NREL is a national laboratory of the U.S. Department of Energy

Office of Energy Efficiency & Renewable Energy

Operated by the Alliance for Sustainable Energy, LLC.

This report is available at no cost from the National Renewable Energy

Laboratory (NREL) at www.nrel.gov/publications.

Contract No. DE-AC36-08GO28308

Fatal Flaw Analysis of 

Utility-Scale Wind Turbine 

Generators at the West 

Haymarket Joint Public Agency

A Study Prepared in Partnership with the 

Environmental Protection Agency for the 

RE-Powering America’s Land Initiative: 

Siting Renewable Energy on Potentially 

Contaminated Land and Mine Sites

Joseph Owen Roberts and Gail Mosey

Produced under direction of the U.S. Environmental Protection 

Agency (EPA) by the National Renewable Energy Laboratory (NREL) 

under Interagency Agreement IAG-08-0719 and Task No. 

WFD3.1001. 

Technical Report

NREL/TP-7A30-58768

August 2013
NREL is a national laboratory of the U.S. Department of Energy

Office of Energy Efficiency & Renewable Energy

Operated by the Alliance for Sustainable Energy, LLC.

This report is available at no cost from the National Renewable Energy

Laboratory (NREL) at www.nrel.gov/publications.

Contract No. DE-AC36-08GO28308

National Renewable Energy Laboratory

15013 Denver West Parkway

Golden, CO 80401

303-275-3000 • www.nrel.gov

Fatal Flaw Analysis of 

Utility-Scale Wind Turbine 

Generators at the West 

Haymarket Joint Public Agency 

A Study Prepared in Partnership with the 

Environmental Protection Agency for the 

RE-Powering America’s Land Initiative: 

Siting Renewable Energy on Potentially 

Contaminated Land and Mine Sites

Joseph Owen Roberts and Gail Mosey

Prepared under Task No. WFD3.1001

Technical Report

NREL/TP-7A30-58768

August 2013
NOTICE

This report was prepared as an account of work sponsored by an agency of the United States government. 

Neither the United States government nor any agency thereof, nor any of their employees, makes any warranty, 

express or implied, or assumes any legal liability or responsibility for the accuracy, completeness, or usefulness of 

any information, apparatus, product, or process disclosed, or represents that its use would not infringe privately 

owned rights. Reference herein to any specific commercial product, process, or service by trade name, 

trademark, manufacturer, or otherwise does not necessarily constitute or imply its endorsement, recommendation, 

or favoring by the United States government or any agency thereof. The views and opinions of authors

expressed herein do not necessarily state or reflect those of the United States government or any agency thereof.

This report is available at no cost from the National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Available electronically at http://www.osti.gov/bridge

Available for a processing fee to U.S. Department of Energy

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Cover Photos: (left to right) photo by Pat Corkery, NREL 16416, photo from SunEdison, NREL 17423, photo by Pat Corkery, NREL 

16560, photo by Dennis Schroeder, NREL 17613, photo by Dean Armstrong, NREL 17436, photo by Pat Corkery, NREL 17721.

 Printed on paper containing at least 50% wastepaper, including 10% post consumer waste. 
iii

This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Acknowledgments

The National Renewable Energy Laboratory (NREL) thanks the U.S. Environmental Protection 

Agency (EPA) for its interest in securing NREL’s technical expertise. In particular, NREL and 

the assessment team for this project are grateful to the West Haymarket Joint Public Agency

facility managers, engineers, and operators for their generous assistance and cooperation. 

Special thanks go to the West Haymarket Joint Public Agency; Brenda Mumper of the Federal 

Aviation Administration (FAA); Jessica Trice, Lura Matthews, and Shea Jones of EPA; and 

Katie Brown, AAAS Science and Technology Policy Fellow hosted by EPA. 
iv

This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Executive Summary

The U.S. Environmental Protection Agency (EPA), in accordance with the RE-Powering 

America’s Land initiative, selected the West Haymarket Joint Public Agency site in Lincoln, 

Nebraska, for a feasibility study of renewable energy production. The National Renewable 

Energy Laboratory (NREL) was contacted to provide technical assistance for this project. The 

purpose of this report is to assess the site for possible wind turbine electrical generator 

installation and estimate the cost, performance, and site impacts of different wind energy options. 

The West Haymarket Joint Public Agency site is approximately 400 acres with approximately 

32 acres appropriate for installation of a single utility-scale wind turbine. 

A fatal flaw analysis was done to quickly determine if the West Haymarket Joint Public Agency

site is worth investing significant development time and capital. Utility-scale wind turbines have 

many siting considerations, and many of these potential fatal flaws can be identified 

relatively quickly. 

The site must be able to have access for turbine components (new or existing) and an electrical 

interconnection (or access to one) suitable for the scale of the project. The site must have 

favorable local ordinances as well as national impact considerations (e.g., Department of 

Defense radar or flight paths).

The wind resource at the height of the technology selected must be sufficient for a financially 

viable project. The strength of the wind resource, while a fixed quantity for a given location, 

does not need to meet a minimum threshold due to other influencing variables, such as 

incentives, the value of the power generated, and the cost of the technology, construction, 

financing agreements, and operations and maintenance. 

The project must also have an energy user or offtaker with agreements to purchase the power 

generated. The ownership of the turbine must be defined, but there are many options 

for ownership. 

Special considerations for this site include local regulation prohibiting structures taller than 

150 feet above ground level and setback consideration for rail. Site-specific Federal Aviation 

Administration (FAA) constraints limit the height of a potential wind turbine to 267 feet above 

ground level at the potential turbine site. 

The feasibility of wind systems installed at this site is highly impacted by the available area for a 

project, wind resource, operating status, ground conditions and restrictions, distance to electrical 

infrastructure, and distance to major roads. The West Haymarket Joint Public Agency is suitable 

in area to have a single utility-scale wind turbine, and the wind resource in Lincoln 

is appropriate. 

Due to the local height restrictions, some small wind turbines can be installed with tip heights 

below the 150- or 275-foot above-ground-level ordinance limit; this, however, drastically 

reduces the economic viability of a wind turbine installation. As such, the site fails the fatal flaw 

analysis, and it is not recommended that utility-scale wind turbine installations be pursued 

further at this site.
v 

This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Table of Contents

1 Site Background .................................................................................................................................... 1

2 Benefits of Renewable Energy ............................................................................................................ 2

3 Wind Energy .......................................................................................................................................... 3

3.1 Wind Characteristics...................................................................................................................... 3

3.2 Wind Turbines............................................................................................................................... 5

4 Fatal Flaw Analysis............................................................................................................................... 8

4.1 Site Area Available for Turbines................................................................................................... 8

4.2 Wind Resource.............................................................................................................................10

4.3 Permitting and Setbacks...............................................................................................................10

5 Interconnection Considerations........................................................................................................16

5.1 West Haymarket Joint Public Agency Energy Usage..................................................................16

5.1.1 Net Metering and Offtake Options.................................................................................16

6 Conclusions and Recommendations................................................................................................18

Appendix A. FAA Aeronautical Study Findings .....................................................................................19

Appendix B. Screening Contaminated Lands, Landfills, and Mine Sites for Wind Energy 

Potential ...............................................................................................................................................25
vi This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

List of Figures

Figure 1. U.S. wind resource map ................................................................................................................. 4

Figure 2. Nebraska 80-m annual average wind speed map ........................................................................... 5

Figure 3. Modern utility-scale wind turbines ................................................................................................ 6

Figure 4. Aerial image of potential turbine location ...................................................................................10

Figure 5. FAA potential impact areas..........................................................................................................11

Figure 6. Long-range radar impact potential...............................................................................................13

Figure 7. NEXRAD radar impact potential................................................................................................. 14

Figure 8. Military operation impact potential..............................................................................................15

List of Tables

Table B-1. Wind Resource, Acreage, and Infrastructure ............................................................................25

Table B-2. Potential Land Use Restrictions and Exclusions.......................................................................26

Table B-3. Considerations for Landfills and Potentially Contaminated Lands...........................................26

Table B-4. Site Owner and Policy Considerations......................................................................................27
1 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

1 Site Background

Under the RE-Powering America’s Land initiative, the Environmental Protection Agency 

(EPA) provided funding to the National Renewable Energy Laboratory (NREL) to 

support a feasibility study of wind renewable energy generation at the West Haymarket 

Joint Public Agency site in Lincoln, Nebraska. The purpose of this report is to assess the 

site for possible wind turbine electrical generator installation and estimate the cost, 

performance, and site impacts of different wind energy options. 

The site is approximately 400 acres with specific consideration of a 32-acre parcel and is 

located within the city limits of Lincoln. 

The site has been utilized as a rail yard and as a gas processing facility for over 

100 years. A specific 32-acre parcel was considered as it has a high likelihood of 

contamination due to possible previous operations on the site. This site has good access 

to roads, rail, and electrical infrastructure and multiple potential electrical offtakers. 
2 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

2 Benefits of Renewable Energy

The cost of renewable energy technologies is relatively high. However, there are many 

compelling reasons to consider moving toward renewable energy sources for power 

generation instead of fossil fuels, including: 

• Using fossil fuels to produce power might not be sustainable 

• Burning fossil fuels can have negative effects on human health and 

the environment 

• Extracting and transporting fossil fuels can lead to accidental spills, which can be 

devastating to the environment and communities 

• Foreign sources of fossil fuels can be a threat to national security and 

economic stability

• Fluctuating electric costs are associated with fossil-fuel-based power plants 

• Burning fossil fuels contributes to climate change 

• Generating energy without harmful emissions or waste products can be 

accomplished through renewable energy sources 

• Abundant renewable resources are available in Nebraska, particularly 

wind energy. 
3 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

3 Wind Energy

Uneven heating of the earth’s surface creates motion of the atmosphere and thus kinetic 

energy in this movement. Variation in heating and factors, such as surface orientation or 

slope, rate of reflectivity, absorptivity, and transmissivity, also affect the wind resource. 

In addition, the wind resource can be affected (accelerated, decelerated, or made 

turbulent) by factors such as terrain, bodies of water, buildings, and vegetative cover. 

Wind is air with kinetic energy that can be transformed into useful work via wind turbine 

blades and a generator. Overall, wind is a diffuse resource that can generate electricity 

cost effectively and competitively in regions with a good wind resource, high cost of 

electricity, or both.

3.1 Wind Characteristics

Winds vary with the season, time of day, and weather events. Analysis of wind data 

focuses on several critical aspects of the data—average annual wind speed, frequency 

distribution of the wind at various speeds, turbulence, vertical wind shear, and maximum 

gusts. These parameters allow for estimation of available energy in the wind and the 

suitability of turbine technology for the site. 

The wind speed at any given time determines the amount of power available in the wind. 

The power available in the wind is given by: 

P = (A ρV3

)/2

where

P = power of the wind [W] 

A = windswept area of the rotor (blades) [m2

] = πD2/4 = πr

2

 

ρ = density of the air [kg/m3

] 

V = velocity of the wind [m/s] 

As shown, wind power is proportional to velocity cubed (V3

). This matters because if 

wind velocity is doubled, wind power increases by a factor of eight (23 = 8). 

Consequently, a small difference (e.g., increase) in average speed causes significant 

differences (e.g., increases) in energy production. Examining ways to increase the wind 

velocity at a particular site should be considered. Normally, the easiest way to 

accomplish this is to increase the height of the tower. The wind industry has been moving 

toward higher towers, and the industry norm has increased from 30 m to 80 m over the 

last 15–20 years. 

The map of the national wind resource can be seen in Figure 1. Wind maps can give a 

visual approximation of the wind resource in an area but do not provide enough data for 

estimating annual electricity output at a particular site. On-site wind data collected for a 

period of 1–3 years is necessary to estimate wind turbine performance. This study used 
4 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

recently collected on-site wind data for its screening level production estimates 

and analysis.

Figure 1. U.S. wind resource map1

Figure 2 shows additional detail of the wind resource in the State of Nebraska.

 

1 “Wind Powering America.” U.S. Department of Energy. Accessed August 27, 2013: 

http://www.windpoweringamerica.gov/wind_maps.asp.
5 

This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Figure 2. Nebraska 80-m annual average wind speed map2

3.2 Wind Turbines

Wind turbines consist of rotating blades that convert the kinetic energy of the wind to 

electric power. They have a number of moving parts and require regularly scheduled and 

unscheduled maintenance. Manufacturer warranties cover the first 2–10 years. 

Professional wind turbine maintenance contractors are recommended after the warranty 

period. Figure 3 shows large wind turbines that are of the scale and general size that 

might be considered at the site. 

 

2 “Wind Powering America.” U.S. Department of Energy. Accessed August 27, 2013: 

http://www.windpoweringamerica.gov/wind_resource_maps.asp?stateab=ne
6 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Figure 3. Modern utility-scale wind turbines. Photo by Joseph Owen Roberts

Wind turbines, at less than wind-farm scale, are typically cost-effective where the 

average wind speed is high, where the competing energy costs are high, or a combination 

of both. Large wind farms of 100–500 MW have been driving the industry because of 

lower installed costs, largely due to economies of scale and improved low wind speed 

turbine technology, which result in an overall lower cost of energy. 

In the United States, about 58,000 MW of wind power have been installed.3 Turbines are 

available from as small as 250 W to as large as 5 MW. For the size of the wind plants 

considered here, large turbines in the range of 1,000 kW to 3,000 kW per turbine would 

be appropriate. 

Wind power became a commercial-scale industry more than 30 years ago. Over that time, 

wind power has moved from the fringes of the electric power sector to a mainstream 

resource responsible for 35% of U.S. new power capacity from 2007 through 2011; it is 

second in new capacity additions only to new natural gas power.4 In the best resource 

areas or localities with exceptionally high electricity costs, wind power can be costeffective even in the absence of direct financial incentives or subsidies. Recent 

 

3 Wiser, R.; Bollinger, M. 2011 Wind Technologies Market Report. Washington, D.C.: Department of 

Energy, 2011. http://www1.eere.energy.gov/wind/pdfs/2011_wind_technologies_market_report.pdf. 4 E. Williams, J Hensley, AWEA US Wind Industry Annual Market Report2012 2013
7 

This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

technological improvements5 are expected to significantly lower the life cycle cost of 

wind energy. Initial investment costs for wind power are relatively high compared to 

natural gas or other forms of generation6

; however, with zero fuel costs and relatively 

modest fixed annual operations expenditures, wind-generated electricity is often a 

favorable generation resource over the long term. Estimated costs for typical projects in 

the United States for commercial power purchase agreements range from $0.025/kWh 

to $0.12/kWh.7

 

5 Wiser, R.; Lantz, E.; Bolinger, M.; Hand, M. (February 2012). Recent Developments in the Levelized Cost 

of Energy from U.S. Wind Power Projects. http://eetd.lbl.gov/ea/ems/reports/wind-energy-costs-2-

2012.pdf. 6

 U.S. EIA. Updated Capital Cost Estimates for Utility Scale Electricity Generation Plants, April 2013. 

http://www.eia.gov/forecasts/capitalcost/pdf/updated_capcost.pdf. 7 Wiser, R.; Bollinger, M. 2011 Wind Technologies Market Report. Washington, D.C.: Department of 

Energy, 2011. http://www1.eere.energy.gov/wind/pdfs/2011_wind_technologies_market_report.pdf. 
8 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

4 Fatal Flaw Analysis

A fatal flaw analysis aims to minimize the investment in feasibility studies to quickly 

determine if a site is worth investing significant development time and capital. Utilityscale wind turbines have many siting considerations, and many of these potential fatal 

flaws can be identified relatively quickly. 

The site must be able to have access for turbine components (new or existing) and an 

electrical interconnection (or access to one) suitable for the scale of the project. The site 

must have favorable local ordinances as well as national impact considerations 

(e.g., Department of Defense radar or flight paths).

The wind resource at the height of the technology selected must be sufficient for a 

financially viable project. The strength of the wind resource, while a fixed quantity for a 

given location, does not need to meet a minimum threshold due to other influencing 

variables, such as incentives, the value of the power generated, and the cost of the 

technology, construction, financing agreements, and operations and maintenance.

The project must also have an energy user or offtaker with agreements to purchase the 

power generated. The ownership of the turbine must be defined, but there are many 

options for ownership. 

A fatal flaw analysis was performed for the West Haymarket Joint Public Agency site to 

determine the feasibility of installing a utility-scale wind turbine that resulted in the 

discovery of significant barriers to utility-scale turbines at the site.

4.1 Site Area Available for Turbines

The West Haymarket Joint Public Agency has over 400 acres of land potentially suitable 

for placement of wind turbines with a specific parcel of 32 acres having the highest 

likelihood of being suitable for a utility-scale wind turbine. Figure 4 shows the 

developable area for wind. Some of these areas will be excluded for setback and future 

development considerations. The site has sufficient setback for a 140+ meter tip height 

turbine depending on local siting ordinances. It is recommended that if a large utilityscale wind turbine is pursued that engaging the rail companies to understand their setback 

requirements be understood. The site is also within a potential flood zone, which would 

increase the cost of the foundation, as turbines constructed in flood plains must be able to 

maintain structural stability even if the foundation is under water. Typical cost additions 

for a utility-scale machine for a project of this size would amount to approximately an 

additional 10% of the foundation cost for a typical spreadfoot foundation and a 2-MW 

80-m hub height wind turbine.8

The site has good access to road and rail for the transportation of equipment and turbine 

components. It is assumed that there is an electrical interconnection suitable for the size 

of turbine (~2 MW) nearby, but specific investigation as to the location and size of such 

infrastructure should be identified. A typical three-phase line in this area of the city 

should have more than sufficient capacity for a 2-MW wind turbine, but other 

 

8 Internal NREL Balance of Station cost estimation tool.
9 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

considerations, such as power quality, electrical flicker, and technology selection, should 

be considered. 

Due to the site location and proximity to other industrial users, such as rail and 

commercial buildings, noise generated by the turbine should not be a likely issue. Visual 

impacts, such as shadow flicker from the movement of the turbine blades, should be 

studied and considered due to the proximity of sporting event venues and the adjacent 

highways and interstates. Figure 4 shows the proximity to local rail lines, the new sports 

stadium, and local roadways.
10 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Figure 4. Aerial image of potential turbine location

Image generated using Google Earth

4.2 Wind Resource

This study assumed utility-scale wind turbines of 80 m or greater hub heights. Modern 

turbine technology, as well as improvements in modeling wind resources, in North 

America has changed what wind resources are financially cost effective to develop for 

utility-scale wind energy.

The annual average wind speed at 80 m above ground level is estimated to be 6.67 m/s, 

but the local surface roughness from buildings could decrease this value in reality. This 

strength of wind resource is currently considered developable in some areas of the 

country, but local power prices in Nebraska could decrease the cost effectiveness of a 

project in this wind regime. It is also worth noting that this area of North America 

typically has a steep gradient of the change of wind speed versus height above the 

ground. This phenomenon is called wind shear, and areas such as this site with high wind 

shear exhibit higher wind speeds as the height above the ground increases. Thus, smaller 

turbines will experience significantly lower wind speeds than higher hub height machines 

at this specific site. This decreases the potential energy that could be produced from a 

smaller, lower hub height wind turbine. 

4.3 Permitting and Setbacks

One of the largest constraints to permitting large wind turbines is the requirement that the 

turbines do not cause interference with air traffic, weather radar, and military operations. 

The site is within a direct flight path, and the Federal Aviation Administration (FAA) was 
11 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

engaged to determine the overall height potential of a utility-scale turbine. Figure 5 

shows that the site is within a flight approach path. 

Figure 5. FAA potential impact areas9

The FAA determined that a maximum height of either 267 or 302 feet above ground level 

at the site might be possible.10

...lowering the turbine to 267 ft. AGL / 1419 ft. AMSL would eliminate 

all impacts and a favorable determination could be issued that would be 

effective upon issuance. 

If the turbine height were lowered to 308 ft. AGL / 1460 ft. AMSL with 

submission of a 2C accuracy code survey, it would eliminate all impacts to 

instrument procedures and other obstruction standards except 77.17(a)(2). 

A favorable determination could be issued for that height that would be 

subject to the petition process. It would become final 40 days after 

issuance if no petitions were submitted to FAA Headquarters. If any 

petitions were to be submitted, the determination would not become final 

until Headquarters issues a finding. 

Best regards, 

Brenda Mumper

Wind Turbine Specialist 

AR, KS, LA, MO, NE, OK, TX and Republic of Panama 

Federal Aviation Administration, Air Traffic Organization

Obstruction Evaluation Group, AJV-15 

 

9 Image generated using the FAA Notice Criteria Tool. Accessed May 22, 2013: 

https://oeaaa.faa.gov/oeaaa/external/gisTools/gisAction.jsp?action=showNoNoticeRequiredToolForm. 10 See Appendix A for more details from the FAA findings report. 
12 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Further investigation into these height restrictions with local stakeholders revealed that 

local ordinances specify a maximum height of potentially 150–275 feet above ground 

level.11 Consideration for local viewshed corridors might also preclude the installation of 

a tall wind turbine as the city is concerned with initial impressions of patrons.12 

The zoning regulations thus dictate that at the turbine location just within the outer 

approach zone restricts the height of structures to a maximum of 275 feet.13

Given the intent and proximity of the local ordinances, the likelihood of a utility-scale 

wind turbine being installed at this site is very low. Other technology scales, such as 

small wind turbines with tip heights of 150 feet or less, are applicable given the 

aforementioned constraints, but the potential energy output, quality of wind resource at 

lower heights, and inherent economies of scale of the technology drastically decrease the 

financial viability of a wind turbine installation at this site. As such, this site fails the fatal 

flaw analysis for a utility-scale turbine installation. 

Long-range radar can also be affected by the movement of the turbine blades and could 

cause interference for air traffic control if not mitigated. Figure 6 shows that there is 

minimal potential for long-range radar impacts. Many turbines have been installed in this 

potential impact zone, and mitigation measures can vary from ignoring the interference to 

upgrading the software of the radar to filter this interference. 

 

11 “Airport Zoning Regulations.” 27.59.040(b). Accessed July 3, 2013:

http://lincoln.ne.gov/city/attorn/lmc/ti27/ch2759.pdf. 12 LPlan 2040. “Placemaking.” Section 4.3. Accessed July 3, 2013: 

http://lincoln.ne.gov/city/plan/lplan2040/plan/document/Amended/place.pdf. 13 “Airport Zoning Regulations.” 27.59.040(b). Accessed July 3, 2013: 

http://lincoln.ne.gov/city/attorn/lmc/ti27/ch2759.pdf.
13 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Figure 6. Long-range radar impact potential14

Figure 7 shows that the site has a very low probability of interfering with local 

weather radar.

 

14 Image generated using the FAA DoD Preliminary Screening Tool. Accessed May 22, 2013: 

https://oeaaa.faa.gov/oeaaa/external/gisTools/gisAction.jsp?action=showLongRangeRadarToolForm.
14 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Figure 7. NEXRAD radar impact potential15

Figure 8 shows that there is a low probability of a wind turbine at the site interfering with 

military operations.

 

15 Image generated using the FAA Notice Criteria Tool. Accessed May 22, 2013: 

https://oeaaa.faa.gov/oeaaa/external/gisTools/gisAction.jsp?action=showNoNoticeRequiredToolForm.
15 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Figure 8. Military operation impact potential16

 

16 Image generated using FAA’s Obstruction Evaluation/Airport Airspace Analysis (OE/AAA). Accessed 

May 22, 2013: https://oeaaa.faa.gov/oeaaa/external/gisTools/gisAction.jsp.
16 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

5 Interconnection Considerations

5.1 West Haymarket Joint Public Agency Energy Usage

The West Haymarket Joint Public Agency site could have potential for on-site renewable 

energy offtakers for behind-the-metering opportunities; however, a specific net-metering 

agreement would need to be negotiated with the local electrical utility. 

5.1.1 Net Metering and Offtake Options

Net metering is an electricity policy for consumers who own renewable energy facilities. 

"Net," in this context, is used to mean "what remains after deductions"—in this case, the 

deduction of any energy outflows from metered energy inflows. Under net metering, a 

system owner receives retail credit for at least a portion of the electricity it generates. As

part of the Energy Policy Act of 2005,

17 under Sec. 1251, all public electric utilities are 

required upon request to make net metering available to their customers:

(11) NET METERING.—Each electric utility shall make available upon 

request net metering service to any electric consumer that the electric 

utility serves. For purposes of this paragraph, the term ‘net metering 

service’ means service to an electric consumer under which electric energy 

generated by that electric consumer from an eligible on-site generating 

facility and delivered to the local distribution facilities may be used to 

offset electric energy provided by the electric utility to the electric 

consumer during the applicable billing period. 

Net excess generation (NEG) is carried forward to a customer's next bill. Under prior 

law, any NEG remaining at the end of each 12-month period was granted to the 

customer's utility. In 2009, California Assembly Bill 920 (AB920)18 gave net-metering 

customers two additional options for the NEG remaining after a 12-month period. They 

can roll over any remaining NEG from month-to-month indefinitely or they can receive 

financial compensation from their utility for the remaining NEG. 

By January 1, 2011, the renewable energy certificates (RECs),

19 also known as green 

certificates, green tags, or tradable renewable certificates, became tradable commodities 

in the United States. They represent proof of electric energy generation from eligible 

renewable energy resources (renewable electricity). RECs that are associated with the 

electricity produced and are used on-site remain with the customer-generator. If, 

however, the customer chooses to receive financial compensation for the NEG remaining 

after a 12-month period, the utility will be granted the RECs associated with only that 

surplus they purchase. 

 

17 For a summary of this bill and its full text, see http://frwebgate.access.gpo.gov/cgi-in/getdoc.cgi?dbname

=109_cong_bills&docid=f:h6enr.txt.pdf. 18 “Assembly Bill No. 920.” Accessed July 3, 2013: http://www.leginfo.ca.gov/pub/09-

10/bill/asm/ab_0901-0950/ab_920_bill_20091011_chaptered.pdf. 19 For a description of RECs, see http://apps3.eere.energy.gov/greenpower/markets/

certificates.shtml. 
17 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Nebraska currently has a limit of 25 kW on net-metered systems,

20 and more recent laws 

passed to address wind development specifically considering decommissioning.21 The 

local utility, Lincoln Electric Systems, currently owns and operates a small wind farm of 

older 660-kW machines north of Lincoln. Lincoln Electric Systems, as well as some local 

developers, expressed interest in this project when the FAA request was filed. Lincoln 

Electric Systems had a request for proposals (RFP) out to developers to repower their 

small wind farm, and developers were interested in the economies of scale of being able 

to purchase an additional turbine for this site. As such, Lincoln Electric Systems might be 

more open to innovative electrical offtake options. 

 

20 DSIRE. “Nebraska. Net Metering.” Accessed July 3, 2013: 

http://www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=NE07R&re=0&ee=0. 21 DSIRE. “Nebraska. Solar and Wind Easements and Local Option Rights Laws.” Accessed July 3, 2013: 

http://www.dsireusa.org/incentives/incentive.cfm?Incentive_Code=NE01R&re=0&ee=0. 
18 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

6 Conclusions and Recommendations 

Using land that cannot be used for other purposes would minimize the environmental 

impact of a wind generation plant. The West Haymarket Joint Public Agency site has the 

following attributes, which greatly increase the viability of a potential wind project at 

the site: 

• Potentially developable wind resource 

• Low potential for nearby opposition 

• Adequate access to local electrical infrastructure

• Constructible site with flat terrain. 

Despite these attributes, the fatal flaw analysis results determined that the West 

Haymarket Joint Public Agency site is not suitable for a utility-scale wind turbine due 

mainly to local height restrictions and flight paths, which constrain the scale of the 

technology that is feasible at the site.

Other fatal flaw failure criteria, as well as further difficulties to deploying a utility-scale 

wind turbine at the site include: 

• Known FAA and local zoning interference 

• Known flood plain requiring buoyant foundation design

• Unknown rail setback requirements 

• Potential shadow flicker issues with sports complexes and interstates

• Lack of incentives for conventional net metering for a utility-scale turbine. 

Further investigation into specific local ordinance interactions are advised if a turbine of 

over 150 feet is pursued. Further development of ownership and investment options 

should be explored. 

The site fails the fatal flaw analysis due to the local and federal height restrictions, which 

constrain the scale of the technology that is feasible at the site. Smaller wind turbines 

could be installed but the combination of the lesser wind resource at these shorter hub 

heights combined with the economies of scale for wind turbines greatly increase the cost 

of energy generated by turbines less than 150 feet tall. 
19 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Appendix A. FAA Aeronautical Study Findings
Mail Processing Center Aeronautical Study No. 

Federal Aviation Administration 2012-WTE-1748-OE 

Southwest Regional Office 

Obstruction Evaluation Group 

2601 Meacham Boulevard 

Fort Worth, TX 76137 

Issued Date: 04/02/2012 

EPA 

Tim Rehder 

EPA Region 8 

1595 Wynkoop St 

Denver, CO 80202 

** PUBLIC NOTICE ** 

The Federal Aviation Administration is conducting an aeronautical study concerning the following: 

Structure: Wind Turbine Lincoln EPA Turbine 

Location: Lincoln, NE 

Latitude: 40-49-10.28N NAD 83 

Longitude: 96-42-55.24W 

Heights: 1152 feet site elevation (SE) 

417 feet above ground level (AGL) 

1569 feet above mean sea level (AMSL) 

The structure above exceeds obstruction standards. To determine its effect upon the safe and efficient use 

of navigable airspace by aircraft and on the operation of air navigation facilities, the FAA is conducting an 

aeronautical study under the provisions of 49 U.S.C., Section 44718 and, if applicable, Title 14 of the Code of 

Federal Regulations, part 77. 

** SEE REVERSE SIDE FOR ADDITIONAL INFORMATION ** 

In the study, consideration will be given to all facts relevant to the effect of the structure on existing and 

planned airspace use, air navigation facilities, airports, aircraft operations, procedures and minimum flight 

altitudes, and the air traffic control system. 

Interested persons are invited to participate in the aeronautical study by submitting comments to the above 

FAA address or through the electronic notification system. To be eligible for consideration, comments must 

be relevant to the effect the structure would have on aviation, must provide sufficient detail to permit a clear 

understanding, must contain the aeronautical study number printed in the upper right hand corner of this notice, 

and must be received on or before 05/09/2012. 

This notice may be reproduced and circulated by any interested person. Airport managers are encouraged to 

post this notice. 

If we can be of further assistance, please contact our office at (405) 954-5189. On any future correspondence 

concerning this matter, please refer to Aeronautical Study Number 2012-WTE-1748-OE. 

This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

20
Signature Control No: 160902484-161863720 ( CIR ) 

Brenda Mumper 

Specialist 

Attachment(s) 

Part 77 

Map(s) 

This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

21
Additional Information for ASN 2012-WTE-1748-OE 

Proposal: To construct a(n) Wind Turbine to a height of 417 feet above ground level, 1569 feet above mean 

sea level. 

Location: The structure will be located 2.74 nautical miles southeast of the Lincoln (LNK) Airport reference 

point. 

Part 77 Obstruction Standard(s) Exceeded: 

Section 77.17 (a) (2) by 150 feet - a height that exceeds 1419 feet above mean sea level within 2.74 nautical
 

miles of LNK.
 

Section 77.17 (a) (3) by 36 feet - a height that increases a minimum instrument flight altitude within a
 

terminal area (TERPS Criteria). The proposal would necessitate a Notice to Airmen (NOTAM) to add take-off
 

minimums: Runway 14, 400-3 or standard with a minimum climb of 220 ft. per NM to 1700 ft. AMSL. The
 

structure would also increase the circling minimum descent altitude (MDA) for all procedures, Category D to
 

1940 ft. MSL without a survey or to 1880 ft. MSL with a 2C accuracy code survey.
 

Section 77.17 (a) (5) a height that affects an Airport Surface by penetrating:
 

Section 77.19 (b) Conical Surface by 59 feet as applied to LNK.
 

Section 77.19 (d) Approach Surface by 92 feet as applied to LNK.
 

Preliminary FAA study indicates that the above mentioned structure would: 

have no effect on any existing or proposed arrival, departure, or en route visual flight rules (VFR) operations.
 

not exceed traffic pattern airspace
 

have no physical or electromagnetic effect on the operation of air navigation and communications facilities.
 

have no effect on any airspace and routes used by the military.
 

This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

22
Map for ASN 2012-WTE-1748-OE 

This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

23
Map for ASN 2012-WTE-1748-OE 

This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

24
25 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Appendix B. Screening Contaminated Lands, 

Landfills, and Mine Sites for Wind Energy 

Potential 

Through ongoing collaboration, EPA and NREL created a Site Screening Wind Decision 

Tree to guide state and local governments and other stakeholders through a process for 

screening sites for their suitability for future redevelopment with wind energy. The tool 

can be downloaded from the RE-Powering America’s Land Initiative Mapping & 

Screening Tools webpage.

22 

This decision tree can be used to screen individual sites for wind energy potential or for a 

community-scale evaluation of multiple sites. The process is also applicable for a range 

of sites, from single turbine installations to large wind farms. It is not intended to replace 

or substitute the need for a detailed site-specific assessment that would follow an initial 

screening based on the decision tree.

As a preliminary step, stakeholders can consider the screening criteria below to determine 

a site’s suitability for wind energy potential. These criteria are a subset of those included 

in the RE-Powering Wind Decision Tree, which contains additional information for each 

criterion, as well as links to resources and tools that support the screening process. 

Table B-1. Wind Resource, Acreage, and Infrastructure 

Consideration Screening Threshold

Resource: Wind Speed23 ≥ 5.5 m/s at 80-m

Usable/Available Acreage 1-2 turbines: ≥ 2 acres 

Large-scale: ≥ 40 acres

Utility-scale: ≥ 100 acres

Site Slope < 12 degrees (~20% grade)

Distance to Transmission Lines ≤ 1 mile

Distance to Graded Roads ≤ 1 mile

Distance to Nearest Residence or Commercial Building > 1,000 ft

Local Average Retail Price of Electricity > $0.08/kWh

 

22 EPA. “Mapping and Screening Tools.” Accessed June 26, 2013: 

http://www.epa.gov/renewableenergyland/rd_mapping_tool.htm. 23 DOE. “Wind Powering America.” Accessed June 26, 2013: 

http://www.windpoweringamerica.gov/wind_maps.asp. 
26 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Table B-2. Potential Land Use Restrictions and Exclusions

Consideration Screening Threshold

Within areas with land-use restrictions that preclude wind development No

Within dense urban area No

Distance to airport runways > 10,000 ft

Within restricted areas near radar installations No

Within or adjacent to water, wetlands, wild and scenic rivers, wilderness study 

areas, and critical habitat areas for endangered or threatened species

No

Within or adjacent to migratory paths for birds and bats No

Within designated areas of historical or cultural significance No

Table B-3. Considerations for Landfills and Potentially Contaminated Lands

Consideration Screening Threshold

Landfills

- Capped & closed (at least the portion being evaluated for wind); OR

- Capped & pre-remedy; closure plan can readily incorporate wind installation; 

OR

- Uncapped & pre-remedy; geotechnical and resource investigation for wind can 

help determine cap requirements

Yes

Wind turbine installation compatible with site’s long-term monitoring and 

maintenance plan, including leachate and gas collection systems, erosion 

control, and storm water management plans

Yes

Potentially or Formerly Contaminated Lands

• Assessment determines that levels of contamination do not pose 

unacceptable risk to human health and the environment; OR

• Historic uses not likely to have caused significant contamination requiring 

expensive cleanup; OR

• Cleanup costs to redevelop site to residential or commercial space are 

prohibitive but would not be for wind energy reuse AND site otherwise 

meets all other wind energy eligibility criteria.

Yes

Wind turbines will not compromise remediation underway or in place during wind 

turbine construction or operation 

Yes

Zoning or other institutional controls limit redevelopment for residential, 

commercial, or recreational uses AND allow for redevelopment for renewable 

energy

Yes
27 This report is available at no cost from the 

National Renewable Energy Laboratory (NREL) 

at www.nrel.gov/publications.

Table B-4. Site Owner and Policy Considerations

Consideration Screening Threshold

Site owner is interested in leasing site for wind energy development Yes

Site owner is: 

• A private entity and eligible one or more of government or utility-based 

incentives available for wind energy; OR

• A public entity and has authority to enter into long-term agreements for land 

lease and/or power purchasing

Yes

State and/or local utility has strong policy support for renewable energy 

development

Yes

If the site meets these criteria, stakeholders can consider evaluating the site using the 

complete RE-Powering Wind Decision Tree in order to more fully screen the site for 

wind energy development potential. 

For more information, go to the RE-Powering America’s Land Initiative website: 

www.epa.gov/renewableenergyland or email cleanenergy@epa.gov.