound environment in the project study

area or, as here, evidence is tendered suggesting that Table 1 values are not representative. In

such circumstances, the Commission must focus on whether the evidence supports that the

Table 1 values are representative of the ambient sound environment at the subject receptors and

if not, what ASL should be used in establishing the PSL at those receptors. And, while Rule 012

does not currently and has never expressly restricted the opportunity for measurements and the

availability of a Class A2 adjustment to pristine and noisy circumstances, its intended purpose

effectively limits any other circumstance to one where both the evidence of measured ASL and,

most significantly, the reasons for the proposed Class A2 adjustment are compelling such that

they outweigh the reasons for reliance on the assumed values. As discussed in more detail below,

neither of these conditions are satisfied on the evidence in this proceeding.

57. Notwithstanding the above, the Commission recognizes the apparent inconsistency

pertaining to the definition of pristine area that was created when Section 2.6 was added.

Table 2, which sets out the requirements for Class A2 adjustments refers to the definition of

pristine area found in the glossary section of the rule, whereas Section 2.6(2) refers to a “pristine

area” described as “(i.e nighttime ambient sound levels might be less than 35dBA)”. While the

intent of the changes to Rule 012 was to add clarification, this particular amendment had the

opposite effect and has caused confusion. This Commission panel consequently recommends that

Section 2.6(2) of Rule 012 be further amended by the Commission to simply refer to the

definition of pristine area in Appendix 1.

3.2.2 Determination of ambient sound levels

58. In the hearing, the Clearview Group suggested that measured ASLs are inherently better

(i.e., more representative) than assumed ASLs because measured ASLs are based on data

collected at the receptor locations.

59. The Commission’s use of the assumed ASLs in Rule 012 for rural areas is intended to

provide a reasonable, consistent and practical mechanism for predicting and assessing

cumulative sound levels in NIAs, especially where, as is the case for wind developments, the

project area can span many square kilometres. The use of assumed ASLs is also intended to

promote comparability when assessing energy-related projects in similar environments and allow

for consistency when assessing noise compliance at receptors within a common project area.

Further, assumed ASLs promote consistent PSLs for energy applications filed at different times

and prevent divergence between PSLs for oil and gas facilities regulated by the AER and utility

facilities regulated by the AUC.

60. The Commission emphasizes that the use of an assumed nighttime ASL of 35 dBA is not

intended to describe ambient conditions at a particular receptor on a particular night; instead, this

value is intended to describe typical or representative ambient conditions for receptors in rural



areas where agricultural and/or oil and gas activity is also taking place. As such, Rule 012 (the

current and previous version) makes it clear that Class A2 downward adjustments are appropriate

when considering pristine areas without agricultural, industrial or oil and gas related operations

and, as is more often the case, Class A2 upward adjustments are appropriate for unusually noisy

areas such as locations near highways or rail lines.

61. Although the Commission accepts that measurements may yield ASLs that are different

than the average, it also recognizes that measured ASLs reflect the particular environmental

conditions and nearby activities that are present at the time the measurements are collected. As

stated by both parties, ASLs can be highly variable.

62. In rural areas where agricultural and/or oil and gas activities take place, the noise from

those activities can be intermittent and unpredictable, making it difficult to obtain a

representative ASL. It is for this reason that the use of an assumed ASL is generally considered

reasonable in those areas. A proponent’s obligation under Subsection 2.6(5) of Rule 012 to

demonstrate the reasonableness of using an assumed ASL in those instances (rural areas where

agricultural and/or oil and gas activities take place) can be satisfied by documenting the

existence of such activities. And although it nonetheless remains open to interveners to challenge

the use of the assumed ASL by providing evidence of compelling circumstances warranting a

departure from the assumed values as well as measurement data in support of a Class A2

adjustment, obtaining representative ASL values via measurement in a non-pristine environment

requires a comprehensive measurement program of sufficient duration to capture conditions that

are typical of the acoustic environment at a given location.

63. The evidence presented by the Clearview Group is not sufficient to demonstrate that the

project area is pristine or that the ASL in the project area is materially different than other parts

of rural Alberta, where oil and gas and agricultural activities also take place.

64. Rather, the Commission finds EDP’s description of the project area as “typical of rural

Alberta with predominate agricultural and energy industry land use”73 to be accurate and

consistent with the evidence of Mr. de Haan. Given the presence of agricultural and oil and gas

activities throughout the project area, the Commission finds that it was reasonable for EDP to

conclude that the assumed ASLs based on Table 1 of Rule 012 are representative of the project

area.

3.2.3 Representative conditions for the measurement of ambient sound levels

65. As mentioned above, the Commission is satisfied that the project area is not pristine and

accepts EDP’s submission that the acoustic environment in the project area is consistent with a

typical rural Alberta area. It therefore finds that the use of assumed ASLs based on Table 1 of

Rule 012 is appropriate for these applications. Accordingly, the ASL survey by the interveners

and its results are not a basis upon which to evaluate project compliance and noise impact at the

affected receptors. Nevertheless, the Clearview Group conducted an ASL survey, offered

measured data, and raised representative conditions for the measurement of ASLs as an issue in

this proceeding. As a result, the Commission addresses two issues related to ambient sound

measurements: measurement duration and data transferability.

73 Exhibit 24401-X0056, RWDI Reply Evidence SHWF 1603477 - October 11, 2019, PDF page 5.



66. With respect to measurement duration, Rule 012 states that “… ambient sound level must

be determined under representative conditions that portray typical conditions for the area, and

not under extreme conditions (e.g. an unusually quiet day).”74 Subsection 4.4(1) of Rule 012

states that “[m]ultiple nights may be required to establish representative conditions.”75 As such,

the appropriate duration for ASL surveys is case specific.

67. The Commission agrees with EDP and Mr. Ashtiani that 24 hours of measurement data is

inadequate to establish representative ASLs in circumstances where there are no constant

dominant sound sources. While Rule 012 speaks to a 24-hour measurement duration for CSL

surveys,76 it does not provide specific requirements for the duration of ASL surveys to establish

representative ASLs.

68. In a CSL survey, there is typically a predictable and known noise source being measured

(e.g., post-construction measurements to demonstrate compliance for a new facility). This is not the

case for ASL surveys in a typical rural area, which aim to characterize a variable and unpredictable

sound environment. Therefore, it is necessary for ASL surveys to collect data for longer than

24 hours to capture typical ambient conditions in a study area.

69. Given that the measured receptors in this case have no nearby constant dominant sound

sources but instead have potential high variation of ASLs, the Commission considers that

Mr. de Haan’s measurement survey was of insufficient duration to capture representative

conditions at the receptors. As such, the Commission does not accept that the ASLs measured by

Mr. de Haan over a particular 24-hour period were representative of the acoustic environment for

the intervener residences.

70. With respect to data transferability, Rule 012 allows measurement data collected at one

receptor to be used to establish ASLs at other receptors in a similar acoustic environment. In the

present circumstances, the Commission accepts that Receptor C and Receptor D may have

similar acoustic environments, and that it may have been appropriate to use measurement data

collected at Receptor C to establish the nighttime ASL for Receptor D. However, because the

ASL established at Receptor C is based on an inadequate measurement duration, the Commission

does not accept that the ASL measured at Receptor C should be considered representative of the

ASL at Receptor D. Furthermore, Mr. de Haan’s explanation for why Receptor D was not

selected for ASL measurements was not convincing, given the largest exceedance of the Class

A2-adjusted PSL was predicted for this receptor and the residents of this receptor expressed a

sensitivity to noise.

3.2.4 Rule 012 compliance and noise impacts

71. In light of the Commission’s finding that the use of assumed ASLs based on Table 1 of

Rule 012 is appropriate for these applications, the nighttime PSL for the affected receptors,

including the intervener residences, is 40 dBA. Based on the results of the project NIA, the

Commission finds that cumulative sound levels at all affected noise receptors will likely comply

with that nighttime PSL. Therefore, the project, as amended will likely remain compliant with

the PSLs set out in Rule 012 and approved in the original decision for the project.

74 Rule 012: Noise Control, PDF page 15. 75 Rule 012: Noise Control, PDF page 26. 76 Rule 012: Noise Control, PDF page 23.



72. The Commission agrees with EDP that it is unlikely that the project amendments will

have an adverse impact on the interveners given their distance from the nearest turbine and the

marginal project noise contributions. In particular, the Commission finds that the noise

contribution from the project turbines is too low to have any adverse impact at Receptor D.

3.2.5 Post-construction comprehensive sound level surveys

73. Although the project NIA predicts compliance with Rule 012 PSLs at all receptors, given

the concerns raised by the Clearview Group and that the predicted sound levels are close to the

nighttime PSL at a number of receptors, the Commission requires EDP to complete a

post-construction CSL survey to verify compliance with Rule 012 once the project commences

operation.

74. In selecting monitoring locations for post-construction CSL surveys, the Commission

must consider a number of criteria, including commitments made by EDP, project layout, the

project contribution to cumulative sound levels, predicted cumulative sound levels and margin of

compliance, the degree of conservatism in the model, technical feasibility and concerns brought

forward by local residents in the study area.

75. The Commission is satisfied that the four receptors recommended by RWDI on behalf of

EDP (i.e., receptors R19, R28, R32 and R35) are appropriate monitoring locations for the

purpose of testing project noise compliance. The Commission notes that Mr. de Haan agreed

with the selection of these receptors for testing purposes.

76. The Commission agrees with the noise consultants for both EDP and the

Clearview Group that the intervener residences (i.e., receptors A, B, C, D and E) are not suitable

locations for a post-construction CSL survey because the predicted noise contribution from the

project at these receptors is too small to be measured effectively.

77. The Commission also finds that it is unnecessary to conduct a pre-construction ASL

survey, because it is appropriate to establish ASLs and PSLs for all receptors in the project area

using Table 1 of Rule 012. A more detailed discussion of this topic is presented in the previous

subsections.

78. Based on the foregoing, the approval is subject to the following condition to verify and

confirm that the project, as amended complies with the requirements of Rule 012:

• EDP shall conduct a post-construction comprehensive sound level survey, including

an evaluation of low frequency noise, at receptors R19, R28, R32 and R35. The

post-construction comprehensive sound level survey must be conducted under

representative conditions and in accordance with Rule 012. EDP shall file all studies

and reports relating to the post-construction comprehensive noise survey with the

Commission within one year of connecting the power plant to the Alberta Interconnected

Electric System.



4 Other factors considered

79. EDP’s participant involvement program for the project amendments included the distribution

of information packages to all stakeholders within 2,000 metres of the project boundary. The

packages included information on the revised project layout, new turbine information, and updated

information on noise impacts, shadow flicker analysis and visual representations.

80. EDP provided Alberta Environment and Parks (AEP) with an environmental evaluation

addendum that described the proposed amendments. AEP confirmed that it had no new concerns

regarding wildlife or wildlife habitat disturbances and that the project’s risk rating from the

original wildlife referral report remained unchanged.

81. EDP requested a construction completion date of December 31, 2021, for the Sharp Hills

Wind Project.

5 Conclusion

82. The Commission has considered the applications having regard to the applicable

legislative and regulatory framework described earlier. For the reasons that follow, the

Commission finds that the project, as amended is in the public interest having regard to its social,

economic, environmental and other effects.

83. The Commission is satisfied that the incremental impacts arising as a result of the

proposed amendments to the Sharp Hills Wind Farm and Sedalia 363S Substation are minor in

nature and the technical, siting, emissions, environmental and noise aspects of the power plant

continue to meet the Commission’s Rule 007 and Rule 012 requirements. EDP’s participant

involvement program has provided stakeholders with the opportunity to understand the proposed

amendments, voice their concerns and have those concerns addressed where feasible. Having

regard to the purpose of consultation as described above, the Commission finds that EDP has met

the regulatory requirement described in Rule 007.

84. The Commission accepts that the environmental impact of the proposed amendments is

minor in nature. There is a reduction in the number of turbines required for the project and the

substation alterations do not require additional disturbance. The Commission accepts AEP’s

position that no new impacts to wildlife and wildlife habitat arise from the proposed amendments

and that the risk assessment as detailed in the wildlife referral report remains unchanged.

85. The Commission has revised the receptors that require post-construction CSLs in light of

the proposed amendments. Condition 23 of Approval 22665-D02-2018 has therefore been

replaced by the following condition:

• EDP shall conduct a post-construction comprehensive sound level survey, including

an evaluation of low frequency noise, at receptors R19, R28, R32 and R35. The

post-construction comprehensive sound level survey must be conducted under

representative conditions and in accordance with Rule 012: Noise Control. EDP shall file

all studies and reports relating to the post-construction comprehensive noise survey with

the Commission within one year of connecting the power plant to the Alberta

Interconnected Electric System.



86. The Commission has removed Condition 19 from the power plant approval because EDP

fulfilled this requirement when it submitted its radar monitoring study on February 13, 2019. On

April 3, 2019, the Commission confirmed compliance and that it was not directing EDP to

implement a radar monitoring program.77

87. As noted above, the Commission has released this decision concurrently with its decision

on EDP’s review and variance application, Decision 24819-D01-2019. In that decision, the

Commission varied Condition 20 of Approval 22665-D02-2019. The new condition is reflected

in the power plant approval set out in Appendix 1 of this decision.

6 Decision

88. Pursuant to sections 11 and 19 of the Hydro and Electric Energy Act, the Commission

approves applications 24401-A001 and 24819-A002 and grants EDP Renewables SH Project GP Ltd.

the approval set out in Appendix 1 – Power Plant Approval 24401-D02-2019 – December 20, 2019.

89. Pursuant to sections 14, 15 and 19 of the Hydro and Electric Energy Act, the Commission

approves Application 24401-A002 and grants EDP Renewables SH Project Ltd. the approval set

out in Appendix 2 – Substation Permit and Licence 24401-D03-2019 – December 20, 2019.

90. The appendices will be distributed separately.

Dated on December 20, 2019.


(original signed by)

Carolyn Hutniak

Panel Chair


Anne Michaud

Vice-Chair


Neil Jamieson

Commission Member

77 EDP Radar report and Commission’s confirmation of compliance was filed in Proceeding 22665.



Appendix A – Proceeding participants

Name of organization (abbreviation) Company name of counsel or representative

EDP Renewables Canada Ltd.

T.L. Oleniuk

Clearview Group

G. Fitch

Viola Olsen

Alberta Utilities Commission Commission panel Carolyn Hutniak, Panel Chair Anne Michaud, Vice-Chair Neil Jamieson, Commission Member Commission staff

R. Watson (Commission counsel) M. Anderson (Commission counsel) V. Choy K. Wen J. Yu



Appendix B – Oral hearing – registered appearances

Name of organization (abbreviation) Name of counsel or representative

Witnesses

EDP Renewables Canada Ltd.

T.L. Oleniuk N. Bakker

Kenneth Little Payam Ashtiani Teresa Drew

Clearview Group

G. Fitch

Henk de Haan

Documents

EDP Renewables SH Project GP Ltd. · EDP also adjusted the project to be developed in two phases. 4. EDP proposed to change the turbine model from a Vestas V136 turbine to an Enercon