I was expecting something like this.
It didn't stand to reason that you could build essentially an identical wind project to the Freedom Ridge one and not have the same kinds of problems.
So, as she says, we need to learn from this. One take-home is that the GE 1.5 MW S and SE models make more noise than expected, and possibly even seem more noisier here in Maine than in other environments. Why?
Two words: Wind shear.
For months now I've been telling anyone who will listen that we have surprisingly high wind shears in Maine.
The wind shear exponent is the number used in the Power Law equation to estimate the power of wind the further off the ground you get.
A high wind shear means more powerful wind further up. A low wind shear means relatively constant winds as you climb up the atmosphere. The standard wind shear tables stop at 0.3, supposedly the highest normally encountered, but in Maine in summer (when there are leaves on the trees and thus more blockage to the ground-level wind) I have measured wind shears (using simultaneous anemometry) at 0.45 and higher. A project in Massachusetts on the coast measured wind shear from one particular direction in summer at 0.57. A project in an area of coniferous trees, such as the one on Vinalhaven, would have constant high wind shears all round the compass and the year. One in an area of deciduous trees, such as the one on Freedom, would have higher wind shears in summer than in winter.
A high wind shear means you can have winds above 12 mph up high, at say 80 meters, one standard height of a GE 1.5 tower (they also come in 65 meter versions), powerful enough to turn a turbine and make noise, and low winds or none at ground level.
Meaning there may be no ground level ambient noise to drown out a turbine.
In Texas, Iowa, Scotland and Samso, other places where turbines have been used, with relatively low wind shears, there will be ground level winds and ground level ambient noise that will drown out the turbines.
In Maine there may not be.
Does this mean we can't have either commercial or community owned wind power plants in Maine? Of course not.
It means we have to plan them more carefully for noise, use more inclusive models of finance, and expect to get some noise.
Using more inclusive models of finance, especially some community ownership, is key. Noise like this is much more of a problem for commercial operations than it is for community ones because there is no reward, or not much of one, for the community sacrifice. If the only community benefit is taxation at around $50,000 per turbine, give or take 50% depending on the mill level, that's not enough.
But a GE turbine in a high electricity cost area, such as Vinalhaven which pays up to 25¢/KWH, may yield power worth $750,000 a year to the community. From which a stream of income comes that is large enough to compensate the community for its sacrifice.
Vinalhaven has three turbines. A couple million dollars a year is a lot of income to a town that may have only a one million dollar/year budget.
Our anti-wind groups will cry foul, that the turbines are providing such large incomes and so "buying" votes. But I would say that this is a community decision, whether or not to have such turbines, and not up to anti-wind advocates unless they are local, in which case they get one vote, and one say, like everyone else.
But there is the noise to consider. Planning projects should be designed to minimize nuisance, but they can't be designed to prevent all nuisance. Should I be permitted to object to State Route 7, which goes right by my house making 50-60 decibels until quite late at night for many Jackson residents who live right on it? Or to the Great Farm Rifle club a couple hundred yards away where my neighbors may shoot machine guns for fun, on Sunday to boot, making 80-plus decibels in my dooryard?
Turbines are quieter than these other nuisances if planned properly.
Does this mean that blanket setbacks, such as the one-mile ones proposed for Dixmont or Jackson are required?
No. In fact, such setbacks are possibly capricious and violate planning standards for that reason. A performance standard is much better. A community or developer that has to meet a performance standard has the option of using a quieter or smaller turbine. The blanket setbacks apply to all turbines above a certain KW rated capacity, usually 100 KW.
If Fox Islands Wind had used Northwind 100s instead of GE 1.5s, I venture to guess that there would have been much less noise. A blanket setback affects smaller turbines as much as it does larger ones, and so is not properly tailored to the particular nuisance it seeks to control.
As I've mentioned here and to anyone who will listen, the Supreme Court standard for planning, since Lucas vs. South Carolina Coastal Commission, is that planning regulations can be used to avoid a public nuisance or "noxious use," even to the extent of a constitutional "taking" of some value from an owner's property. But the Lucas ruling also says that the regulation must promote some clear public interest, clearly identified "background principles of nuisance and property law that prohibit the uses" landowners intend.
This has been generally taken to mean that rational and even scientific systems be used to measure the nuisance and abatement, so that we can positively identify the nuisance, and that regulations be tailored to actually deliver nuisance abatement based on the science.
This, in a nutshell, is why I had to go to Vinalhaven last month to put up an anemometer next to a decibel meter, so the nuisance could be measured, to determine if it did or did not comply with the DEP's noise regulations.
A blanket setback that disallows the use of a quieter turbine to reduce noise from a proposed development does not meet the Lucas standard. The nuisance the blanket setback was intended to control was noise. But the noise can be controlled without the setback. Therefore the regulation has "taken" some value in the owner's property, the value of the right to put up a quieter turbine. It's just a matter of time before a landowner sues to regain this right.
There would have been much less power produced too, though, if Vinalhaven had used smaller turbines. While a GE 1.5 may produce five million KW a year, a Northwind 100 will only produce a couple hundred thousand.
I venture to think that the dust will settle on the Vinalhaven project more by the community buying out the neighbors who have noise than by the community giving up on a couple million dollars a year, widely distributed through cheaper power bills and even through buying out the houses of those most affected. Which houses will no doubt promptly be resold to other buyers who can live with the turbines.
But I guess we'll wait and see.
>>>>>>>
-----Original Message-----
From: XXXXXX
Subject: FW: Very sad news from Sally Wylie of Vinalhaven
Sent: Wednesday, December 09, 2009 5:50 PM
To: undisclosed recipients:
Subject: Very sad news from Sally Wylie of Vinalhaven
Hard lessons from the Fox Islands Wind Project
by Sally Wylie
North Haven and Vinalhaven Schools were let out for the ribbon cutting ceremony on November 17. Students passed out colorful pinwheels and excitement was in the air. Governor John Baldacci joined the crowd. First District Congresswoman Chellie Pingree flew in from Washington, D.C. to join her daughter Hannah Pingree, Speaker of the House, in order to celebrate the completion of the Fox Islands Wind Project. As one speaker said, this was the largest group of North Haven and Vinalhaven residents together, ever! The turbines were running, the community had pulled together, and with the support of the Fox Islands Electric Cooperative Inc., the Island Institute, and George Baker, CEO of Fox Islands Wind LLC (FIW), remarkably, the dream of community-based wind power on Vinalhaven was a reality!
Amongst the participants were many of us who are neighbors of the turbines. Although our group overwhelmingly supported the project, we now live with the daily presence of turbine noise, 24/7. As one of the Fox Islands Wind Neighbors (FIWN) recently noted, "We support the windmills, but not the noise." The noise is as constant as the wind, building in intensity according to wind speed and direction. It can be a low rumbling, whooshing, grinding background noise that one can just hear above the sound of the trees or it can build to an in-your-face noise, like jet engines roaring combined with a grinding and pulsating sound that echoes in your head, keeps you awake at night, and beats on your house like a drum.
As neighbors of the wind turbines, we find ourselves in the midst of an unexpected, unwanted life crisis. When GE flipped the switch and the turbines began to turn, island life as we knew it evaporated.
As I watched the first rotation of the giant blades from our deck, my sense of wonder was replaced by disbelief and utter shock as the turbine noise revved up and up, past the sound of our babbling brook, to levels unimagined. It was not supposed to be this way!
During informational meetings, on the Fox Islands Wind website, in private conversations, and with personal correspondence, we were all told that ambient noise from the surrounding area would cover the sound of the turbines. This was our expectation. The Fox Islands Wind August 31 cover letter to the state Department of Environmental Protection (DEP) explained, "When the turbines are generating higher sound levels, background noise will be higher as well, masking the sound of the turbines." On the Fox Islands Wind Web site FAQ we read, "The blades passing through the air can make a 'whooshing' sound and mechanical parts or unusual wind currents can produce a steady 'hum' or 'whine.'
However, ambient noise is usually louder than any noise produced by wind turbines and modern wind turbines are significantly quieter than older models." Our immediate experience was the reverse..
Since that moment of realization, we have been on a steep learning curve. Our days are filled with e-mail correspondence with neighbors and George Baker, of Fox Islands Wind, research on the noise pollution and health risks associated with turbine noise, research on the impact of low-frequency noise, research on technological solutions, research on the impact of turbine noise on domestic and wild animals, research on state sound regulations, conversations with the press, neighborhood meetings, meetings with the electric cooperative and FIW, a meeting with the DEP, multiple letters to our State Representative, Hannah Pingree, letters to Congresswoman Chellie Pingree, letters to the Vinalhaven Land Trust board members, e-mails to possible sound consultants, debates with neighbors as to how we will pay for a sound consultant, letters to the DEP where we are beginning to know everyone's name, and the list goes on.
We have been to the town office to copy tax maps and get the addresses of year-round and summer residents who live near the turbines. We have driven all over the island with sound meters, determining that the turbine sound can travel more than a mile in certain areas and noticing whose homes are impacted. We have spoken with people in town to spread the word. We have invited people to our homes to listen for themselves. We have learned and explained under which conditions the turbines are loudest and why. We have developed data sheets so we can keep daily noise observation records. We have worked to find the words and sounds to describe the noise, each perfecting our own imitation, some better than others. We have learned to count windmill rpm and discovered that above 15 rpm the noise is tough to take. We have read lengthy amendments and studied sound protocols. We have learned about state sound regulations and found that the 45 decibel limit that is designated as "quiet" in Maine, is truly a cruel joke. On our quiet cove, we now know that 45 decibels is loud.
We have studied spreadsheets, yearly wind speed records, and have worked to determine how much Fox Islands Wind can slow the turbines down and still cover the cost of the windmills. We are scrambling. We do not want to leave the homes we have built with our own hands, the gardens we have planted, the memories that are so much a part us, and the dreams we hold for the future. We are not looking for financial gain. We are desperate to gain back what has been taken from us.
From where we are sitting, it seems that the industry standard for turbine noise in rural areas is absolutely wrong! I cannot speak for all the Fox Islands Wind Neighbors on this, but my husband and I feel that, on a local level, well-meaning individuals made a critical miscalculation. Depending on wind speed, wind direction, etc., we estimate that households within a mile to a mile-and-a-half radius of the turbines are impacted by the sound. This is a very serious issue that affects many homeowners on Vinalhaven and could also, due to diminishing property values, affect the tax base of the town. In an island community, such as Vinalhaven, where people sincerely care about and support one another, we are in the position where economic gain in the form of reduced electrical rates/wind turbine debt could be pitted against community well-being. How willing will the Fox Islands Wind Cooperative and the community be to share the burden of this major miscalculation? Rather than bringing us together, the noise from the turbines has the potential to tear our community apart..
As I type, a computer is whirring away in our basement, sending wind speed data and noise level data to sound technicians in Boston. FIW is taking sound measurements, as required by the DEP, and it is our joint hope that they will be able to make adjustments to windmills in order to reduce the noise. Along with our neighbors, we are recording daily noise observations which sound specialists can use as a means to determine under which conditions the noise is most disturbing. We are eager participants in doing whatever we can to rectify the situation. We feel fortunate that Fox Islands Wind is controlled by the Fox Islands Electric Cooperative and that they are eager to work with us to find an answer.
However, it is very clear to us, that life as we know it on Vinalhaven has changed irrevocably. We understand that our best hope is to come to a reasonable compromise.
We are working with FIW to find a balance between the level of noise that is tolerable and the turbine speed necessary to produce electricity. This is a far cry from what we were told and what we expected. One has to wonder if wind turbine technology is truly ready to be implemented in rural areas. Community based wind power is a very good idea, a smart answer to our energy dilemma. The numbers actually work. It is just that our life-for us, and for our neighbors-does not. Ironically, for households within earshot of the turbines, the GE windmills fly in the face of island sustainability. Some islanders who lived close to the turbines were given the choice of either selling their homes or land to FIW at the assessed value or living with the turbine noise. Most chose to sell rather than live with the noise.
Others are trying to stay where they are with hopes that GE specialists and FIW sound specialists will find technological solutions. The Island Institute website states, "The Institute's perspective is fundamentally ecological. It understands that all life is intimately linked with its environment; that people are therefore an inextricable part of the ecosystem of the Gulf of Maine, that there is an interdependent web of existence more evident on islands than in other communities and landscapes." As is, there are some year-round families on Vinalhaven who feel their existence is being marginalized and the noise issue minimized.
Before any other island community takes the step towards wind power, come to Vinalhaven and see for yourselves the consequences of those actions. Come to our meetings. Come stand on our porches, listen to the nonstop roaring, thumping, whooshing, grinding sounds of the turbines, and compare it to the quiet you currently experience. Watch how our community struggles with this issue and see how we resolve it. Look at the compromises we make and decide if those trade-offs are worth it for you and your neighbors. For many islanders, a cohesive, caring community and good quality of life are of critical importance. Don't let the wind blow it away.
Sally Wylie lives on Vinalhaven and in Rockland. She is part of the group Fox Island Wind Neighbors.
http://www.workingwaterfront.com/online-exclusives/Opinion/13571/
8 comments:
Once the Turbines are up it is very difficult to "change" to handle the sound issue. People forget that these will be making sound EVERY DAY FOR REST OF THEIR EXISTENCE. You can handle a loud car that goes by blaring its Bass thumping along... but can you handle it EVERYDAY FOR THE REST OF YOUR LIFE?
I find it interesting that we consider $$$ compensation... as long as they get enough. Then why do we have super fund sites? If the surrounding community gets $$$ to compensate them for the toxic dump just next door... then according to this logic everything is ok. Ask Plymouth if this is ok....
The same groups fighting for "Wind and Alternative Energy" have
taken down dams
dismantled nuclear plants
refused to drill for oil
refused to tap into Natural Gas (our next door neighbors in Canada just found a HUGE source)
support ethanol (burns more oil to make it)
The same groups who want turbines in rural maine are NIMBY's...
Not In My Back Yard.
Yes you can have it in those places... but not in my area.
I find this comment confusing. It assumes that all environmentalists think the same things, which I do not think is a very careful approach. I wouldn't normally comment back, but evaluating energy and energy systems policy is my core business, and I can't let this slide, especially since the commentator is a teacher in our local public schools system.
First up, a question: What should college teachers and public school teachers be teaching about energy systems, renewable energy and energy efficiency?
I have an answer to this question that I worked out many years ago when I first started teaching about climate change and energy policy:
We should cover all the major formats of energy system and accompanying pros and cons in a balanced way, and teach students to carefully evaluate their options.
And what should we teach about the controversy energy problems often cause?
We shouldn't demonize any particular group in society, such as "environmentalists," "big oil companies" or "anti-wind activists." But that doesn't mean to say we can't talk about individual or group points of view when we can work out fairly what they are.
Students need to understand different points of view. We would try to characterize the opinions of individuals and groups fairly. I generally use the individual or group's own statements and Socratic questions for this, posting a statement such as Mr. Kelley's comment here and asking "now what is he saying?"
It is true that environmental groups in Maine have advocated dam removal and the dismantling of Maine Yankee, and then gone on to advocate for wind power. I think Mr. Kelley is referring primarily to the Natural Resource Council of Maine. You'd have to be conversant with Maine environmental politics to understand this, though. I may be wrong here too, since the statement is confusing or confused on this. He may also be referring to environmentalists en masse.
I'm not a member of NRCM, although I do work with them on occasion, as I do with a lot of different groups in the state. I don't feel the need to defend them and in fact they can quite well defend themselves, but I do think that in several of these cases Mr. Kelley uses, what the NRCM advocated was reasonable, although I could see why some folks would be confused. Read the next comment to see why.
Let's just take the examples and work down them:
I quite like hydro power because it's clean and has a nice ability to meet peak and off-peak load as needed. I think we could use more in Maine, but not necessarily by keeping the most outdated run-of-river schemes on major anadromous fish rivers. Dams such as the Fort Edwards dam, recently removed, didn't produce a lot of power, and blocked fish passage to important tributaries. Surely we can distinguish between advocating for removing a few such dams and support for other schemes and for hydropower in general?
I also teach about nuclear power in class. It's a good source for base load power, if we figure out what to do with the waste and if we have safe plants. I am not sure that Maine Yankee was the best approach, being not dissimilar in operation to the Chernobyl and Three Mile Island plants, using mechanical insertion of control rods to slow the reactor down. This is an inherently unsafe approach. It's also outdated. I'd be willing to see a Hyperion or other fourth generation reactor in my region, even close to my house. I'm not sure what the NRCM position is on fourth generation or Hyperion systems.
I don't think that using more oil is going to help us much with climate change, or energy independence for that matter. Oils seems to cause a lot of trouble around the world. Using oil more efficiently is important, however, and along with other conservation methods, is the cheapest way to reduce emissions. I advocate for better home insulation, and do quite a bit of insulation work myself. Unity College runs a weatherization scheme in which students help fix up houses for folks, especially old folks in the area.
Natural gas can reduce climate emissions, if it is used to substitute for oil and coal in power production and transportation. Again, I didn't take sides in the LNG issue -- not my role. But I'd be willing to see (another) pipeline come through my backyard. (There is one already, just down the road.)
I support research into cellullosic ethanol using Maine forest products. This has to be combined with an understanding of forestry sustainability and proper scale and community control, or we'll have another "The Paper Plantation" situation.
I do want to have a wind turbine in my backyard, preferably quite a large one since the idea of dumping its power into my heating system on days like today seems pretty cool to me. I'd like to buy a secondhand Vestas V15 or Nordtank 65 and put it up behind my house. I can't afford this right now, but one day I will be able to.
But this will likely soon be illegal in Jackson, Maine.
Lastly, I don't think we should equate noise nuisance with pollution, especially toxic pollution. Neither should we throw away the the principle of compensation in environmental law. In college classes we generally teach that tort and nuisance law is one approach to regulating environmental problems. But we also teach the use of trading systems such as acid rain pollution trading, and command-and-control systems such as Superfund.
By the way, Superfund is not entirely a command and control system. One requirement is that companies are liable for the costs of the toxic pollution they cause: they have "joint and several liability," and can be forced to pay for clean up and to compensate victims.
As a college level teacher, I'm also required to do research and public service work in addition to teaching, which is why I also run a Community Wind Assessment program, and why I sometimes post wind-power related comments on my web site. I'm an advocate for community-ownership of wind power resources in Maine, and also an advocate for the careful planning of wind power developments.
If Mr. Kelley wanted to know more about what I think of such things he could find out fairly easily, by reading more of my websites or my other publications. In particular, I think you will find that I'm a consistent advocate of rationality and science and grown-up levels of thinking and decision-making in energy policy.
OF COURSE THAT'S NO SUBSTITUTE FOR SOUNDING OFF IN LARGE CAPITAL LETTERS!
I guess passion for an issue... makes me not qualified? to make a comment? or I am scary because I am just local teacher one of the unwashed masses who can't possibly be smart enough to know what the colleges do?
This statement would be unfair... and I assume you did not mean this.
I was not making the point that different areas of energy resources should not be explored. Actually I was pointing out ALL (oops... I am yelling again)
everything... should be explored.
Not just one source over the other.
As I would listen to your expertise let me give you some insight into mine.
You asked "First up, a question: What should college teachers and public school teachers be teaching about energy systems, renewable energy and energy efficiency?"
The information being pushed in the public school area... just check out different events and competitions (Wind Turbine for example) is NOT evenly distributed.
It trends towards the "positive" for example, Angus King is going to meeting praising the virtues of wind power (never mind the amount of money he individual gain for every wind turbine places)
Do you believe that there is equal effort to expose kids to different points of view to energy sources?
If big Oil ran a program having kids try to build the best drilling rig it would be accepted?
Again I don't care if any of the other energy sources are explored, but find it incredulous that you would believe there is not a bias out there on this issue.
Lastly... your opinion and mine for that matter is irrelevant when it comes to some one having to live directly with the "new" energy format. If the turbine is not in my back yard were I hear and have to see it I may get only the benefits, but none of the consequences.
We may say "the technology" will get better.. and less noise.. and it won't hurt your lifestyle, but unless we are living under the wind turbine on the island our point of view does not matter to that individual.
I know there are times for the greater good we have to take on for the team. My problem when the great good is for people to "feel" good about themselves not for any real tangible gain.
Lets dam up every river for power... was not a good thing.. just as lets put wind power up every where isn't.
but that is my humble opinion
I guess passion for an issue... makes me not qualified? to make a comment? or I am scary because I am just local teacher one of the unwashed masses who can't possibly be smart enough to know what the colleges do?
This statement would be unfair... and I assume you did not mean this.
I was not making the point that different areas of energy resources should not be explored. Actually I was pointing out ALL (oops... I am yelling again)
everything... should be explored.
Not just one source over the other.
As I would listen to your expertise let me give you some insight into mine.
You asked "First up, a question: What should college teachers and public school teachers be teaching about energy systems, renewable energy and energy efficiency?"
The information being pushed in the public school area... just check out different events and competitions (Wind Turbine for example) is NOT evenly distributed.
It trends towards the "positive" for example, Angus King is going to meeting praising the virtues of wind power (never mind the amount of money he individual gain for every wind turbine places)
Do you believe that there is equal effort to expose kids to different points of view to energy sources?
If big Oil ran a program having kids try to build the best drilling rig it would be accepted?
Again I don't care if any of the other energy sources are explored, but find it incredulous that you would believe there is not a bias out there on this issue.
Lastly... your opinion and mine for that matter is irrelevant when it comes to some one having to live directly with the "new" energy format. If the turbine is not in my back yard were I hear and have to see it I may get only the benefits, but none of the consequences.
We may say "the technology" will get better.. and less noise.. and it won't hurt your lifestyle, but unless we are living under the wind turbine on the island our point of view does not matter to that individual.
I know there are times for the greater good we have to take on for the team. My problem when the great good is for people to "feel" good about themselves not for any real tangible gain.
Lets dam up every river for power... was not a good thing.. just as lets put wind power up every where isn't.
but that is my humble opinion
You're obviously neither stupid nor unwashed. And Unity College is hardly Colby, Bates or Bowdoin when it comes to snootiness. But you posted a rather comment on my blog that was perhaps not so well thought out and you got a more reasoned response that made you own look exactly what it was, and should take responsibility for that.
As for passion, can we get beyond that and try reason instead?
Passion I suppose is OK in poetry or English, but this is planning, physics, ecology and engineering and, I'm tired of some of what passes for "passion" in town meetings related to wind power, or energy in general. Part of my job is to help towns think about wind power, and often you can't get past the "passion" on both sides.
I prefer facts and reason to passion.
So for instance, even though the new Dixmont wind ordinance has essentially banned the turbines on Mount Harris, and even though it will be more or less impossible economically to connect a turbine at the west end of the Mount Harris ridge line to the power lines at the east without Dixmont involvement, folks in Jackson are still losing their hair and yelling at one another "passionately" over a wind power development that I have told them several times is a dead duck.
That's not "passion." That's nuts. And a waste of everyone's time.
Plain stupid, in fact.
They should calm down and stop yelling and hating one another. There isn't going to be a wind farm anyway.
I find that disappointing, especially since the ordinances have banned even the less noisy systems. But it is what it is. Led by fear and "passion," not reason.
As to the energy formats, the reason why some don't get equal airtime with NREL and DoE and private non-profit programs, is we now have a national policy to reduce climate emissions, and become more energy-independent, and oil is a contributor to emissions, as well as to energy dependence.
The policy includes a shift to electric vehicles, hence the large amount of effort and government money going into the Chevy Volt and lithium batteries.
Brave New World, perhaps, but it's worth understanding it as a coherent energy world view.
This is a cohesive policy, it has been well worked out by the DoE, especially key behind-the-scenes players like Pat Dehmer and Steve Fetter. I suggest you study some of Pats slide shows and speeches if you want to see what is actually proposed.
Oil use is part of the policy, but the intent is to reduce its use incrementally, and be ready with the replacement.
This is because the emerging consensus is that oil is a strategic dead end right now, in terms of both emissions and eventual scarcity. The "elephant in the room" fact is not "Peak Oil" but oil demand. Even if we could increase global production significantly above current levels, global demand is increasing faster, more than 2%/year prior to the recession, therefore oil will get more expensive whatever we do, therefore all these other, cheaper formats will get more desirable from an economic point of view.
Most sensible public energy thinkers have realized this.
Only a handful of die-hard oil-baron-funded Republicans are bucking this trend in Congress, and our own Republican senators are not part of this. See for instance, Senator Collins recent climate bill option, which I thought quite decent.
So, knowing that there is a policy, and knowing the weight of effort that is now going into emissions reductions, it isn't surprising that we see a barrage of information in the schools and colleges related to non-oil and non-coal options. Especially from DoE.
Of which wind is one example. But so are most of the others I've mentioned.
The first stage in any assessment of ground-level energy problems is of course conservation, though. I generally expect, when I go look at a building or campus, that I can find a 40% self-financing reduction in energy use just with better windows and doors, insulation, energy controls, changes in building scheduling, and the like.
Not taking advantage of that 40% is pretty silly, and will be even sillier as oil price rises.
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