Morris Ridge Solar Energy Center

Case No. 18-F-0440

1001.19 Exhibit 19

Noise and Vibration

EXHIBIT 19 Morris Ridge Solar Energy Center, LLC

Morris Ridge Solar Energy Center
 TABLE OF CONTENTS
EXHIBIT 19  Noise and vibration .......................................................................................................................... 3 
(a)  Sensitive Sound Receptor Map.................................................................................................................. 3 
(b)  Ambient Pre-Construction Baseline Noise Conditions ............................................................................... 3 
(c)  Future Noise Levels at Receptors during Facility Construction.................................................................. 4 
(d)  Estimated Sound Levels to be Produced by Operation of the Facility ....................................................... 6 
(e)  Future Noise Levels at Receptors During Facility Operation ..................................................................... 8 
(1)  Future Noise Levels During Operation ................................................................................................. 8 
(2)  Tonal Evaluation .................................................................................................................................. 8 
(3)  Amplitude Modulation ........................................................................................................................... 8 
(4)  Low Frequency or Infrasound............................................................................................................... 9 
(f)  Predicted Sound Levels Table ................................................................................................................... 9 
(g)  Applicable Noise Standards ..................................................................................................................... 10 
(h)  Noise Standards Comparison .................................................................................................................. 11 
(i)  Noise Abatement Measures for Facility Construction .............................................................................. 12 
(j)  Noise Abatement Measures for Facility Design ....................................................................................... 13 
(k)  Community Noise Impacts ....................................................................................................................... 13 
(5)  Potential for Hearing Damage ............................................................................................................ 13 
(6)  Potential for Speech Interferences ..................................................................................................... 14 
(7)  Potential for Annoyance/Complaints .................................................................................................. 14 
(8)  Potential for Structural Damage ......................................................................................................... 15 
(9)  Potential for Interference Technological, Industrial, or Medical Activities that are Sensitive to Sound15 
(l)  Post-Construction Noise Evaluation Studies ............................................................................................ 15 
(m)  Operational Controls and Mitigation Measures to Address Reasonable Complaints ............................... 16 
(n)  Input Parameters, Assumptions, and Data Used for Modeling ................................................................ 17 
REFERENCES ........................................................................................................................................................ 18 

LIST OF TABLES
Table 19-1. Summary of L1h (dBA) Sound Modeling Results for Each Operating Scenario ....................................... 8 
Table 19-2. Modeled Sound Level Results .............................................................................................................. 10 
Table 19-3. Facility Design Goals and Regulatory Limits......................................................................................... 12 

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Morris Ridge Solar Energy Center
EXHIBIT 19 NOISE AND VIBRATION
Compared with most other types of power generation facilities, the potential for community sound impact from a
photovoltaic solar energy project is minimal. Potential sources of sound include the step-up transformers in the
collection substation, electrical inverters and transformers within the various solar panel fields, electrical arrays and
HVAC equipment and inverters associated with the possible energy storage facilities, and temporary construction-
related noise. There are no vibration issues associated with the operation of such a facility. Vibration during
construction is expected to be minimal and is discussed further in Exhibit 21.

This exhibit includes a detailed analysis of the potential sound impacts associated with the construction and operation
of the Facility. In order to assess the potential sound impacts, a Preconstruction Noise Impact Assessment (PNIA) for
the construction and operation of the Facility was prepared by RSG, under the direction of Mr. Kenneth Kaliski and Mr.
Eddie Duncan. Both are Board Certified through the Institute of Noise Control Engineering and RSG is a member of
the National Council of Acoustical Consultants. The PNIA is included as Appendix 19-A to the Application.

(a) Sensitive Sound Receptor Map

A map of the Sound Study Area showing the location of sensitive sound receptors and boundary lines (differentiating
participating, potentially participating and non-participating parcels) within 1,500 feet of the proposed Facility
components is provided in Figure 19-1. The figure also depicts all potential noise sources within the Sound Study Area,
including transformer(s), inverters, the substation, and the energy storage building. The sensitive sound receptors
include any residences, outdoor public facilities and areas, hospitals, schools, libraries, parks, camps, summer camps,
places of worship, cemeteries, and Federal and State Lands that were identified within 1,500 feet of the Facility.
Seasonal receptors include cabins and hunting camps, identified by property tax codes, and any other seasonal
residences with septic systems/running water. All residences are included as sensitive sound receptors, regardless of
participation in the project or occupancy (i.e., year-round and seasonal residences are included).

(b) Ambient Pre-Construction Baseline Noise Conditions

Ambient Sound Monitoring Locations

On behalf of the Applicant, RSG completed winter (leaf-off) and summer (leaf-on) background sound level monitoring
at six representative locations distributed throughout the Facility Site. The monitoring locations were selected to be as
representative as possible of the broader local soundscapes that exist in the immediate region. The various
representative areas included rural residential, low and high traffic roads, and remote areas. Table 3 of the PNIA
indicates the site characteristics of each monitoring location. Additional detail on each monitoring location is described
in Section 5 of the PNIA.

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Ambient Sound Level Monitoring
Background sound level monitoring was performed at these six locations during the winter of 2019 (March 13 to March
15) and the summer of 2019 (July 15 to July 18). Sound level data were collected using three Cesva SC310, one
Svantek 979, and two Larson Davis 831 sound level meters that continuously-logged 1/3-octave band sound levels
monitored once each second. Specific sound level meters used at each location, along with the specific metrics logged
by each sound level meter, are shown in Table 4 of the PNIA. The microphones were fixed to temporary posts at a
height of 1.2 meters (approximately 4 feet) above local grade. Each instrument was field calibrated before and after
monitoring periods, with either a Cesva CB-5, Larson Davis CAL200, or Brüel Kjær 4231 calibrator. Additional detail is
provided in Section 4.2 of the PNIA.

Statistical sound level data were averaged into 10-minute increments and summarized over the monitoring period.
Statistical levels were calculated from the one-second equivalent continuous sound levels (Leq). The 1/3 octave band
spectra were also recorded at each location to document any pre-existing tonal sounds. Biogenic sounds, including
insects, amphibians, and birds were excluded through the application of the “ANS” frequency-weighting network. If
tones above 1.25 kilohertz (kHz) were detected, then the A-weighted sound level was recalculated by summing 1/3
octave bands from 20 Hz to 1.25 kHz, effectively removing the high-frequency portion of the sound. Additional detail
on the background sound level monitoring methodology and data analysis is provided in Section 4 of the PNIA.

Baseline Sound Monitoring Results

The sound levels for the winter and summer monitoring periods for all six sites are summarized in Tables 10 through
12 of the PNIA. During both seasons, the nighttime Leq levels are less than the daytime levels, which is typical and
indicates a diurnal pattern. Equivalent continuous sound levels, Leq, are the energy-average level over 10 minutes. The
10th percentile sound levels (L90) are the statistical value above which 90% of the sound levels occurred during 10
minute intervals. The difference between the overall Leq and overall L90 for each site ranged from 11 dB (in winter) to
27 dB (in summer). A difference between the Leq and L90 indicates that the soundscape is likely to include transient or
intermittent sounds, such as aircraft overflights or passing automobiles and farm equipment. Graphical timelines for
the A-weighted Leq and L90 broadband noise levels for both summer and winter monitoring at each monitoring location
are found in Section 5 of the PNIA.

(c) Future Noise Levels at Receptors during Facility Construction

In contrast to other forms of power generation, the duration of the construction phase for a PV solar facility is short and
the activities that generate significant noise are few. Where a fossil fuel or wind generating project would require the
pouring of massive concrete foundations and the delivery and assembly of very large components, construction of a

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solar facility largely involves the installation of mounting posts for the PV panel racking, manual installation of the
individual panels, some grading and earthwork, erection of the collection substation and energy storage facility, and
collection line trenching. The duration of the construction phase for the Facility is anticipated to require approximately
18 months, although the activities that generate any significant sound are few and will not extend the full phase of
construction. Construction of the Facility is proposed to take place from 7:00 AM to 7:00 PM Monday through Friday,
and 8:00 AM to 8:00 PM Saturday and Sunday.

Noise resulting from construction was modeled with ISO 9613-2, Acoustics – Attenuation of Sound During Propagation
Outdoors, Part 2: General Method of Calculation (ISO 9613-2) 3-D sound propagation standard as implemented in the
Cadna/A software package. Sound source information was obtained from the Federal Highway Administration’s
(FHWA) Roadway Construction Noise Model and manufacturer data. For construction noise modeling, construction
activities were categorized into six groups: road construction, substation and energy storage construction, trenching,
array inverter construction, piling, and racking. The closest receptors were identified and the worst-case areas around
the Facility Site were modeled assuming the maximum sound emissions of all associated construction equipment
operating simultaneously. The results of the construction noise modeling are summarized below and are provided in
additional detail in Section 6.7 of Appendix 19-A.

 Facility road construction would take place within and adjacent to the solar arrays. The primary noise sources
associated with this activity are excavators, dozers, graders, dump trucks, and rollers. The cumulative
maximum modeled sound results of all primary road construction sources operating simultaneously near the
closest receptor (Receptor ID 168) is 74 dBA. See Figure 75 and Table 20 of the PNIA.

 The primary sources of noise associated with the construction of the substation and energy storage facility
are excavators, dozers, graders, dump trucks, rollers, concrete mixing trucks, concrete pumper trucks, flatbed
trucks, man-lifts, and large and small cranes. The cumulative maximum modeled sound results of all primary
substation and energy storage construction sources operating simultaneously near the closest receptor
(Receptor ID 237) is 64 dBA. See Figure 76 and Table 21 of the PNIA.

 Trenching would take place along the underground collection line routes throughout the Facility Site. The
primary noise sources associated with this activity are excavators, dozers, rollers, compactors, flatbed trucks,
forklifts, and trenchers. The cumulative maximum modeled sound results of all primary trenching sources
operating simultaneously near the closest receptor (Receptor ID 575) is 80 dBA. See Figure 77 and Table 22
of the PNIA.

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  Array inverter construction would take place around each inverter pad location throughout the solar arrays.
The primary noise sources associated with this activity are excavators, dozers, graders, rollers, dump trucks,
concrete mixing trucks, and concrete pumping trucks. The cumulative maximum modeled sound results of all
primary inverter construction sources operating simultaneously near the closest receptor (Receptor ID 540)
is 67 dBA. See Figure 78 and Table 23 of the PNIA.

 Piling would take place throughout the solar arrays. The primary noise sources associated with this activity
are flatbed trucks, boom trucks, and pile drivers. The cumulative maximum modeled sound results of all
primary piling sources operating simultaneously near the closest receptor (Receptor ID 610) is 73 dBA. See
Figure 79 and Table 24 of the PNIA.

 Racking would take place throughout the solar arrays. The primary noise sources associated with this activity
are flatbed trucks and forklifts. The cumulative maximum modeled sound results of all primary racking sources
operating simultaneously near the closest receptor (Receptor ID 610) is 72 dBA. See Figure 80 and Table 25
of the PNIA.

(d) Estimated Sound Levels to be Produced by Operation of the Facility

Modeling was performed in accordance with the standard ISO 9613-2, Acoustics – Attenuation of Sound During
Propagation Outdoors, Part 2: General Method of Calculation. This model takes into account source sound power
levels, surface reflection and absorption, atmospheric absorption, geometric divergence, meteorological conditions,
walls, barriers, berms, and terrain. The acoustical modeling software used here was CadnaA, from Datakustik GmbH.

The accuracy of ISO 9613-2 is ±3 dB for moderate downwind conditions within the range of 100 meters to 1,000 meters
for average propagation heights up to 30 meters. ISO 9613-2 does not report accuracy beyond 1,000 meters, but at
this range, sound levels from the Facility would be well below noise design goals.

Model input parameters are listed in Appendix C of the PNIA. The modeled equipment included 51 array inverters,
array transformers collocated with each array inverter, two substation transformers, 26 energy storage building
inverters, 53 energy storage building rooftop handling units, and 24 energy storage building exhaust fans. All equipment
was modeled at the manufacturer’s published maximum sound power levels. If only the overall A-weighted sound levels
were provided by the manufacturer, octave bands were estimated based on RSG measurements of similar equipment
or published spectra. Additional details on the equipment evaluated in the modeling, including sound power levels, are
provided in Section 6.1 of the PNIA.

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The Facility sound power levels were used to model the one-hour equivalent average sound level during the following
operating scenarios:
1) Dark with no energy storage
2) Dark with energy storage discharging
3) Dark with VAR support
4) Sunlight with no energy storage
5) Sunlight with energy storage charging
6) Sunlight with energy storage discharging

The noise sources operating under each scenario are shown in Table 15 of the PNIA. The highest sound levels [45
dBA at the nearest sensitive receptor] occur during “Sunlight with Energy Storage Discharging,” as all equipment would
be operating at the same time. Equipment operating under this scenario includes the array inverters, array
transformers, substation transformer without fans, and the energy storage exhaust fans, rooftop air handling units, and
inverters. However, most of the hours are likely to be in the “Dark with No Energy Storage” scenario, which has the
fewest sound sources operating (only array transformers and substation transformer without fans).

Mitigated Short-Term Modeling Results

Mitigated short-term sound propagation modeling results for the five modeling scenarios described above are shown
in Figures 64 to 69 of the PNIA. Results of the modeling indicate that the sound levels are at or below 45 dBA L1h at all
receptors and the sound from the substation transformer is at or below 40 dBA L1h at the nearest home. The mitigated
results include the noise abatement measures associated with the energy storage facility described in Section 7 of the
PNIA and in Exhibit 19(j), below. The highest sound levels occur around the energy storage facility for all scenarios.
Figure 72 of the PNIA shows the results of the “Sunlight with Energy Storage Discharge” scenario, with a focus around
the energy storage facility. The highest sound level at a receptor is 45 dBA L1h and the highest sound level at a property
line is 47 dBA L1h. Figure 70 of the PNIA shows the sound levels for the “Dark with No Storage” scenario around the
energy storage facility, and represents a typical night. The highest sound level at a receptor is 34 dBA, which meets
the applicable design goal of 40 dBA. Table 19-1 below includes a summary of the L1h modeling results for each
operating scenario.

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Table 19-1. Summary of L1h (dBA) Sound Modeling Results for Each Operating Scenario
Sunlight,
Dark, Energy Sunlight,
Dark, No Dark, VAR Sunlight, No Energy
Storage Energy Storage
Storage Support Storage Storage
Discharge Discharging
Charging
Minimum 1 10 6 5 10 12
Maximum 34 45 37 35 45 45
Average 9 19 21 20 19 23

(e) Future Noise Levels at Receptors During Facility Operation

(1) Future Noise Levels During Operation

Future noise levels during operation of the proposed Facility have been calculated using the methodology
described above in 19(d) under the heading Sound Propagation Modeling – ISO 9613-2. Table 29 of the PNIA
provides the A-weighted sound power levels produced by Facility components and Tables 31 and 32 in Appendix
D of the PNIA provides the predicted low frequency octave band model results and A-weighted (dBA) sound
pressure levels at each of the receptors.

(2) Tonal Evaluation

The spectrum used for the array transformer is from a measurement performed by RSG for a similarly sized unit.
Inverter data are measurements provided by the manufacturer. Most of the equipment for the Facility has the
potential to be tonal. The tonal prominence of the array transformer and inverter are shown in Figure 63 of the
PNIA. The transformer meets the ANSI S12.9 Part 4 criteria for tonality. For the inverter, tonality occurs most at
high frequencies, which attenuate faster with distance. Therefore, this tonality may not actually be present in the
far field. The tonality analysis performed by RSG was based on the sound power of the source and not the sound
pressure level at the receptor. Tonality is generally reduced at the receiver due to masking from broadband
background sound noise. Section 6.2 of the PNIA provides additional data on predicted tonality of the Facility.

(3) Amplitude Modulation

None of the sound sources of the Facility are known to generate amplitude modulation. Transformer sound is
characterized by a constant hum and is not amplitude modulated. Inverter sound is typically a constant fan sound
or a hum, which are not amplitude modulated. Energy storage cooling systems are dominated by sound generated
by fans, which are operated at relatively constant, non-modulating speeds.

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 (4) Low Frequency or Infrasound

Low frequency sound propagation modeling indicated that the sound levels are less than or equal to ANSI S12.9
Part 4 Annex D and ANSI S12.2 Section 6 criteria in the 31.5 Hz and 63 Hz 1/1 octave bands. The results for the
worst-case receptor are detailed in Table 17 of the PNIA and results for each receptor are included in Table 31 of
the PNIA.

Solar projects, including energy storage, are not known for infrasound emissions. All rotational equipment has
relatively high rotational speeds with a relatively small diameter relative to the wavelengths of infrasound. As a
result, three is no known mechanism for infrasound generation. Therefore, infrasound was not modeled and is
forecast to be insignificant.

(f) Predicted Sound Levels Table

The A-weighted/dBA sound levels at the sensitive sound receptors identified in subsection (a), for the operating Facility
are provided in tabular form in the subsections below. To calculate the long-term average, simple conservative
assumptions were used. For each metric, these are:
 Annual L10 – this is assumed equal to the highest sound emissions from the Facility, which is the L1h during
Sunlight Discharge, when all equipment is operating at its maximum capacity.
 Annual L50 – This is the greater of the L1h of Sunlight No Storage and Sunlight Charging, calculated at each
receptor.
 Annual L90 – This is equivalent to the L1h of the Dark No Storage scenario
 Annual Leq – this is equivalent to the L50.

These scenarios assume the sun is always shining during the daylight hours and that the sunlight is always strong
enough to generate the maximum power of the Facility. It also assumes that every day would have four hours of energy
storage discharge, as well. These are conservative assumptions that could never happen. However, for the purposes
of this modeling exercise it represents a worse-than-worst case evaluation. Actual sound levels will be lower over the
course of the year.

The A-weighted/dBA sound levels at the sensitive sound receptors identified in subsection (a), for the operating Facility
are provided in Table 19-2 below. The table includes the following:
1) The daytime ambient noise level.
2) The summer nighttime ambient noise level.
3) The winter nighttime ambient noise level.

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 4) The worst-case future noise level during the daytime period.
5) The worst-case future noise level during the summer nighttime period.
6) The worst-case future noise level during the winter nighttime period.
7) The daytime ambient average noise level.
8) Typical Facility noise levels.
9) Typical Facility daytime noise level.

Table 19-2. Modeled Sound Level Results

Minimum Maximum Average
Daytime Ambient L90 26 33 29
Summer Night Ambient L90 21 23 22
Winter Night Ambient L90 25 39 30
Daytime Ambient L90 + Facility L10 27 45 31
Summer Night Ambient L90 + Facility L10 22 45 25
Winter Night Ambient L90 + Facility L10 25 45 30
Daytime Ambient Leq 44 55 49
Facility L50 11 45 22
Daytime Ambient Leq + Facility L50 44 55 49

(g) Applicable Noise Standards

Noise standards applicable to the Facility Site, as well as noise guidelines that are required, or recommended, by
various agencies, are described below. More information on these standards is included in Section 2 of the PNIA.
Compliance with these standards is discussed below and Table 19-3.

Local and State Regulations

The Town of Mount Morris regulates solar projects under its Solar Farm Law in Section 48-44.3 of the Zoning
Ordinance. However, there is no specified noise limit in the Solar Farm Law. There are also no State guidelines that
are specific to solar facilities.

World Health Organization Guidelines

The United Nation’s World Health Organization (WHO) has published “Guidelines for Community Noise” (1999) which
uses research on the health impacts of noise to develop sound level guidelines for communities. The WHO guidelines
suggest a daytime average over a 16 hour day (Leq(16)) of 55 dBA to protect against serious annoyance and 50 dBA
Leq(16) to protect against a moderate annoyance. During the nighttime, the WHO recommends a limit of 45 dBA averaged

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over eight nighttime hours measured outside the bedroom window (Leq(8h)) and an instantaneous maximum of 60 dBA
LFmax (fast response maximum).

In 2009, WHO Europe conducted an updated literature review and built upon WHO’s guidelines for nighttime noise in
Europe. They added an annual average nighttime guideline level to protect against adverse effects on sleep
disturbance. This guideline is 40 dBA Lnight, outside, measured outside the bedroom window. These noise guidelines were
applied to the Facility for sources that operate every hour of every night, which for the Facility would be limited to
transformers under oil natural air natural (ONAN) cooling. Additional detail on WHO standards is provided in Section
2.3 of the PNIA.

As described in the PNIA, and Table 19-3 below, the Facility is in compliance with all of these guidelines and no
receptors are predicted to experience sound levels over those suggested by the WHO.

Federal Standards and Guidelines

No federal noise standards apply to solar power production or energy storage on private land. However, many federal
agencies have adopted guidelines and standards that apply to other types of facilities. Table 1 of the PNIA provides a
summary of some of these standards. Many of the agency standards or guidelines refer to the U.S. Environmental
Protection Agency (USEPA) protective noise levels of 1974. To protect against hearing loss, the USEPA recommended
sound levels less than 70 dBA averaged over the year. To address outdoor activity interference and annoyance, the
USEPA recommended 55 dBA Ldn for outdoors in residential areas and other outdoor areas “in which quiet is a basis
for use.” As described in the PNIA, and Table 19-3 below, the Facility is in compliance with these USEPA guidelines,
and no receptors are modeled with sound levels over those suggested by the USEPA to protect against speech
intelligibility.

(h) Noise Standards Comparison

Noise standards applicable to the Facility, are provided below in Table 19-3. The Facility has been designed to meet
the World Health Organization (WHO) and WHO Europe guidelines. As indicated in Table 19-3, the Facility is in
compliance with all of the standards and guidelines applicable to the Facility.

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Table 19-3. Facility Design Goals and Regulatory Limits
Number (Percent) of
Standard Design Goal Maximum Sound Level
Receptors Exceeding Goal
WHO 1999 nighttime 45 dBA L8h 11:00 PM to 7:00
45 dBA 0 (0%)
guidelines AM
WHO 1999 daytime 50 dBA L16 7:00 AM to 11:00
45 dBA 0 (0%)
guidelines PM
WHO Europe 2009 40 dBA Lnight, outside for all
annual average nighttime transformers under ONAN 34 dBA 0 (0%)
guidelines cooling
U.S. EPA speech 55 dBA L1h within any non-
47 dBA 0 (0%)
interference participating property
Sound-induced vibrations 31.5 & 63 Hz octave bands
51 dBZ 0 (0%)
(ANSI S12.2-2008) less than 65 dBZ
ANSI S12.9 Part 5 tonal
Tonal Penalty 5 dB n/a n/a1
penalty
1 1/3 octave band spectra are not available for all equipment. However, the transformers, which are the sources most likely to be tonal at any

receptor, are more than 5 dB below all design goals.

(i) Noise Abatement Measures for Facility Construction

The Complaint Resolution Plan for the Facility, which is attached as Appendix 12-C, has been provided to address any
complaints received during construction and operation of the Facility, including complaints regarding sound levels. A
Noise Complaint Response Protocol, specific to Facility Operation is discussed in Exhibit 19(l) and Exhibit 19(m) below
and is included as Appendix G to the PNIA. The Applicant takes seriously any reasonable complaints that it receives
from members of the public. In accordance with the plan, complaints can be registered via phone, writing, or email.
The Applicant will contact the individual within two business days following receipt of the complaint. The Applicant will
also implement a comprehensive complaint response for all registered complaints, which will include community
engagement, gathering information, response to the complaint, a follow up after the response has been issued, and
further action if the complainant believes that the issue continues to exist.

Although impacts related to construction noise will be temporary, and are not anticipated to be significant, measures
employed to minimize and mitigate temporary construction noise may include:
 Utilizing construction equipment fitted with exhaust systems and mufflers that have the lowest associated
noise whenever those features are available,
 Maintaining equipment and surface irregularities on construction sites to prevent unnecessary noise,
 To the extent feasible, configuring the construction in a manner that keeps loud equipment and activities as
far as possible from noise-sensitive locations,

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  Using back-up alarms with a minimum increment above the background noise level to satisfy the performance
requirements of the current revisions of Standard Automotive Engineering and Occupational Safety and
Health Administration (OSHA) requirements,
 Developing a staging plan that establishes equipment and material staging areas away from sensitive
receptors when feasible, and
 Requiring contractors to use approved haul routes to minimize noise at residential and other sensitive noise
receptor sites.

(j) Noise Abatement Measures for Facility Design

Adverse noise impacts will be avoided or minimized through careful siting of Facility components, the use of
alternative designs, and alternative technologies. Noise abatement measures proposed for the Facility are
generally centered around the energy storage facility. The mitigation measures include the use of low-noise
condenser fans on the rooftop air handling units, acoustically absorptive barriers adjacent to the energy storage
building inverters, a 3.5-meter high parapet around the perimeter of the energy storage building roof, and exterior
absorption panels on the side of the energy storage building behind the inverters. Additional detail on mitigation
elements is included in Section 7 of the PNIA.

(k) Community Noise Impacts

(5) Potential for Hearing Damage

The Facility’s potential to result in hearing damage was evaluated against three guidelines established by the
OSHA and WHO. Comparison of sound propagation modeling to these guidelines shows that construction and
operation of the Facility will not result in potential for hearing damage. Each of these standards, and the Facility’s
compliance with them, is further described below.

OSHA protects against the effects of noise exposure in the workplace. Permissible noise exposure levels for an
8-hour day are 90 dBA. At sound levels above 85 dBA over an 8-hour workday, employers shall provide hearing
protection to employees. Sound pressure levels, as generated by Facility construction and operation at sensitive
sound receptors, will be under this threshold, so the Facility will be in compliance with OSHA standards. Therefore,
based on the OSHA standard, the Facility will not result in potential for hearing damage.

The WHO long-term guideline to protect against hearing impairment is 70 dBA Leq-24h over a lifetime exposure, and
120 and 140 dB peak sound levels for impulsive sounds (e.g., blasting) for children and adults, respectively. No
blasting will be required for the construction of the Facility, and construction noise levels at the closest receptors

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 were modeled well below the 120 and 140 dB thresholds. In addition, the operation of the Facility will not produce
noise levels over 70 dBA Leq-24h. Therefore, there is no potential for hearing impairment from construction or
operation of the Facility.

(6) Potential for Speech Interferences

The Facility’s potential to result in indoor and outdoor speech interference was assessed using the framework
provided in the WHO (1999) document Guidelines for Community Noise and in the USEPA (1974) document
Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare with an Adequate
Margin of Safety.

The 1974 USEPA document states that an outdoor level of 55 dBA (Ldn) allows 100% sentence intelligibility
indoors, and 99% sentence intelligibility at 1 meter outdoors. These are the maximum sound levels below which
there are no effects on public health and welfare due to interference with speech or other activity. This includes a
5 dBA margin of safety. Because all sensitive sound receptors were predicted to receive a maximum operational
sound level of 45 dBA, the Facility will not result in interference with indoor or outdoor speech, as defined by
USEPA guidelines.

The WHO recommends and indoor sound level of 35 dBA (Leq) to protect speech intelligibility. This is equivalent
to approximately 50 dBA Leq outdoors based on reduction of noise from outside to inside by approximately 15 dBA
with windows open, and 25 dBA with windows closed (USEPA, 1974). Because all sensitive sound receptors were
predicted to receive a maximum sound level of 45 dBA, the Facility will not result in interference with indoor or
outdoor speech, as defined by WHO and USEPA guidelines.

(7) Potential for Annoyance/Complaints

The potential for annoyance was determined using the Modified Composite Noise Rating (MCNR) method. The
end result of the MCNR is a letter grade from “A” to “I”, which provides as estimate of the community response to
the noise. Grades of “A,” “B,” and “C” indicate no community reaction, “D” indicates sporadic complaints, and “I”
indicates vigorous community action. Detailed information regarding the steps in the MCNR analysis are included
in Section 6.6 of the PNIA. For the L90 metric, all receptors except one are ranked as a “C” or better. The one
exception is CNR D at Receptor 243. For the median sound level (L50), most receptors are ranked “A” with one
receptor, Receptor 237, ranked “E.” 1% of receptors are ranked “D,” which predicts sporadic noise complaints and
the remaining receptors are ranked “C” or better (with the exception of one receptor that is ranked “E”). The median
scenario represents the highest sound levels because it assumes daytime charging, which is among the highest
sound levels from the facility, along with the median background sound level. Under the annual average scenario,

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 most receptors are ranked “A”, with the highest receptor, Receptor 237, ranked “C.” Table 19 of the PNIA provides
the results of the MCNR for the L90, L50, and overall Leq.

(8) Potential for Structural Damage

As previously indicated, at this time, blasting activities are not anticipated during construction of the Facility. It is
also not anticipated that any other construction activities (such as excavation, horizontal directional drilling [HDD],
or rock hammering) will produce any cracks, settlements, or structural damage to existing proximal buildings or
infrastructure, including any residences or historic buildings.

(9) Potential for Interference Technological, Industrial, or Medical Activities that are Sensitive to Sound

Operation of the Facility will not create any adverse ground-borne vibration. Any vibrations from Facility
construction will be temporary in nature and are not anticipated to impact any nearby technological, industrial, or
medical activities. In addition, solar projects, including energy storage, are not known to produce infrasound
emissions. All rotational equipment has relatively high rotational speeds with a relatively small diameter relative to
the wavelengths of infrasound. As a result, there is no known mechanism for infrasound generation and infrasound
is forecast to be insignificant for the Facility.

(l) Post-Construction Noise Evaluation Studies

The Applicant has included a Noise Complaint Resolution Protocol (Appendix G to the PNIA). The protocol
includes procedures to initially respond to noise complaints, criteria required to trigger sound monitoring, sound
monitoring procedures to determine violations of noise level Certificate standards, potential resolutions to
violations of Certificate noise standards, and reporting requirements.

Sound complaints will be grouped into one of three categories:

1. Upset operations – non-repeatable or rarely implemented temporary activities,
2. Abnormal operations – noise due to maintenance issues that are repairable, or
3. Normal operations – noise of operations equipment, including solar arrays and energy storage.

Sound monitoring will be conducted for those complaints that meet all of the following conditions:
1. The sound complaint was determined to be a result of normal operations (and no maintenance issue is
found),
2. The complainant represents a sensitive receptor, as defined in Exhibit 19(a) above, located within 1 mile
of any transformer, inverter, or energy storage facility, and

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 3. Based on previous monitoring or pre-construction sound modeling, there appears to be a reasonable
possibility that the sound level induced by the Facility is greater than 40 dBA at the location of the
complaint (or 35 dBA is the sound is described as tonal).

If sound complaints are received from a single resident, monitoring will be conducted at that residence. If there are
concurrent noise complaints from several homes in the same area that are indicative of the same or similar noise
sources, monitoring will be conducted at the potentially worst-case location. The Applicant will inform any resident
when sound monitoring will be conducted and coordinate with the resident to determine an appropriate location
for the equipment. The Applicant will make all reasonable efforts to conduct sound monitoring under conditions
similar to those existing at the time the complaint arose. Monitoring procedures will generally follow ANSI S12.9
Part 4 to determine violation of a noise standard. Within six weeks of the conclusion of sound monitoring, the
Applicant will provide a report with the official results of monitoring to the complainant, the Siting Board and the
Town Clerk. If it is determined that the sound level at any non-participating permanent residence, attributable to
the Project, will result in a violation of the established sound limit, the Applicant will take steps to identify the issue
and evaluate practical measures to further minimize sound levels.

The Applicant will not, as a result of additional complaints, repeat sound monitoring in a representative area during
any five-year period following the first complaints response procedure for that area, unless there have been
changes in system operation or maintenance that can be reasonable assumed to have resulted in higher sound
levels. Additional details on sound monitoring procedures, data analysis, and reporting are included in the Noise
Complaint Response Protocol (Appendix G to the PNIA).

(m) Operational Controls and Mitigation Measures to Address Reasonable Complaints

The Applicant takes seriously any complaints that it receives from members of the public. The Complaint
Resolution Plan for the Facility, which is attached as Appendix 12-C, includes a complaint response protocol that
that the Applicant will follow during Facility construction and operation. Should a resident have a complaint about
noise levels generated during Facility construction or operation, the resident may issue a formal complaint.
Complaints can be registered by phone, mail, or email. The Applicant will implement a comprehensive response
for all registered, reasonable complaints, which will include community engagement, gathering information,
response to the complaint, a follow up after the response has been issued, and further action if the complainant
believes that the issue continues to exist.

Complaints related specifically to noise may require additional steps for resolution. The steps for noise-specific
complaints are described below and in additional detail in the Noise Complaint Response Protocol (Appendix G).

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 After any noise complaint, the Applicant will investigate whether the cause is due to upset operations, abnormal
operations, or normal operations.

If it is determined, based on the sound monitoring protocol described in Exhibit 19(l), that the Facility is resulting
in a sound level exceeding established sound limits at any non-participating permanent residence, the Applicant
will evaluate measures to minimize sound levels at specific receptors. Potential mitigation measures include:
 Construction of noise barriers to further attenuate the sound from propagating in a specific direction,
 Application of acoustically absorptive material if the complaint is due to reflections off a vertical surface
at the Facility,
 Changes to operational control of the equipment,
 Repair of equipment that is not properly functioning, or
 Equipment enclosures or acoustical louvers, if appropriate.

(n) Input Parameters, Assumptions, and Data Used for Modeling

Specific modeling parameters are included as Appendix C of the PNIA prepared by RSG. GIS files containing
modeled topography, noise source and sensitive sound receptor locations, and all external boundary lines
identified by Parcel ID number are being provided to DPS under separate cover in digital format.

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REFERENCES
International Organization for Standardization (ISO). 1989. ISO 9613-2 Acoustics – Attenuation of Sound During
Propagation Outdoors, Part 2, “A General Method of Calculations.” ISO 9613-2, Geneva, Switzerland, 1989.

United States Department of Transportation (USDOT), Federal Highway Administration. 2006. Roadway Construction
Noise Model User’s Guide. Table 1. January 2006.

United States Environmental Protection Agency (USEPA). 1974. Information on Levels of Environmental Noise
Requisite to Protect Public Health and Welfare with an Adequate Margin of Safety. 550/9-74-004, March 1974.

World Health Organization (WHO). 1999. Guidelines for Community Noise.

WHO. 2009. Night Noise Guidelines for Europe.

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