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TOWN OF HOUNDSFIELD:
COUNTY OF JEFFERSON
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SPEAKERS:
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JACK A. NASCA
STEPHEN M. TOMASIK
RICK GREINER
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HELD AT:
TOWN OF HOUNDSFIELD
411 W. Washington Street
SACKETS HARBOR, New York 13685
MAY 18, 2009
7:00 p.m.
REPORTED BY:
DIANA M. YAUCHLER
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SPEAKERS:
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MR. NASCA:
I would
I'm Jack Nasca and I'm with the New York State
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Notice Bulletin.
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2009.
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Each of
session.
He is a project
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environmental permitting.
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He is a
Also, he will
That will be
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MR. TOMASIK:
What I'm
you.
If any one of
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record of it.
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for that.
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local agencies.
So any state or local agency that will
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So any
The SEQR
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SEQR process.
An
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of the EIS.
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draft scope.
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Between
prepared in September.
our website.
minute.
That is the
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DEC chose to
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them.
After the close of the comment period on
final product.
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The final
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comment period.
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What
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So,
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If
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address.
listed there.
All records,
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Mexico.
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But if you
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discharge.
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So,
I have
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done enough.
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MR. GREINER:
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It's also
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see.
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Let me
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MR. NASCA:
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answer.
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This will
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Thank you.
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MR. NASCA:
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reconsider?
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Okay.
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our presentations.
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sheet.
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transmission lines.
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those.
future.
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Thank you.
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C E R T I F I C A T I O N
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ability.
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_______________________________
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$
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according (1)
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approximately (6)
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Babcock (2)
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contact (2)
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course (1)
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data (2)
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date (1)
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details (1)
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determine (2)
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develop (1)
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discharge (1)
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discussion (1)
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dock (1)
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document (1)
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done (1)
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down (1)
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during (2)
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eight (1)
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EIS (10)
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electrical (1)
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employ (1)
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ENB (1)
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enough (1)
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entire (1)
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environmental (4)
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(1) $2 - equally
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farm (1)
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February (1)
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final (9)
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Following (1)
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formal (1)
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forward (1)
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frame (1)
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friends (1)
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home (1)
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interaction (1)
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involved (8)
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jurisdiction (1)
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Impact (1)
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indicated (1)
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informal (1)
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install (2)
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law (2)
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lead (1)
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manager (1)
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materials (1)
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May (7)
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meeting (6)
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Megawatt (1)
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mentioned (3)
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Mexico (2)
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middle (1)
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mile (1)
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more (2)
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moves (1)
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(2) equipment - one-on-one
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page (1)
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part (7)
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Power (3)
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read (1)
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top (1)
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town (5)
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transmission (8)
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upon (1)
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water (3)
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way (2)
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web (2)
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website (3)
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(3) operation - website
wetlands (1)
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windfarm (2)
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wish (1)
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word (1)
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workers (3)
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writing (2)
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written (4)
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APPEARANCES:
JACK A. NASCA
Chief Energy Projects and Management
New York State Department of Environmental
Conservation
Division of Environmental Permits
625 Broadway, 4th Floor
Albany, New York 12233-1750
(518) 402-9172
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STEPHEN M. TOMASIK
Division of Environmental Permits
New York State Department of Environmental
Conservation
625 Broadway, 4th Floor
Albany, New York 12233-1750
(518)486-9955
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RICK GREINER
Babcock & Brown
1600 Smith Street, Suite 4025
Houston, TX 77002
(713) 308-4233
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STEPHEN W. LITWHILER
Citizen Participation Specialist
New York State Department of Environmental
Conservation
Dulles State Office Bldg, 5th Floor
317 Washington Street
Watertown, New York 13601
(315) 785-2252
MR. NASCA:
I am Jack Nasca.
I am with the
Conservation.
stationed in Albany.
Environmental Permits.
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Project.
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A second notice
tonight.
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In other words,
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wind project.
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MR. TOMASIK:
Thanks.
What I am going
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way in.
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I am
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right now.
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as possible a time.
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DEC.
completed.
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Town of
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established.
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And
Bulletin.
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And
period.
discretionary action.
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Any of
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findings.
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need to make.
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10
If after the 10
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MR. TOMASIK:
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Any of
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11
well.
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libraries.
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documents.
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you.
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25
12
County.
today.
The
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And
However, if you do
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permit applications.
There is a particular
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application.
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to those permits.
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details.
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MR. GREINER:
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possible.
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housing.
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purposes.
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Also be an
So
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developed.
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long.
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About 50
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about.
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an annual basis.
And shall I take any questions or --
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MR. NASCA:
What we
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will go off the record now and open the floor for
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questions.
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We
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3
MR. NASCA:
statement.
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9
MR. LITWHILER:
Okay.
First
We are going to
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us.
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to talk about.
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We want to do this so
Just
And just
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their comments.
writing also.
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long.
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So I am probably not
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Doyle.
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spelling.
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MR. DOYLE:
Doyle.
Thank you.
My name is Shawn
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8
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I am
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area.
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underwater.
There
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township here.
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Sackets Harbor.
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13
14
Pulaski.
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PILOT agreements.
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the table.
25
And
21
power.
10
Some of the
Make sure to --
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13
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15
MR. LITWHILER:
16
MR. JOHNSON:
Thank you.
Mr. Johnson.
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I have to deliver
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22
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Point Penninsula.
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23
consideration.
4
5
MR. LITWHILER:
Thank you.
Thank you.
Next Mr.
Bowers.
MR. BOWERS:
Thank you.
I am Herb
10
11
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13
And I have
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22
pylon.
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the ships.
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And
25
of wind noise.
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these people.
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So the
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93,400 households.
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26
10
11
State.
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source.
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20
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23
24
25
They
27
wind.
10
11
The power of
So there
12
13
14
power.
15
there is none.
16
MR. LITWHILER:
Thank you.
Other cards?
17
18
19
20
MR. FRANZ:
Sure.
My name is Mitch
21
Franz.
Residence of Henderson.
When I spoke to
22
23
24
25
And I
28
10
11
area.
12
project.
13
That's my comment.
MR. LITWHILER:
Thank you.
Others?
14
15
16
17
hearing.
18
MR. NASCA:
You
I am seeing no
Okay.
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20
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22
project.
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25
29
And once
are here.
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30
2
3
4
City of Watertown
Jefferson County
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11
C E R T I F I C A T I O N
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hereof.
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_______________________________
23
LYNN M. LAPAN
Court Reporter
24
25
40 (1)
15:23
08 (2)
7:14;8:3
1
10 (4)
9:2,3;10:4;21:4
104 (1)
23:18
13 (1)
3:23
16 (1)
27:8
17 (1)
21:22
18 (3)
3:19;8:3;21:22
2
2 (1)
10:15
20 (1)
20:2
2008 (1)
21:22
2009 (5)
3:19,20,23,24;
28:25
21 (1)
7:15
22 (1)
20:2
25 (1)
26:11
252 (4)
16:8;26:4,7,12
27 (1)
8:9
29 (4)
8:11;10:17;13:14;
28:25
3
3 (3)
3:19,25;14:12
3.0 (1)
14:13
3.14 (2)
21:20;22:5
30 (2)
13:18;26:11
32 (1)
27:7
4
4 (2)
3:20,24
Min-U-Script
5 (2)
22:15,24
50 (2)
15:23;22:13
7
7 (3)
3:19;4:2;12:12
70 (2)
26:13,22
75 (2)
26:13,13
8
84 (2)
14:11;22:12
9
93,000 (1)
16:9
93,400 (1)
25:24
A
ability (1)
26:25
able (2)
5:22;21:7
above (3)
15:4,21;25:17
absorb (1)
24:11
accept (4)
3:13;8:15;10:16;
18:7
acceptance (1)
8:11
accepted (4)
3:17;7:22;8:8;
19:21
access (1)
11:18
accompany (1)
15:16
across (1)
20:4
Act (2)
6:8;13:6
action (6)
6:18;9:9;10:2,2,9;
13:2
actual (1)
13:23
actually (2)
15:9;24:9
addition (2)
13:13;24:24
additional (3)
13:18;18:15;20:2
address (4)
8:21;11:10,16;
17:18
addressed (1)
19:4
adequate (1)
8:9
adjourned (1)
29:16
admire (1)
20:7
adopted (1)
8:25
advance (1)
22:25
aerodynamic (1)
23:19
affair (1)
27:3
afternoon (5)
3:2;4:6;17:20,23;
29:4
again (7)
8:4;10:12;16:16;
19:8,16;20:16;29:4
against (2)
19:12,12
agencies (4)
7:8;9:14,14,17
agency (15)
6:13,16;7:13,15,
18;8:19;9:2,4,5,5,6,
21,25,25;13:3
agenda (1)
6:5
agreement (2)
20:23;21:3
agreements (2)
20:22,25
Albany (1)
3:7
allow (5)
4:18;5:3;14:22,25;
16:14
almost (1)
27:5
along (2)
11:9;12:10
always (2)
18:8;27:24
ambient (1)
22:24
among (2)
19:15;27:11
annoying (2)
25:5,20
annual (2)
16:3,10
answered (1)
4:21
anticipate (1)
15:25
appeared (2)
3:19,22
appears (1)
18:3
applicants (1)
8:7
application (4)
12:22;13:10,10,11
applications (2)
13:8,16
approval (1)
9:22
approve (1)
10:8
approved (1)
22:4
approving (1)
12:4
approximate (1)
14:11
approximately (2)
14:11;16:2
architect (1)
23:13
area (6)
14:2;19:20;20:9;
21:2;24:17;28:11
areas (1)
28:9
around (2)
15:2;28:6
Article (1)
12:12
associated (3)
6:19;13:17,19
atmosphere (1)
25:14
attended (1)
21:23
attenuate (2)
24:3,12
Aubertine (2)
21:18;23:2
authority (1)
9:6
available (3)
3:17;7:20;8:4
avoid (1)
14:15
away (3)
24:9,23;25:4
awful (1)
20:8
B
Babcock (1)
14:2
back (7)
5:18,24;7:14;8:3,
19;9:4;28:15
backup (2)
26:8,21
based (2)
7:25;10:9
basis (2)
10:6;16:10
bass (1)
28:10
battlefield (1)
19:7
beautiful (1)
19:6
become (1)
5:5
begin (1)
4:2
below (1)
23:22
benefit (2)
15:25;19:11
benefits (2)
16:6;19:14
best (1)
25:23
bills (1)
19:14
bit (6)
10:11;13:23;
16:14;18:13,14;25:2
blade (1)
23:21
blades (1)
23:20
Board (5)
21:22;22:3,12,17;
23:8
boat (1)
24:9
both (4)
4:4,16;8:18;15:4
Bowers (3)
23:5,6,7
bridge (3)
24:22,23;25:4
brief (3)
4:15,19;5:25
bring (1)
27:17
brought (1)
25:23
building (1)
7:22
buildings (2)
15:7,13
bullet (1)
6:15
Bulletin (3)
3:21,22;8:6
burying (1)
20:13
business (1)
(1) 08 - business
C
cable (3)
15:18,18;19:19
call (4)
10:14,25;17:4,5
called (6)
8:19;9:7,14,17;
13:5,9
can (27)
6:2,3,17;7:7,10,12;
9:17;10:8,17,25;
11:4,18;15:7,9;16:6,
18;17:11;20:16;24:9,
21,24;25:3,16,18;
26:5;27:8;28:24
capacity (1)
26:8
captains (1)
24:15
card (6)
11:4;16:17;17:24;
18:19,22;27:17
cards (2)
10:13;27:16
center (1)
19:23
Central (1)
16:5
certainly (1)
10:24
chance (1)
28:14
channel (1)
24:20
Chaumont (1)
23:7
chief (1)
3:5
choice (1)
9:10
clean (1)
26:20
clearly (1)
24:10
Clerk (1)
11:15
clock (1)
13:7
close (4)
4:18;16:13,20;
28:16
closed (1)
29:6
closest (1)
25:11
coal (2)
26:9,16
Coast (1)
Min-U-Script
27:25
collection (1)
15:3
coming (2)
3:3;29:4
comment (10)
8:14;10:15;13:12,
13,19;17:23;18:10;
25:22;27:18;28:12
comments (24)
3:14;5:4,7,25;7:22,
24,25;8:13,15,17,17,
22,23;10:17,18;11:8;
17:18,25;18:3,6,15;
28:20,23,25
Commission (1)
29:8
communication (1)
10:22
community (1)
27:23
companion (1)
11:23
comparable (1)
23:24
complete (4)
3:17;13:9,11,18
completed (1)
7:9
completion (1)
22:19
components (2)
12:4;25:6
concern (4)
19:8;21:25;22:5,9
concerned (3)
19:16;22:12;23:14
concerns (2)
19:3,5
concludes (1)
13:14
Concurrently (1)
11:22
conditions (1)
26:6
conduct (1)
22:18
conform (1)
22:23
Conservation (2)
3:5;6:21
considerable (2)
23:17;25:17
consideration (3)
6:12;12:15;23:2
Considering (1)
22:10
construct (2)
6:23;14:25
construction (3)
14:4,19,23
contact (1)
11:2
continue (1)
20:10
contrary (1)
22:9
conversation (2)
24:10,15
coordinate (1)
14:3
Copies (1)
11:13
Corporation (2)
11:17;21:4
cost (1)
21:8
councilman (1)
21:23
County (7)
12:2;16:4;18:25;
19:2;20:21,23;21:5
couple (2)
10:23;11:20
course (2)
8:13;10:10
cover (1)
6:2
create (2)
22:3,14
created (1)
23:20
cube (1)
27:4
cut (1)
18:12
D
date (1)
18:17
day (3)
9:2;13:18;29:13
days (3)
9:3,16;10:5
dBA (2)
22:13,24
deadline (1)
8:12
deal (1)
19:4
Dear (1)
21:21
debate (1)
27:11
DEC (11)
7:4,14;8:8,10,25;
9:3;11:16;12:24;
22:23;25:25;29:6
decibels (1)
23:18
decision (2)
6:13,18
declaration (1)
7:16
declares (1)
22:6
DEIS (8)
7:19,24;8:7,11,20,
24;11:18;13:14
Del (1)
21:21
deliver (1)
21:17
Denmark (1)
27:14
deny (1)
10:8
Department (5)
3:4;6:21;12:14,19;
28:5
Department's (1)
3:20
described (2)
12:6;24:14
details (1)
13:24
determine (2)
13:10;22:20
determined (1)
13:16
developed (1)
15:11
developers (1)
26:3
development (4)
11:23;14:4;20:19;
21:5
directly (1)
6:18
discretionary (3)
9:7,8,9
discussed (1)
23:9
dispose (1)
9:12
disruption (1)
19:24
disrupts (1)
20:11
distance (2)
24:9,19
distinct (1)
12:3
District (1)
16:5
disturbance (1)
28:9
Division (2)
3:6,8
dock (1)
14:22
document (4)
7:23;8:15;12:21;
25:25
documents (1)
11:19
dollars (2)
16:3;20:13
Don (2)
24:13,14
done (2)
20:8;25:9
down (7)
10:10;12:11;
15:18;17:12;18:25;
19:22;27:8
Doyle (4)
18:20,24,25;25:23
Draft (8)
3:14;7:18;8:3,11,
13,14;17:18,19
dredging (1)
28:7
during (3)
16:18;17:13,22
E
earlier (1)
12:24
early (1)
6:13
east (1)
22:16
economic (2)
20:19;21:5
effect (1)
23:10
eight (2)
15:18;19:25
eighth (1)
27:9
EIS (10)
8:3,14,25;9:16,18,
20;10:5;11:13;17:18,
19
either (5)
4:20,22;9:11;10:8;
29:2
elaboration (1)
9:20
electrical (1)
15:3
electricity (2)
11:24;15:17
e-mail (1)
10:24
emissions (1)
27:13
employee (1)
19:20
employees (1)
24:5
end (3)
9:3;18:17;20:15
Energy (2)
3:5;21:3
engineer (1)
26:24
enough (1)
16:9
(2) businesses - enough
8:8
F
fact (1)
27:12
factors (2)
6:12;9:19
facts (1)
14:6
fairly (1)
13:4
false (1)
26:19
far (1)
18:10
Farm (3)
14:10;16:2;21:25
farms (1)
19:12
Fax (1)
10:23
February (1)
8:9
feel (3)
11:9;18:13;23:24
few (4)
4:6;5:11;14:5;
23:12
field (1)
11:23
fill (2)
10:13;27:17
filled (1)
16:17
final (8)
5:8;8:2,19,20,24,
25;9:16,18
finally (1)
12:24
find (2)
19:18;20:18
finding (1)
9:24
findings (1)
9:18
fine (1)
10:25
first (4)
7:12;17:5;18:19;
23:16
fishing (2)
27:22,24
fit (1)
6:4
five (1)
25:7
floor (1)
16:21
folks (2)
11:11;28:16
follow (2)
4:11;27:2
followed (3)
3:25;4:14;5:13
form (1)
29:2
formal (4)
4:18;5:4,8,14
formally (1)
29:6
forward (2)
28:3,15
found (1)
22:22
four (1)
6:6
frame (1)
24:2
FRANZ (2)
27:20,21
free (3)
9:25;11:9;26:20
frequency (1)
23:21
front (6)
5:24;17:9,17,25;
18:20;27:17
fuel (1)
27:13
full (1)
11:18
function (1)
27:4
fund (1)
6:18
funding (1)
9:12
further (1)
10:10
G
Galloo (8)
3:11;15:19;19:7;
21:19,24;22:16;
23:10;27:23
gas (2)
26:9,16
Gaspe (1)
24:16
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4:10
gear (1)
23:16
generally (3)
19:11;23:22;26:2
generate (3)
16:2,8;26:18
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11:24;22:7
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12:5
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27:22
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27:11
Germany (1)
27:14
Gill (1)
28:8
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20:20;29:3
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29:10
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21:5
Good (1)
3:2
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12:6,11
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9:10,13
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6:9;13:7
grant (1)
9:11
great (1)
20:9
Greiner (5)
4:14,23;13:22,25,
25
grid (1)
19:23
ground (4)
15:4,4,21;17:6
Guard (1)
27:25
guests (1)
29:8
guide (1)
27:22
H
half (2)
22:16;25:7
halved (1)
27:7
hamlet (1)
19:6
handout (3)
5:18;14:6;18:18
hands (1)
5:20
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19:2;28:11
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7:13;8:16;25:12
Harbor (4)
16:5;20:10;28:3,8
hard (2)
24:3,6
harm (1)
20:4
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20:3
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28:5
hear (6)
17:11;23:23;
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heard (1)
7:24
hearing (14)
3:18,24;4:18;5:5;
8:14;12:15;13:15;
16:13;17:11;21:24;
23:23;24:5;28:17;
29:5
heart (1)
20:5
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3:18
helipad (1)
14:24
helped (1)
21:8
helpful (1)
18:8
Henderson (3)
15:19,22;27:21
Herb (1)
23:6
high (2)
19:22;26:6
highest (1)
19:15
historic (1)
19:6
history (1)
27:23
hold (1)
5:10
holding (1)
13:15
hope (3)
20:15,16;22:21
hopefully (1)
4:24
HOUNSFIELD (37)
3:1,10,15;4:1;5:1;
6:1;7:1,5;8:1;9:1;
10:1,4;11:1,14;12:1;
13:1;14:1,10;15:1;
16:1,4;17:1;18:1;
19:1;20:1;21:1,21,
24;22:1;23:1;24:1;
25:1;26:1;27:1;28:1,
21;29:1
hour (1)
27:7
house (1)
15:13
households (2)
16:9;25:24
housing (3)
14:19,19,20
hundred (1)
26:23
hydro (1)
26:9
(3) entering - hydro
I
idea (3)
23:9;25:9,23
ideal (1)
26:6
Impact (15)
3:14,16;5:6,9;6:9;
7:17;8:20;21:19,25;
22:2,6,8,14,20,22
impacts (2)
6:24,25
important (1)
9:21
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23:21;24:3
include (1)
12:20
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5:17;9:15;11:13,
14;12:20
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12:7,9
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12:22
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6:11
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13:16
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5:22
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16:15
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26:2
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11:8
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14:17;15:7,14
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14:8
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28:20
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11:21;12:17;18:11
into (7)
6:4,12;17:16;
20:13;21:7;27:18;
28:20
involved (4)
9:4,5,5,14
Island (21)
3:11;11:24;12:8,
10;14:14,15,18,24;
15:2,6,10,16,19,20;
21:19,24;22:16;
23:10;26:4;27:23;
28:5
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9:22
issue (4)
Min-U-Script
3:20;6:17;9:7,11
issued (5)
7:7;8:3,10;9:16;
10:5
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5:7;8:21;9:21;
13:19
J
Jack (2)
3:3;6:5
Jefferson (1)
16:4
Johnson (4)
21:15,16,16,23
June (3)
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K
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27:3
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L
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12:11
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23:15,25
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28:23
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Law (2)
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24;20:3
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18:2
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16:14;18:13,14;
26:18
Litwhiler (6)
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27:16;28:13
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23:7
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15:16;22:15
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6:13,17;7:4;9:6,10
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15:19,23;18:9,13,
15
long-term (1)
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20:16
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21:8
Lyme (7)
21:17,22;22:3,8;
23:3,8;25:13
M
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March (2)
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May (10)
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14:12;16:8;21:4;
26:4,7,12
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10:20
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10:25
Metzger (1)
24:13
Mexico (3)
11:25;12:11;15:22
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6:10
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14:9;26:11
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milestone (1)
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16:3;20:13
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21:7,13
N
name (7)
11:2,10;13:25;
18:21,24;21:16;
27:20
NASCA (6)
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(4) idea - naval
O
o'clock (2)
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Min-U-Script
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Once (9)
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one (8)
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Ontario (1)
19:19
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26:22,23
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14:20;15:2,12
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26:25
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oral (2)
17:9;29:2
order (2)
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Oswego (4)
11:25;18:25;
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Others (1)
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otherwise (2)
20:4,19
out (10)
3:3;5:21;6:16;
10:13;16:17;26:3,4;
27:8,17;29:4
outline (3)
7:19,23;8:2
output (1)
27:10
over (9)
5:2,15;13:22;15:9;
22:11;24:5,8;26:12;
28:15
overall (1)
6:2
overview (1)
4:15
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28:5
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P
28:10
PILOT (4)
page (3)
20:22,22,25;24:14
5:24;10:11,15
place (2)
part (6)
15:3;24:24
5:5,6;11:11;14:14;
plan (2)
25:11,12
7:5;10:4
partaking (1)
planned (1)
6:3
15:10
participate (1)
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4:4
23:8
participating (1)
plants (2)
29:5
19:21;27:2
particular (4)
play (1)
6:19;7:23;12:17;
6:16
13:8
please (2)
particularly (1)
18:2,20
25:15
plus (2)
parts (1)
22:13,24
15:14
pm (2)
pass (1)
3:19,19
24:19
point (6)
passed (1)
11:5;13:22;22:15,
5:21
21;25:6,10
passes (2)
polite (2)
23:21,25
18:2,4
payments (1)
pollution (1)
16:3
26:21
Peninsula (3)
populate (1)
24:16;25:6,11
28:10
Penninsula (2)
portion (5)
22:15,21
12:5,17;15:6,10;
people (8)
17:23
4:19;5:3;14:23;
15:16;18:2,10;25:21; poses (1)
22:7
27:11
positive (1)
percent (6)
7:16
15:24;26:12,13,14,
possible (2)
22,23
6:14;14:16
perhaps (1)
Power (24)
17:18
11:17;16:9;19:4,9,
period (6)
18,21,24;20:12,17,
4:19;9:3;13:12,13,
20;21:4,7,9,12;26:8,
19;16:19
9,18,20,21;27:2,3,8,
permanent (2)
9,14
14:18,20
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permit (5)
26:9
6:17;9:7,8,11;13:8
power-wise (1)
Permits (12)
19:10
3:6,9;6:22;7:3,4,6,
7;12:25;13:3,4,17,20 prepare (1)
8:19
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presentation (1)
6:25;7:2
4:7
permitting (2)
presentations (6)
14:2,3
4:6,16,22;5:11;
person (2)
6:6;18:5
8:15,18
presented (2)
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9:19;23:9
22:5
presenting (1)
phenomena (2)
4:15
23:24;25:14
preserve (1)
20:9
Pressure (1)
20:24
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22:11
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19:13
probably (1)
18:11
Procedures (1)
13:6
proceedings (1)
29:15
process (23)
4:8,11,13;6:2,4,10,
13,15;7:5,8,10,12;
8:22;9:15;11:9,21;
12:6,22,23;13:9;
14:4,5;28:21
processed (1)
13:5
processes (2)
12:3;15:14
produce (3)
19:10;26:5,11
produced (2)
23:15;26:14
PROJECT (55)
3:1,9,10,11,12,15;
4:1,13,16,20;5:1;6:1,
19,23;7:1;8:1;9:1;
10:1;11:1;12:1,4,5,
18;13:1,17,23;14:1,
5,6,10;15:1;16:1,8;
17:1;18:1;19:1;20:1,
12;21:1;22:1,3,7,13,
19;23:1;24:1;25:1,
12;26:1;27:1;28:1,3,
12,22;29:1
Projects (1)
3:5
propellor (1)
23:25
property (2)
9:12;28:4
proposal (2)
11:22,23
proposed (6)
3:15;4:15;12:8;
21:24;22:12;28:21
protection (1)
6:25
provided (1)
18:22
provides (1)
8:23
providing (1)
28:19
public (32)
3:14,17,18;5:14;
7:20,24,25;8:4,9,12,
14,22,23;12:12,14,
(5) necessarily - public
Q
Quality (2)
4:8;6:8
quickly (1)
9:4
quiet (3)
24:23;25:15,19
quite (4)
24:9,10;25:2,18
R
racket (1)
25:18
raise (2)
5:7,20
raised (2)
4:22;8:22
Re (27)
3:1;4:1;5:1;6:1;
7:1;8:1;9:1;10:1;
11:1;12:1;13:1;14:1;
15:1;16:1;17:1;18:1;
19:1;20:1;21:1;22:1;
23:1;24:1;25:1;26:1;
27:1;28:1;29:1
reach (1)
11:15
reaction (1)
24:21
read (3)
16:6;23:12;28:16
realize (1)
26:24
really (3)
25:11;26:5,19
reason (4)
10:7,7,8;11:6
reasoned (1)
9:20
receipt (2)
8:12;14:22
receive (4)
5:8,19,20;8:16
Min-U-Script
received (4)
12:23;13:3,5;
28:25
recently (1)
24:13
record (16)
4:18;5:3,4,5,6;
10:5,6,9;16:13,21;
17:4,15,16;27:18;
29:3,6
recorder (1)
17:12
recounted (1)
24:18
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21:19
regarding (4)
12:23;22:2,5;
23:11
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19:9
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10:24
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12:13
regulation (1)
6:9
regulations (1)
12:2
related (3)
11:20;12:21;13:19
relatively (1)
4:17
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28:23
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17:13;18:9
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5:3;17:3
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18:22
representatives (2)
20:24;21:11
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15:8
request (1)
22:18
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7:3
required (2)
6:22;7:18
requires (1)
7:6
Residence (1)
27:21
residences (1)
25:6
residents (4)
19:6;21:13;22:15,
20
respectfully (3)
22:8,18;23:2
responding (1)
17:22
response (1)
5:8
responses (1)
8:23
responsibility (1)
14:3
rest (1)
26:13
resulting (1)
13:2
review (14)
3:18;4:8,13;6:8;
7:5,20,25,25;8:4,8,9;
10:4;13:7;28:20
reviewing (1)
12:3
Rick (5)
4:14,23;13:22,25;
16:12
right (5)
6:11;19:3,22;20:5;
21:3
right-of-way (1)
15:24
roads (1)
14:25
rock (2)
10:19,20
room (1)
17:10
route (1)
12:7
rudder (1)
24:2
rules (1)
17:6
run (3)
12:9;15:4,21
S
Sackets (2)
16:5;20:10
safe (1)
28:3
same (1)
20:10
savings (1)
27:13
saw (1)
27:3
School (1)
16:5
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7:19;8:2
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7:23
Scott (2)
21:18;23:2
seaway (2)
24:14,16
second (4)
3:21;4:2;6:15;25:8
Secondly (1)
23:19
section (2)
21:20;22:5
seeing (2)
25:24;28:14
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25:19
send (1)
10:17
sent (1)
11:12
September (1)
8:3
SEQR (10)
6:11,15;7:8,10,11,
13,16;9:15;10:9;12:6
series (1)
15:12
Service (4)
12:12,14;14:25;
29:8
Service's (1)
12:19
session (12)
3:25;4:2;5:2,14;
10:12,13,16;16:15,
20,20,25;20:16
sessions (1)
4:4
set (1)
6:5
several (1)
20:4
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16:11
share (2)
19:5;22:4
Shawn (1)
18:24
ship (5)
24:2,15,22,23;25:4
shipboard (1)
23:14
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24:20
ships (3)
23:25;24:5,7
shore (1)
25:19
short (2)
4:17;13:4
shown (1)
11:16
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18:4
significant (4)
22:7,14,22;25:5
Signor (1)
21:21
simply (1)
12:16
site (7)
7:5;10:4;11:16,18;
12:20,21;25:7
sitting (1)
20:25
situated (1)
14:14
situation (1)
6:20
size (1)
14:11
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18:4
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28:9
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24:8
someone (1)
18:14
sound (3)
24:8,22;25:9
sounds (2)
23:22;24:12
source (2)
26:15,15
sources (2)
26:10,21
southern (1)
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15:14
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28:9
speak (6)
4:3;10:12,12;11:7;
16:18;18:2
speaker (1)
16:17
speakers (2)
17:4,5
specifically (1)
21:20
specifications (1)
23:18
speed (2)
27:4,6
spelling (1)
18:23
split (1)
16:4
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27:21
stable (1)
25:14
stacks (1)
25:2
staff (2)
29:6,7
standards (1)
22:23
State (18)
3:4;4:8;6:7,12,17,
20;9:6,9;12:2,12,13,
(6) published - State
Min-U-Script
T
table (4)
5:18;20:24,25;
21:10
tail (1)
20:15
talk (5)
4:7;13:23;17:21;
19:17;20:6
talked (2)
10:11;17:13
talking (5)
5:17,23;6:6,7;
24:13
tap (1)
21:7
temporary (2)
14:18,19
Ten (1)
9:16
terms (1)
14:17
Thanks (1)
5:16
therefore (1)
25:8
thinking (1)
14:12
though (1)
16:16
three (4)
18:10;24:20,22;
25:4
threshold (2)
22:13;23:23
thus (1)
18:10
Times (1)
3:24
today (11)
3:13;4:9,10,12;
5:17;6:3;8:13,16;
11:7;12:7;13:15
today's (5)
10:12,13,16;11:21;
12:15
Tomasik (7)
3:7;4:7;5:15,16;
10:20;23:11;28:24
tonight (1)
4:3
tooth (1)
27:3
tower (1)
12:5
TOWN (49)
3:1,10;4:1;5:1;6:1;
7:1,4,6;8:1;9:1;10:1,
3;11:1,13,14,15,25;
12:1,11;13:1;14:1;
15:1,22;16:1,4;17:1;
18:1;19:1;20:1;21:1,
17,21,22,23;22:1,3,8,
17;23:1,3,8;24:1;
25:1,13;26:1;27:1;
28:1,21;29:1
towns (2)
20:21;21:8
township (1)
20:8
townships (1)
20:5
train (1)
23:16
transmission (7)
12:7,9;15:21,23;
19:17,22;20:3
transmit (2)
11:24;19:18
transmitted (2)
15:17;25:10
travelling (2)
22:11;24:8
treatment (2)
7:2;15:15
try (5)
5:25;20:18;21:11;
24:6;29:10
turbine (5)
15:5;22:13;23:16,
20;27:5
turbines (7)
14:11;19:13;
23:15;24:17,19;
25:18;26:16
turn (4)
5:15;13:22;17:4;
28:15
Turning (2)
10:15;25:18
two (3)
11:13;12:3;16:3
types (1)
4:9
5:22;10:23;11:4,5;
13:11;17:17,25;18:5,
20;21:11;24:16,25;
25:17,23;27:17,19
upgrade (1)
28:2
upon (1)
8:8
Upstate (2)
11:17;29:7
use (4)
26:10,17;28:2,4
used (1)
21:6
useful (1)
17:19
using (1)
25:25
utility (2)
19:14;20:16
utilize (1)
28:4
under (12)
7:11,13,16;9:15;
12:6,10,10,14;13:5;
15:4;20:18;26:5
underground (2)
19:19;20:12
undertake (1)
6:18
underwater (2)
15:18;19:25
Uniform (1)
13:6
Unit (1)
3:6
unlikely (1)
26:17
up (16)
V
variability (2)
27:2,5
variance (1)
27:10
vastly (1)
20:11
vehicles (1)
15:13
velocity (1)
25:17
ventilating (1)
25:2
view (1)
19:7
village (2)
20:6,7
villages (1)
21:8
waiting (1)
9:2
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5:19
wants (1)
17:24
Warren (3)
21:16,23;23:9
Warren's (1)
25:8
waste (2)
7:2;15:15
water (7)
6:25;7:2;12:10;
15:15;22:11;24:8,11
Watertown (1)
3:24
way (3)
5:23;19:18;20:18
web (5)
11:16,16,18;12:20,
21
weigh (1)
9:18
weight (1)
29:3
welcome (1)
4:4
weren't (1)
5:22
westerly (1)
22:11
wetland (1)
6:24
wetlands (1)
14:15
what's (3)
8:19;9:7;13:5
Whereas (1)
22:6
Whereupon (2)
16:24;29:15
WIND (56)
3:1,11,11,15;4:1,
16;5:1;6:1;7:1;8:1;
9:1;10:1;11:1,22;
12:1,5;13:1;14:1,10,
11;15:1,25;16:1;
17:1;18:1;19:1,12,
12;20:1;21:1,24;
22:1,12;23:1,15;
24:1,17;25:1,3,17;
26:1,3;27:1,2,4,4,6,6,
7,9,10,13;28:1,21;
29:1,7
winds (4)
22:12;26:6,6,11
wish (1)
10:15
words (1)
4:11
work (2)
10:21,24
worked (1)
24:6
writing (6)
8:18;10:16;18:7,8,
16;28:24
written (2)
23:11;29:2
Y
year (4)
7:16,21;8:10,12
years (2)
10:23;24:5
year's (1)
26:12
York (13)
(7) Statement - York
Min-U-Script
DEPARTMENT OF STATE
ONE COMMERCE PLAZA
99 WASHINGTON AVENUE
ALBANY, NY 12231-0001
DAVID A. PATERSON
GOVERNOR
LORRAINE
A.
CORT~S-VAZQUEZ
SECRETARY OF STATE
May 26,2009
Stephen M. Tomasik
C/O NYS DEC Central Office
625 Broadway, 4th Floot
Albany, NY 12233-1750
Re:
S-2009-0029
U.S. Army Corps of Engineers Buffalo District Permit
Application
NYS DEC Region 6 Permit Application
Hounsfield Wind Farm project,
Galloo Island, Hounsfield, Jefferson County
SEQRA Comments DEIS
State regulated freshwater wetlands should be preserved and protected and as such, destruction should
be avoided. However, the DEIS states that some wetlands impacts are unavoidable and proposes
wetland mitigation. If determined acceptable it should be stipulated that where practical, all wetland
mitigation should be located within the sub-watershed that the original disturbed wetland is located
within and that area to be mitigated should be maximized. Additionally, specific parameters should be
established that define what would constitute a successfully established wetland and at what point
guaranteed remedial action would occur, should success parameters not be met. It may be advantageous
to guarantee proper wetland establishment through bonding or other financial security mechanisms.
Additionally, public comments have been received that identify public recreational uses associated with
various wetland areas on the island through existing agreements with the private landowner; these uses
should be preserved to the extent practical.
It may be advantageous to explore the potential benefits derived from curtailing generation during
periods of increased avian activity. A recent study at the Casselman Wind Power Project in
Pennsylvania indicated that avian and bat impacts may be reduced by raising the minimum "cut-in"
WWW.DOS.STATE.NY.US
E-MAIL: INFO@DOS.STATE.NY.US
wind speed necessary t~ begin turning the wind turbine. An investigation into the viability of such a
procedural shift may indicate that the benefits derived warrant its implementation. Similarly, this
procedure may be useful to curtail potential effects on the viability of proximate Significant Coastal
Fish and Wildlife Habitats (SCFWH).
Several SCFWHs are located within close proximity to the proposed project site and because of the
selected w.ind turbine's significant vertical profiles, avian utilization ofthese SCFWHs may be
affected. Specific pre-construction characterization of avian uses ofthe SCFWHs should be required
along with sufficient post construction monitoring to quantify any potential effects. Appropriate
provisions for operating procedure adaptation should be included in the DEIS should effects on
proximate SCFWHs become evident. These and all other wildlife monitoring data should be presented
to all regulatory agencies and made available for public inspection.
Appropriate best management practices and procedures should be identified that will control
stormwater runoff and associated non-point source pollutants reaching Lake Ontario during the
construction and operation of the proposed facility. Additionally, all point source discharges should be
treated in a manner consistent with current state regulations. These discharges should not effect any
current or proposed potable water supplies.
Specific procedures should be identified that provide for the removal ofthe proposed temporary dock
and groin and established time frames should be proposed.
Several public property parcels are located on Galloo Island with various historic, cultural recreational,
visual and other resources associated with them. Additionally, public areas on the mainland, notably
the historic areas of Sackets Harbor, may have similar resources. The benefits derived by the public
from these properties should not be impacted.
Potential public-access and water-related recreational opportunities that are compatible with the
proposed activity should be identified and considered. These may include providing areas of safe
harbor as identified at the May 18, 2009 public hearing, public docking facilities to encourage
The applicant's analysis of coastal policy states that excavation of the entrance channel would be to a
depth of 14 feet below ordinary high water, however, the document also makes reference to ordinary
low water as the applicable datum. These discrepancies should be addressed.
Additionally, it would be desirable for the Department of State to be included on the distribution list for
all future monitoring reports regarding this proposed project.
Please contact Matthew Maraglio with any questions regarding this project and New York State Coastal
Policies at (518) 474-5290 (email:matthew.maraglio@dos.state.ny.us).
Silt
~erv~lonsistenCY
Unit
Office of Coastal, Local Government
and Community Sustainability
JZ/mm
C.
OFFICERS
Charlie Ames
President
Doug Fuegel
Vice President
Tom Lott
Treasurer
Stephen Tomasik
NYS DEC Div. of Env. Permits
625 Broadway, 4th floor
Albany, New York 12233-1750
BOARD OF
DIRECTORS
Gerry Bresadola
Jerry Lougnot
Jack Quinlan
Neil Duell
Roy Hunsberger
Bill Thomas
Jay Levy
Zane MacFadden DDS
Joe Wilcznski
Jake & June Howell
Barry Stevens
Skip Geppner
Surely, there is a better solution to the routing of this power line, than
the one you have purposed going over my property, with all of the
undeveloped land in the north country, why pass through populated area's?
Respectfully,
Raymond S. Walty
P.O. Box #67
8508 Reed Canal Road
Henderson Harbor, NY 13651
315-938-5258
**************Recession-proof vacation ideas. Find free things to do in
the U.S.
(http://travel.aol.com/travel-ideas/domestic/national-tourismweek?ncid=emlcntustrav00000002)
owned by Ross, he was Town Supervisor at the time and Richmond the Village Clerk, the
site has proven to give limited cell phone service. The proposed Galloo transmission line
routing was put in place to make the Ross land a candidate for windmills at the expense
of me and many other land owners. The misuse of political positions in NNY to enhance
those individuals personal income needs to be examined by a neutral agency, this practice
is out of control due to lack of oversite.
I support green energy, however this process requires more oversite.
Respectfully: Peter M. Price
8048 NYS route 3 PO box 67
Henderson NY 13650
_________________________________________________________________
Windows Live: Keep your life in sync.
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W ~ I * P&-
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The U.S. Fish and Wildlife Service (Service) has reviewed the Draft Environmental Impact
Statement (DEIS) for the proposed Hounsfield wind energy project dated March 2008. The
project sponsor, Upstate NY Power Corporation, proposes to camtruct up to 84 wind energy
turbines on Galloo Island in the Town of Hounsfield, Jefferson County, New York.
Our review md comments are being provided under the State Environmental Quality Review Act
(SEQRA) process, in which the New York State Department of Environmental Conservation
(NYSDEC) is acting as Lead Agency. We may provide future comments pursuant to the
Migram Bird Treaty Act (MBTA) (40 Stat. 755;16 U.S.C.703-712),the Bald and Golden
Eagle Protection Act PGEPA) (16 U.S.C. 668-668d), the Endangered Species Act of 1973
(ESA] (87 Stat. 884, as mended; 16 U.S.C. 1531 et sq.), the Clean Water Act (CWA) (33
U2S.C. 13441, or the Fish and WiIdlife Coord'mtion Act (48 Stat. 401, as mended; 16 U.S.C.
661 et seq.), as applicable.
The foI1owing represents our specific comments on the text of the DEIS :
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reduction of this "penhouse gas" is 4 percent. Interestingly, electric generating fwilities only
produce about 39 percent of all carbon dioxide emissions in the United States (EM2006).
Project staging and laydown areas are described on Page 1-18. We note that over 9 acres of
forest habitat will be impacted by these areas. No staging areas are proposed in the disturbed
adcultural fields on the northeast portion of the island, Consideration should be given to
reducing impacts to higher q d i t y habitat, instead using disturbed areas. Further, we note that '3 5
turbines are proposed in forest habitat while ody 8 are p ~ p o s e din agricultural areas. A
reduction in the number of turbines, along with associated access roads and electric collection
lines, placed in forest habitat is preferable.
There will be 9 miles of overhead electric collection lines a d 2-6 miles of overhead transmission
line constructed on the island. Overhead lines can cause substantial avian and bat mortaliw due
to collisions with lines and poles (Avery 1978). Avian electrocutians can occur if these
structures are not properly designed. An important resource for planning power line corridors
was produced by the Avian Power Line htemtion Committee (1996) and should be followed.
We recommend that the transmission line be routed around larger tracts of forests, grasslands,
and wetlands to protect existing habitat value, reduce fragmentation, and maintain interior wre
areas.
Turbine foundations will be excavated using blasting due to the prevalence of bsdr~ckon the
island. We believe this method of excavation may be very disruptive to some forms of wildlik,
such as reptiles and amphibians, small mammals, and ground nesting birds, Additional
infomation should be provided an the potential impacts to these animals. Approxhately
600 cubic yards of rock will be removed for each foundation and it is unclear to us where this
quantity of rock (over 50,000 cubic yards in total) will be disposed of if it is not used to wake
concrete.
The document indicates on Page 1-29 that 2.4 miles of overhead transmission line will be needed
on the island, but Page 1-23 indicates that 2.6 miles of overhead line will be needed. This
discrepancy should be reviewed,
Permanent road crossings through streams and wetlands are described on Page 1-43, It is
anticipated that four wetland crossings and no stream crossings will be required. However, we
noted the presence of multiple channels which may be intermittent or ephemeral. Irrstead of
using culverts to cross w e h d s , the project sponsor proposes to use ~ a c k
p l d within the
wetland. We do not support this plan for a number of reasons. First, the rock may limit water
movement when compacted. Second, the rock tends to trap sediment which can also limit water
movement. If heavy loads of sediment are present, it can become labor intensive and expensive
to t o m a i n t a i n the cmsshg. During high flow events, the rock can become dislodged and move,
Hard surfaces can cause erosion in areas adjacent to where the rack is placed. F d e r , the rock
will limit nutrient uptake and vegetation growth (although this could also be true for culverts).
Rock crossings are not recommended in wetlands by the Natural Resources Conservation Service
(NRCS 2003). Therefore, we recommend the project sponsor review the current design and,
where necessy, replace rock crossings with bottomless culverts.
We are concerned with language m Page 1-46 in .that it is vague and does mt make
commitments to protect the environment. For example, the text states that mitigation far
t e m p m y wetland impacts will likely consist af restoring disturbed areas as close as possible to
preoonstruction conditions. A commitment should be stated that disturbed mas will be restored
to original conditions.
Text on Page 1-46 also indicateb that service roads will be constructed flush with the surrounding
g a l e to minimize intemption of surface flow. However, several portions of the docum&t
discuss dumping stone to create gravel w e s s roads. A flush surface will not be created by
dumping stone on the ground; however, it would cause a blackage to surfhce water flow,
Page 1-49 indicates that security lighting will be installed with lighting shielded in a downward
direction, We suppert that measure but also suggest that mot is^ sensors be placed on outside
lighting to save electricity and limit the amount af time lights are on at night. This will further
reduce avian attraction. Sodium vapor lights should be avoided.
Recent research at c o m u n i d o n towers in Michigan indicates that steady, burning red lights
(L-8 10) contribute to p a k t avian co1lisions. Minimum intensity and maximum offdmation
white or red strabe or flashing lights reduced mortality up to 71 prcent (Gerhring 2006).
Canstruction afthis p m j e will require a work farce of approx"~z~ate1y
220 M,Xn addition, 24
permanent staff will handle routine turbine operation and maintemmca, This level of human
presence and activity will be extremely disruptive to wildlife, especially those species on the
island which are secretive md are~egativelyaffected by human presence (i.e. h & c m bittern).
Because the project will be com~ctedon an island, there is limited arm for refuge from these
activities. The DEIS s&ouIdreview this issue in greater detail.
The consultationrecord on Table 1.6-2 is out of date and should be updated after Mky 2008.
Other statutes under our jurisdiction, ia addition to those: listed on Page 1-59, include the MBTA
md the BGEPA. The text should be revised to reflect these law.
Section 2.0 Rmurce Characterizaticru, Impact Assessment and Mitigation The DEIS
indicates that up to 168 acres of the island has been used for agriculture, It is important to note
that large numbers of gulls have been observed &ding in these areas. However, the report also
indicates that agricultural practices will be Mted upon project cmstnaction but available for
future use. Given that productive @r;ultute can attract some birds in large ~lurnbers~
we
recommend against planting crops which attract birds to the island. Tnis will avoid attracting
wildlife to an area with turbines.
While the DEIS indicates, on Page 2-22, that one stream is mapped on the island, a review af
aerial photography reveals what applears to be other channels. During a recent sik visit, we noted
several channels, although they may be intermittent or ephemeral in nature.
Work within Lake,Ontario includes blading and dredging ta create a vessel slip. We recommend
that silt curtains be required to cantah turbidity and prohct water quality in t h work
~ areas,
Apprmimately 650' large boat trips, 216 large b q e trips, 51 small boat trips, and the arrival of
mechanized landing craft on another 41 trips durifig ;eomtruction, will result in impacts to
shoreline areas and water quality. Slip and dock areas should be monitored regularly far erosion
during the construction period and corrective measures taken if necessary.
Un Page 2-30, the text states that concrete slurry disposal and washout procedures will protect
stream, pond, and lake water quality, but does not specifically mentiofi wetlands. F&,
the
report indicates a de minimu5 mount af fluids could leak from vehicles and equipment, but does
not consider hazardow fluids in turbine nacelles or transformers. This should be addressed in
this section.
Reference is made to a landfill on Page 2-33, but we saw no ather information for this type of
facility. If a landfill is proposed an the island, additional details on potential wildlife impacts
should he provided.
Lake sediments are described on Page 2-36 and testing indicates that of 17 sampIes, 10 had no
appreciable contamination, but the other samples had moderate c o n ~ t i o n The
. DEIS should
provide a better swnrtlary of the sampling results and do a more thorough evaluation of the
potential contaminantsthat may occur in proposed dislurbd asens. This should inclyde a more
in-depth analysis of the potential impacts to fish and wildlife,
Wetlands are described in Section 2.4.3, which indicates that approximately 361 acres of this
habitat type are found on the island. Qne area, Wetland J, m y not be jurisdictional due to its
isolation h m a navigable waterway. The report should be updated and pro.vi& infunnation on
whether ar not this area has been deemed jurisdictional.
Placement of fill into wetlands will mostly result fiom the construction of access roads and
clearing for electric lines. A total of 0,79 acres will be permanently impacted. As mentioned
above, the placement of rock into wetlands for crossings is not recommended. Instead culverts
should be considered as a means of crossing these areas. W e the project design does avoid
most of the site wetlands, many of these m a s will be completely swrounded by roads and
turbines, thereby decreasing the habitat value. We do not klieve &at the project &sign avoids
wetlands to the patest extent practicable. Several mads and electric lines can be moved to
avoid wetrands (between Turbines 64 and 65154 for example). Also, the overhead line between
Turbines 71 and 77 could be moved to folIow the access road and avoid crossing Wetlad F.
As mitigation for 0.79 m wetland impact, the project sponsor proposes to create 0.27 acre of
wetland fram an upland area. We found no explanation as to why the wetlands would not be
replaced in their entirety. Tmically, wetlands are replaced at a ratio higher than what is being
impacted. Forested wetlands are usualIy replaced at a ratio of 2 acres created for every 1 acre
impacted, due to the time it takes to replace wetland functions. It is stated that few l o d o n s are
mailable to create more wetlands. We have not seen information which supports the notion that
additional wtlmds c m n t be created on the island. In fact, we observed several suitable areas,
such as adjacent to Wetlands D or F. We recommend the wetland mitigation plan be reevaluated
and at least 1.5 acres of created wetland be built or restored, since most of the impacted wetI-d
is forested in nature.
Measures to protect wetlands are listed on Pages 2-53 and 2-54. However, measures are
suggested rather than committed to in the text. We suggest changes to the text, fm example,
rather than stating that clay ditch plugs can be used to prevent dram@ of wetlands, the text
should say they will be used. Also, seeding with appropriate grasses should be changed to
seeding with native species, if appropriate.
Section 2.5 describes wildlife and habitat and lists the attributes of the @em Lake Ontario
region and its importance to wildlife, particularly birds. In discussing the various habitat types
found on the island and associated wildlife dependent upon h m ,the DEIS concludes that there:
will be minor wildlife impacts, Given the long time W e for construction (3 years) and the
constant human activity, we expect impacts to be substantial, ifnot sigmficant, to sensitive
species. Also, given the web of infrastructure and turbines to be- constructed throughout the
island, remaining habitat will be degraded Further, we believe that the permanent presence of
project staff on the island who will be constantly inspecting, operating, repairing, and moving
equipment throughout the island, will permanently affect wiIdlife*especially those species not
accustomed to or tolerant of human presence. Also, there may be potetltid impacts to birds on
nearby Little Galloo Island, including State-listed species, fmn construction activity and boat
trafEc.
On Page 2-61 it is indicatd t . the project wiIl not adversely affect adjaent Little Galloo Islmd
or the species that transit between h e two islands, We found insufficient data in the report to
support this statement. It is noted in the avian report that "Little Galloo colonid waterbirds were
documented .to making regular feeding flights across Big Gallao Island''. Visual surveys were
only conducted for 20 minutes once a week between April and November. Additional visual
observatiam are needed tu confirm movement3 of Caspian terns, gulls, and cormorants. We
recommend repeating the studies to cormfirm results.
The first p g r a p h on Page ES-22 has contradictory statements with the first sentence,indicating
a minimal impact on birds and bats, and the second sentence signifying there will be impacts of
m d m significance. This should be clarified.
It is mentioned that impacts to reptile and amphibian habitat will be minimal due to the low
amo,untof wetland loss. However, upland areas represent significant habitat during some portion
of herpafaunalife cycles. The DEIS needs to consider the impact to upland areas as well as the
network of roads and utility corridors upon habitat conditions. Although the report states there
will be habitat fragmentation from roads and electric lines, it does not quantify the efkcts on
habitat quality. This should be dded to the document.
On Page 2-73, it is mentioned that the substationwill be built within deciduous forest and
because there is no unique habitat or wildlife, an alternative location is not necessw. We
disagree with that statement. An n p field is located adjacentto the forested site where human
disturbance, such as deer feeding stations and trails, are found. We believe this would be a more
appropriate location and reduce the need for forest clearing.
Bald eagles bave been observed on the project site, particularly on the northern shore near North
Pond. A gdden eagle was also observed near the center of the island. On August 8,2007,the
bald eagle was re~ovsdfram the Federal Endangered Species list md is no longer protected
under the ESA; however, bald eagles remain on the New York State list as a threatened speciesBald and golden eagles are also pr~tectedunder the MBTA and the BGEPA. The Service is
currently -finalizingregulations r e h d to eagle take, and we suggest the project sponsors review
that i n f o d o n when available. D i d movement studies of the project area were conducted
over 43 days for only 1 year (2008). The Service typically recornmends that avian studies be
conducted for more than one season in separate years to account for seasonal and annual
variation. Therefore, we recommend additional monitoring be conducted to determine eagle and
other raptor use of the project area
Data is lacking on wintering birds on and near the island, Only 5 avian surveys were completed
during the winter of 2007-2UO8 wnd these were conducted at a quick pace due to adverse weather
conditions. Severe weather caused the cancellation of 8 other surveys. We understand the
difficultyin accessing the project site in winter; however, there is a lack of data for Wintering
birds. This is especially troubling since large concentrations of waterfowl use @e lake around the
island and bald eagles use the area in winter as well. In fact, bald eagles were o b m e d on ewh
of the five winter survey dates. For these reasons, we recommend additional surveys be
conducted in the winter to determineavian use during that time. We recommend weekly surveys
be conducted from November through March and encompass all times of the day. Several
stations should be monitored simultaneously throughout the island.
Eighty bird species were documented on the project site duringbreeding bird surveys, inclding
eight State-listed species. Another 42 species were observed during the surveys, but it was
determined they were not breeding an the island. Although this is a goad indication of species
richness, many af the breeders are common species (American robin, yellow warbler, house
wren>etc.). Still, the island currently pmvides habitat for some rare species which have
experienced population declines and c~nstructionof the project may reduce or eliminate heeding
opporhmities for species of concern (upland sandpiper, northern harrier, and bald eagle). While
these species are not known to nest on the island, they were ohserved several times and are
potential nesters. We d i m p with the statement &at the p j , t m y open up some m a s and
make them nzui~blefor northern Met nest@. The network of road&,dectric lines, and
t w b k will limit nesting o p p t d t i e s for this species Additional breeding bird suweyf &odd
bb p e ~ with
~ a
d emphasis on swiaa of special concern d their preEemd nesting habitats.
We ~~d weekly survey9 b ~ e e June
h ahd August eovefhg both early morning and late
ahmoon -time periods.
m Page 2-79 indicates that the haldtat impam from the project will he low, so the
bidogical i m p t fivill be low as welt We disagree with that notion, prhwiIy because -tke
project infrastructure [roads,electric and overhead lines, turbines, subsmtion, and buildings) wiU
twi any remaining habitat into a patchwork of fiqmnted habitat, b y species wuld be
nerntively impad& by this s c m i a There will be5'me speoies tIiaa.hse m a t e d habitat ad
are accustomed to human disturbance which may ben& them (such as the European starling and
Tk
h e r i ~ a Jcrow).
I
&bile W e radar surveyswere co11ducted from April 15 to June 2,2008, and whib the survey
was designed to study spring migration, we believe that the survey8 WE M e d too late md
missed m y esly migrants (we m o m e n d a March 1 shtat).l'he study was comjucted an 43
nights af a dgradon period w h h lasts at least 90 days in the spring. However, it is unkn~wn
if
peak migration nighis w w sampled. It should tld noted that the m a n passage &te of 624 targets
per lci1met.w per hour is one of the highest Peoorded in New Yo&, While the @portindicates
that most targets flew above the turbiae height, qproxbtefy 19 p e n t flew within the mtbr
swept zaw and would be at risk af cdision. The report does not Mikate the import an^^ &.the
island as a mi-gatory stopover habitat, particularly during inglment weather mnditiom,but
should address this issue,
h 16ththe spring migration, we believe the Mi m h sampling period missed a key paion of
migration. This sampling occurred h m August 8 to Qmkr7,2008; howeverI fdl mimtion
geriedy stark in July and ex'tefids into DecemM. Birds such as shoreh'uds, water birds,
raptors, #d wateffowl were pbably miss4 W n g these. surveys. Some late passeritre migrants
-wouldnot have been counted as well. Om recommendation is that a d d i t i d radar m e y s be
conducted f i q July to mid December ta cover the entireperid of fdI migmtiarr.
We note:that the NYSDEC Guidelines far Conducting Bird and Bat Studies at Commercial Wnd
Energy Projcxts (2009)specifies that far certain areas ofthe Stafe: w h w a higher risk to-Gldlife
is possiMe, expanded prwarrstruction m e p s should be completed. The Hou~~sfield
Wid
Projet falls within twa of tlie criteria which necessitate addirioiwl study, i d d i n g , 2 .b.& w i k
5 miles ofthe Great Lakes, a d Zb..iii, within 2 znilw of slreas which concentrate raptars,
waterfowl, ,or specks of special mncem. Therefore, the projat sponsor should adhere to the
guidklirres and conduct tst least one addititianajyear of radar surveys. Doing so will prMQea
mow robust data set and account for antlusrl Y
~ invthe
~ data* Q
~
Noteworthy, is the passerine behavior when birds reached the end of the island and some tumed
around and flew back along the length of the island. If flying though turbines, this would
increase the risk for collision s h e the birds would be flying through or around them twice. We
believe this survey effort is worth repeating to contirrn study findings. The study should be
initiated in early March to capture more of the early spring migration.
Included in ihs study were radar images fjrortl a local weather station which showed a large mass
of waterfowl moving along the eastern end of Lake Ontario on March 27,2008. We raise the
question whether similar weather data can be reviewed for other portions of the year, and/or other
years, to gain knowledge of migration over the project area. The report states that it is unknown
if waEerfowl movements will be affected by the proposed project. X the project is builtJ we
suggest that post-construction monitoring evaluate this issue.
Impacts to birds are discussed on Page 2-92, and while there is a section on forest habitat
fragmentation and displacement of sensitive spwies, little is mentioned abut ~ s l a n species.
d
While no very large blocks of this habitat type exist oh the island, there are blocks which
currently exist but may be hgmented and made unsuitable for obligate species (such as
bobolinks). Grassland breeding bird surveys should be conducted in these areas to determine the
extent of breeding activity and use. Surveys should be conducted from early June through
August at least once per week. This should be reviewed and discussed in the report. As
previously mentioned, despite the lower number of habitat impacts for the project when
compared ta similar wind energy projects, the patchwork of roads, electric lines, and turbines
across the island m y result in greater habitat impacts to species sensitive to these structures than
reported.
It is reported on Page 2-95 that the project has been designed to lessen the impact on avian
habitat, such as forest, wetland, and grassland habitats, to the extent pmticabIe. We dtu not find
this statement to be substantiated. It appears the project is designed to fit the greatest amount of
turbines on the island and only avoid wetlands. Clmsequently, the other habitats are bisected in a
regular pattern. No portion of the island has been set aside to preserve wiIdlife habitat. Ow
mcommendation is b reduce the number of turbines in those areas that are of the most
importance to birds.
Collision risk fiom project operation is discussed on Page 2-96 and concludes that there is no
information to suggest impacts will be anything but low. However, W l o o Island is a unique
setting, there are very few examples of avian studies with which to compare to (none in the
nofiast), and the brief study period (1 year) makes it extremely difficult to predict risk.
Considering that many State-listed species and species of conservation concern are found on the
island, including the Caspian tern (which is found adjacent to the project, in one of only two
colonies in the State), more careful study is warranted. Further, several listed raptor species may
be at risk of collision, including the bald eagle, and warrant a cautious approach.
Studies to determine bat activity included acoustic monitoring and summer mist netting. Mist
netting revealed tha~little h w n bats are the most comman resident species on the island (only 1
silver-haired bat captured) during the summer. A colony of approximately 200 bats was found in
a barn, Migratory bats were monitored during fall migration ushg acoustic monitors located on
two meteorological towers at three heights aboveground, including near the rotor swept zone, a
d
at various locations on the island. Hoary bat calls were identified in the data, including near the
.adfie, ASthefeport p
ihtT out* givm h e species identifiedan GaUo'o Idand,
is
p a W d fhmigratory
&sident.bats to be negafivply. h m
by the pmpos& wind
turbines. The-rqodpredicts tf& fatdip numbers may be simflr b u ~are likelp to be-<hi&r h
mgnitudeIW
other s o r t h wi
~nd energy pr~jects-
The 8ervke typidly mc1n3rnm&wt these SWiia ?xWnducWd ovsr fnuliipk y m ifprdject
apwattm md'beWdrtrckd atdl h e s ~f the ymr and under varied weatherconditim. E
~ b h ewill
s be l w e d within trl*
dgrgwlmj habitat*we m m e n d t&informatian be
g&ered on dispiwemmt o f grtssland nesdng Bif&, Ta-mitigatep ~ h t i i~pacts
d
to bats,
hirbine *atid 9hoUf.d W l e d whbn &Ware mst:a t b e sflld at &her Tisk\cafcallidon.
This bdu&s dwhg MI migration (between July I $A and Beptmber 151,s hours after m e t , md
Whm w i d @ ~ d we
$ k s thm 6meters p& sewd ( j m b k s 3liould k v e a --in tipeed of
.&fat@tbm 6 w b r g per m m d L &%fit wewrch at the Meymsdal~Wid Project in
P e ~ 1 t ~ a , s h b wthat
e d bat m&ty
is r e d u d when tmbines are ncPt+tpratidd d n g bw
wind pepid [Ameft ZQ@Q Aka, pmject a~gmvd& p a he cgnd3im.d upon an~adaptiv~
mmagmmt plan tQ address wildlife mortdiiy e a r e d t g f turbine u~pemti~ars,
A camtmSrticm
emirbmental monitoring pfogmm shadd be hplefnmtedf& this p m w . We suggest that the
pr~gfartrIrmc1uck a W n g mhporient for warkets on haw to identify an$r hqndi$ injmd OF &ad
WiIdife-
An W e Iha d l b iqs2:alJdta supply potable wMer. Detdis ~nthe wakr line are lacking and
have been ~dmmgedsmad .tibht the text i n d b that intake velocities will b~ sad1 and m
imp& & axpemd $0 quatic life, We qtmf@atadequate sqmiting data b e ~ ~ v i d e d ,
M ~ 5 ; t ' ~ . f & e h ~ e h e m ~ b e 3 Q f @ t wb~1a o~t b~ i n
~ ~ee ~r e~w d
i f h~ h-a ~l
navigathn, An m i h o r n quantity ofmtef wPuIa be df%idi+awn
ffom the l&e- Iry me of a gump,
A sgpmte chmiql f w l line w ~ d beg@
d
ta clean the i n t g h . m ~ n .
We-no~e-thatthe DEIS dam
pmde idomation about Vie exact sim of t
k pa& intake nor
the size~ p n i n,of
g any serwn m&. kwas not - c hif bpprspsi'de hydraulic wnluatitionsw h q ~
mfnnpletal ta determine p&nW water w1~52Ztiesat W ifit&& m~-i3ira&ys&cis.needed
to
-debmineif'pdmtid ihpmheat or m m m t of aqua ti^ life mula a m during w&
wi@&wd. ~~k
the kappbg uf quatic ]life against the intake screen, c;m result in
iqq, pedatim,ar death tb orgmisrn~wable,
tookmp intake flow velaciw'. The S M m
typically rgcammends,tbat apprdacb velddcs at the.intake net ex-d Z feet per second so that
qwfic life -willbe aiJe =cap the.int&e flow, Entrdmmt is&e mavd 'ofaquatic.life ifiM
thi intake pipe. A wi=& wire s r e a or similar device i;4 used to prwrrtcenw i n t ~ t pipy
h ~ 3vt
if the apningswe too large, s&km fi* b d fi&, ~ggs,
and h v m t d w t e ~a n b
inta&fie pip. We typically recmmemd a 2 mi11imetejr cles spacing in the mesh .spenine, The
intake o@*g
PO
idormatian.
(A+we hated above, beailed studies fsrmoa of the traiwdssiorr h e prtim afthe project have
nut been completed d,
therefore, IIQ &"is available rn @e impacts tcr reswces; Era!wwerPthis
-sectians
m %:oni:I,usima
~ an mulative itflpts, It is dm no1 cla& why the tmt abw
theremwill
be no cun&tive irhfiactsfiofn #he trsmsmiission lime md mbine.partipns -d?e
prpja
baawe they do not avnrlag gwgraphi~ally.TOwdd@stmdcmulativo b p ~ta twildlifeJ
~
i n f o m i a n mi boih the ~ m i s d o lixi0
n and wind tmhine projects needs to be imlud& in M s
section.
In swixdqbwe find that the DEE does mt contain adequate hfmaEion regadiag pomial
hp&ts of the pe@&
an wildlifeyand additiofd mvhomfital review is necessary1 Baseline
Xopnation ~n biologid reso-wesis incomplete,~e omi#&. Dataare lacking far w m p t e t e
~derstmdjngof @rig,
br&ing, aird wintering birds. Surveys d h g the migmtion and
breeding mmm were conducted for only 1 year.
Qvmdl,we Fmd that insuEdent data wete wlkcted at the pMe& sit^ b determine the bpaiid
an4 temporal uv afthe pmj& ,airspace<
by flying mim,as.\( 3recpmmdatiorn
~
f;ar wildlife
studies at wind prbjects generally sp&&
that datd he collected over multip~~seasom
&id j f m s
to ddewnin-eaverage annual aonditbns. Because of v&biliq in migration a d mqther4
~allwihgdata f ~ 1r year likely d ~ e not
$ rdwt typical wildlife u s b the project m a
Therefom, 'we find that im&ci;ent.data cm@g exist to adetpitely Conduct a rlsk assesm'mt
md pfedi~twildlife m~ftdityfmthis p r ~mt,
j
The,Wim&m-&
b t all w i d power pfojects that proceed to wmtru&ion&buld l~
monitored fwimpacts to wildlife fallowing cons@u&onmd during turbine opetation.
Post-wnstrudbn bat and bird m o ~ i t monitor*
y
sRoa o m for a miisimufll of 3 years.
Propsds for e~ncfudingmonitoring should b aoodmted with Ba* the Serrlce arjd eE?e
NBDEC to emure b y m ~:ompehmive,mmtq,a d -tly
timed. Inftlnnatian gained
from posGCbnSti116tio~rnt)~I&~& will con.tim10 aid fie %rvicbkd pt$ect s'ponsd a%: We
lem more about potential i n i p ~ &or
~ lack thereof, to wildlife in the pmje~tma.We
reammend that gmJ~ctappro.al not be g i v e until a t h the d&&b,sfthepost-~mstsw:ti~n
Jhdtoring plan have b e n re~ik& and a p p r M by&e Bewke and the NYSDEC, Furtl~er,we
racammend o,pera~opd
modificatiws he mmdqiwy during hw wind a p e d nights between
Jrtly f5 ,adSegbinb T 5 mitigate predict&$im@ek ta kts.
Please contact Timothy R. Sullivan at 607-753-9334 if there, are any questions regarding this
&m*.
Sincerely,
David A. Stilwell
Field Sypervisor
References:
Arnett, E.3. (ed). 2005. Relationships between bats and wind turbines in Pennsylvania and
West Virginia: an assessment of bat fatality search protocols, patterns of fatality, and
behavioral inteaions with wind turbines. A final report submitted to the Bats and Wid
Energy Cwperative? Bat Conservation International. Austin, Texas.
Amett, E,B., M. Schirmacher, M.M.P. Huso, and J.P. Hayes, 2009. Effectiveness of changing
wind turbine cut-in speed to reduce bat fatalities at wind facilities. An annual repart
submitted to the Bats and Wind Energy Cooperative. Bat Conservation International.
Avery, M.L. (ed). 1 978. hpacts of trrnmission lines on birds in flight: prbceedifigs of a
workshop. Oak Ridge associated universities, Oak Ridge- TN. January 3 1February 2, 1978. U .S. Fi~b~.&~Wd1fifqS~Mce,
Bial~gicalSewias Program
FWSIOBS-78/48. 15 1pp.
EIA (Energy Information Administration). 2004. Form El&-i4Y%U'iD'ahbase:
2004 Annual
Electric Generator Repart. Energy Information Administration, U. S . Department of
Energy [online]. Available at: http:/lwww.eia.doe.g~v/~neaf/electrieity/pageIei~86Q~
htm1
EIA
.-.-=
(Energy
.
Information Administration). -2806, Annual Energy Review. DQEmA0384(2005). July 2006 [online]. Available at:
http://~.eia.doe.gavIemeu/aer/eleck.
ktmlEIA 2006
e
EL4 (Energy Information Administration). 2 0 0 9 ~U.S. Electricity Use Data Report. Energy
Infomation Administration, U.S. Department of Energy [onIhe]. Available at:
h~://www.eia.doe.gov/fuelelectric.
htd
EM (Energy Informatioh Administration). 21303b. Electric Power Annual 2007 Report. Energp
Information Administration, U.S. Department of Energy [online]. Available at:
http://www.eia.doe.gov/cnea-El~lec~ci~/epdepa~sprdshts.
html
Environmental Protection Agency. 2009. Clean Air Markets - Data and Maps, Available at:
http://camddat~dmaps.ega.gov/gM~~d,~~~~fm?fu~ea~tion=emissi~~.quickreport~
output
Gerhring, J. 72006. Michigan State Police Communication Tower Study: Resulfs Applicable to
Wind Turbines. Toward Wildlife-Friendly Windpowes Conference. Toledo, OH
Research Council.
-qatignal
,s-,
,%
RahdKesoup~:es
Conservation Servli;Le. 2003. ~onservationFractke "s"tm&& % e m
Crossings ftp:i/~p-fc.sc.~ov.usda.govlNHQlpractice-s~ndar~istandardd5~8.pdf
&w,York State Deparhent of Errviranmexltal Consemtion. 2009. Final Guidelines for
Conducting Bird and Bat Studies at Commercial Wind Energy Projects.
,
Albany, NY
c
w
,k
.7
,..
F-
Sincerely,
Jim Howe
Executive Director
The Nature Conservancy
Central and Western New York Chapter
585-546-8030, ext. 26
jhowe@tnc.org
Regardless, even with the presumed ongoing presence of a natural predator (the coyote)
after any deer culling has been done, history suggests that in absence of continued hunter
harvest and/or extreme winter conditions, the deer population will rapidly rebound to
high levels. Indeed, I believe it is likely to soon exceed any reasonable carrying capacity,
whether or not there is a total loss of the agricultural crops historically cultivated to
provide whitetail forage. This almost assuredly risks a loss of floral (and possibly faunal)
biodiversity, potentially including at least some of the threatened/endangered species
mentioned in the draft EIS.
While I would hardly suggest the whitetail is "native" to Galloo Island, it presumably is
now the single most impactful species on that ecosystem. As such, I believe it prudent to
develop a plan for ongoing hunter harvest of deer, particularly if agricultural
subsidization and supplemental feeding of the herd are soon to cease.
Yes, I understand the issues involved in allowing the public some level of access to a
major power installation, even under highly restrictive rules. However, I have seen
bowhunting in particular be tremendously effective in controlling deer numbers in similar
situations. For example, I was involved for a number of years with the special herdcontrol bowhunting program at Clinton Power Station in DeWitt County, Illinois.
Knowing how the hunt at this active nuclear power plant was set up and administered,
and having seen how effective it was at reducing whitetail damage to the habitat while
simultaneously fostering goodwill in the sporting community, I consider it a textbook
example of industry, state government and the public working together toward a mutually
beneficial goal.
Please accept my observations for the record during the public comment period on the
Hounsfield Wind Farm project, and feel free to contact me at any time regarding further
developments with this deer herd. As a staunch professional and personal supporter of
sound wildlife management, I only want to see the Galloo Island whitetail story move
forward on a positive note for all concerned.
Sincerely,
Gordon Whittington
Editor in Chief
North American Whitetail
2250 Newmarket Pkwy., Ste. 110
Marietta, GA 30067
678-589-2034
gordon.whittington@imoutdoors.com
www.NorthAmericanWhitetail.com
-2-
invasive plant species. This invasive species is found throughout the island and wherever it is
found it dominates and out-competes all other ground cover plants important to wildlife species.
The Invasive Species Control Plan included as Appendix M in the DEIS fails to mention pale
swallow-wort and the measures needed to manage this invasive species. Measures proposed to
remove and control the spread of this invasive plant within the project development area should
be described and included in this plan. Additionally, a survey should be conducted to quantify
the current areal extent of this species on the property under control by the project sponsor.
-3-
and September. This deficiency should be addressed with additional breeding bird surveys. On
page 3 of this report, it states that the objective is to collect baseline breeding species data that
can be compared to similar data collected after construction to determine the project impacts.
That is one of the objectives, but another objective is to collect breeding bird data so we know
what species are nesting there or utilizing the area and determine how we can avoid impacting
the species especially when we consider endangered and threatened species. An additional
limitation to this study is identified on page 10, where it states, Weather conditions on Big
Galloo tend to be windy and limit the range of acoustic bird surveys. While several of the
mornings in which this bird survey was conducted had substantial wind and surf noise, and
therefore limited acoustic survey capabilities at some point counts, the bulk of the point counts
and transect surveys in this study were carried out under good bird survey conditions.
Additional point counts need to be conducted to offset the number of point counts conducted in
these poor survey conditions.
The project sponsor has provided a work plan for an additional Breeding Bird Survey to
be conducted in 2009. In a memo to the project attorney dated 06/08/09, DEC concurred that the
scope of this plan, which includes a Breeding Bird Survey and an additional Diurnal Bird
Movement Study, is satisfactory to provide supplemental information necessary for DEC to
assess avian impacts for these resources.
On page 9 of the BBS, there is a reference to the large number of snakes on Galloo
Island, which may act as an impediment for successful colonization of small ground-nesting
birds (e.g., Grasshopper Sparrow, Vesper Sparrow, Ovenbird), which are fairly common
breeders on the mainland adjacent to the island. Further discussion should be included regarding
the basis for this conclusion, including the species of snakes observed and the number of snakes
observed. Additionally, describe if any formal survey methods (such as herpetofauna surveys)
were used to identify the type and number of snakes.
-4-
-5-
not allow for the trap-and-transfer of coyotes. In addition, this is not a well thought-out
recommendation. What will keep these mammals from leaving the island? Even if they did target
voles and not the ground nesting bird species, what happens when the vole numbers decrease?
Also on page 21, the statement that the overall effect of the wind project (including the
transmission line corridor) will increase habitat for these species (Upland Sandpipers and
Northern Harriers - both NY threatened species), and potentially benefit their status in the region,
needs to be supported by a more thorough rationale. For example, does the project anticipate
clearing large patches of habitat and managing them for grasslands? It is also recommended on
Page 22, Eliminate agricultural operations at the north end of Galloo to reduce or eliminate
foraging areas for Canada Geese and migratory shorebirds. This action might presumably
decrease the amount of grasslands on the island and reduce habitat for these species. These
recommendations should be revisited in light of these questions, and be discussed in the context
of an overall habitat management plan for the island (see State Lands and Open Space
Conservation Plan, below).
-6-
The design report additionally states that a screen would be installed on the end of the
pipeline intake to prevent seaweed or fish from being drawn into the pipe. The screen would be
constructed of a metal alloy that is designed to resist biofouling by zebra mussels or other
nuisance plants or animals. Eastern Lake Ontario is a prime spawning area for lake trout, walleye
and alewife, and the proposed water intake location is important in particular due to the offshore
shoal created by the island. DEC will require a water intake screening system with no greater
than openings and intake velocity of foot/sec or less, to prevent impingement of juvenile
fish into the system. A screen of this size is likely to require periodic cleaning to maintain water
flow.
Exhibit 4 Environmental Impact of the Upstate NY Power Transmission Line Article VII
Application, 4.6.7 Subaquatic Cable Construction.
It is stated in this section that construction of the subaquatic cable will be conducted by
jet plow embedment in the bottom of Lake Ontario and details regarding the installation of the
subaquatic cable and associated transitions are provided within Exhibit E-3. This exhibit should
be included as an attachment to Exhibit 4. Additionally, during a recent conference call with the
project sponsor, it was stated that due to concerns for thermal dispersion, the project will involve
placement of four smaller subaquatic cables rather than one larger cable. Placement of four
cables would result in 4X the disturbance of sediment than a single cable route. This needs to be
addressed further and associated impacts of multiple cable routes analyzed in greater detail.
-7-
automatically and immediately revert to the United States, etc. Any uses of the DEC lands on
Galloo Island for the wind project would not be for wildlife conservation purposes and therefore
would not be consistent with the terms of the deed. On page 2-62 of the DEIS, it states, Galloo
Island has been identified in the New York State Open Space Plan as a part of the Great Lakes
Shorelines and Niagara River priority conservation project area. (NYSDEC et. al., 2006). The
2009 New York State Open Space Conservation Plan, released June 2009, continues to list
Galloo Island as an important natural resource. On page 102 of the Plan, it states, Galloo Island,
the largest undeveloped island in Lake Ontario measuring approximately 3 miles by 1 mile
or 1,934 acres is just one of the undeveloped islands worthy of attention. DEC has in the past
expressed interest in acquisition of Galloo Island but was not able to negotiate terms sufficient to
carry out this plan. Nonetheless, DEC continues to hold interest in exploring opportunities for
wildlife conservation, public use and access of existing state lands on Galloo Island consistent
with the management objectives of those properties, and other opportunities that may be
available for overall management of the island consistent with the Open Space Conservation
Plan.
DEIS Appendix G, Operations and Management Plan, identifies a number of
environmental factors to be considered during the operational life of the facility, including
restoration, maintenance, repairs, decommissioning, spill management, wetland mitigation
management, invasive species management, and ice management. DEC typically recommends
that all wind projects consider creation of additional environmental enhancements during the life
of the project beyond those required for restoration and mitigation, through cooperative
partnerships with landowners, local governments, educational and conservation organizations.
The Galloo Island project is unique in that the entire project development area will be under the
control of the project sponsor and, being a resource identified as worthy of attention in the Open
Space Conservation Plan, provides an unparalleled opportunity for a cooperative arrangement
between the project sponsor and DEC in the development of management plans for the island
that accomplish the objectives of the project sponsor, promote activities consistent with the Open
Space Plan, and further the resource management objectives of the Department. These may
include invasive species management and control, grassland/forest management for wildlife
conservation, and limited public access for safe harbor, educational or recreational purposes.
DEC will continue discussions with the project sponsor to identify specific opportunities for
cooperative management, and will include a commitment to engage in this process as a condition
to permits issued for project construction.
-8-
Whereas typically wind farms are located primarily on leased private land, the Hounsfield Wind
Farm is proposed to be located on land wholly owned by the project sponsor. Therefore the
entire project development area would constitute a Facility for purposes of this regulation. The
main difference between this situation and a typical wind power project is that anyone with
knowledge of spill event is obligated to notify DEC according to established reporting
procedures (see Sec. 2.7, below). This includes contractors or other personnel who may not be
directly employed by or represent the project sponsor.
Page 1-2 states that, Even though the facilitys total oil capacity will be greater than
42,000 gallons and it will receive oil over water, the checklist in Appendix A determined that the
facility will not require a Facility Specific Response Plan (40 CFR 112 Appendix F) because the
ASTs are greater than 1.8 miles inland from the slip, and the amount of oil transferred over water
is less than 5,000 gallons per week. DEC has contacted the U.S. Coast Guard to get a clearer
understanding of this regulatory requirement, and will provide additional guidance following this
consultation. However, somewhere between a few 90-gallon spill kits and a full-blown FRP, the
facility needs to maintain appropriate resources for response to significant spills. Spills may
occur due to accidents with fuel delivery vehicles, even when the actual transfer of fuel is not in
progress.
Page 2-1 Sec. 2.1 Definitions This section should cite Article 12 Navigation Law and
should include its legal definitions of petroleum and discharge.
Page 2-2 Listing of stored petroleum This section lists (5) 6,000 gallon above ground
tanks. All tank storage of petroleum will be regulated by PBS Regulations at 6 NYCRR Parts
612-614, and must be registered with the Department. Tanks must meet SPOTS (Spill Prevention
Operations and Technology Series) Memo #14 for secondary containment requirements due to
the proximity to surface waters. The Department accepts four specific double-wall above ground
tank models as complying with this requirement. These models are specifically designed to
provide overfill protection. Most double-wall tanks do not meet this standard. Although the plan
does not specify the tank model, the description of the tank systems appears to be of a type that
does not comply with DEC requirements. This should be clarified, and/or changed to meet DEC
requirements.
Page 2-3, Sec. 2.7 The correct local phone number for NYS DEC Spill Response is
315-785-2513. DECs preference is to strike this number for any part of the SPCC Plan that
discusses proper reporting procedures. The only number that should be used to report a spill is
1-800-457-7362.
Page 4-1, Sec. 4.1 describes potential routes for spills to reach surface water. This section
neglects the potential for spills to follow a subsurface path, either directly to surface water, or via
groundwater migration. State regulations clearly address spills to the land and spills to
groundwater, in addition to spills to surface water.
-9-
Page 4-10, Sec. 4.10 This section states that drums are not refilled. What about used
motor oil? If equipment will be maintained on the island, drums will be filled with spent
petroleum. This should be clarified or revised as appropriate.
Pages 4-12 & 13, Sec. 4.12.1 The term Discharge, as it is used in this document, does
not conform to the definition in Article 12 Navigation Law. In addition, the PBS regulations use
a distinct definition for Spill. Reporting of discharges is discussed further in the appendix on
page 83 of 92. The Departments guidance states, All petroleum spills that occur within New
York State (NYS) must be reported to the NYS Spill Hotline (1-800-457-7362) within 2 hours of
discovery, except spills which meet all of the following criteria:
1. The quantity is known to be less than 5 gallons; and
2. The spill is contained and under the control of the spiller; and
3. The spill has not and will not reach the State's water or any land; and
4. The spill is cleaned up within 2 hours of discovery.
A spill is considered to have not impacted land if it occurs on a paved surface such as asphalt
or concrete. A spill in a dirt or gravel parking lot is considered to have impacted land and is
reportable. Therefore, ALL spills to the land are reportable. Essentially, the only spills that do
not need reporting are those spills <5 gallons that are to a properly designed and maintained
secondary containment system AND which are cleaned up within two hours.
Additional Comments:
1.
The SPCC Plan does not describe a Spill Kit in detail. A typical spill kit uses a 90gallon poly overpack drum (which can be used to pack a standard 55-gallon drum
inside), which is filled with absorbent booms, pillows, and/or pads, safety glasses, and
gloves. The potential for large spills exists both in the construction and operation phases
of the project. In lieu of a full-blown Facility Response Plan, the SPCC plan should
describe, in a reasonable level of detail, the resources available to respond to these spills.
Due to the location of the facility, it is unlikely that contracted spill response services can
arrive in a reasonable time frame. Some of the equipment and materials that should be on
hand include:
Vacuum Truck (minimum 3,500 gallon) Though expensive, this is a critical piece of
equipment needed to respond to any spill larger than 100 gallons, and the facility should
consider having one available on site at all times.
If this equipment is not immediately available, spills that reach the water will likely be
unrecoverable.
2.
The cleanup of spills at the facility will result in the generation of cleanup debris (oil
soaked booms, pads, speedi-dry, soil, etc.). Generally the owner is allowed 60 days to
effect proper disposal, provided the debris is stored properly. It is recommended that
provisions be made for the storage of a rolloff container stored in a pole barn or under a
pavilion. This would allow for accumulation of small quantities of debris as it is
generated, and then hauling the rolloff for proper disposal. In addition, it may be a good
idea to provide a 6,000 gallon tank for waste liquid containment and storage.
3.
4.
While the SPPC Plan describes containment for above ground storage tanks, this
containment does not protect against all types of spills, especially delivery
overfills. The Plans should provide specific tank models and installation plans.
The Plan does not reference containment for the fuel delivery vehicles. The
greatest chance for spills is during product transfer. Federal SPCC requirements
may include secondary containment for the delivery vehicle.
Spill Reporting and Documentation: DECs experience with other wind farms shows that
spills can be expected during the construction and operational phases. Though many of
these spills may be small, they must be properly reported, cleaned up, and documented.
The DEC Regional Spill Response Unit lacks the resources to respond to Galloo Island to
oversee the cleanup of every spill. Therefore, the project sponsor must develop
procedures for DEC approval that address proper reporting, cleanup, and documentation.
This includes a requirement to keep a written summary that includes Spill Date, Time,
Product, Quantity, GPS Location, Debris Quantity, Confirmation Sampling Results, and
Disposal Confirmation. This information should be made available to the Department in
ESRI GIS format with a geographic data and data tables.
-11-
-12-
Comments Received
During Public Comment Period for
Permits Submitted to DEC
The Scoping study offers very little information about the single 230kV
transmission line that is now planned to intersect our Town, plus now
proposed to handle two 230kV transmission lines. The scoping study also does
not offer any alternatives of consideration of a subaquatic transmission
line more directly to the NYS Power Grid, avoiding the intersection and
destruction of historic, agrarian and recreational use lands in several
townships. Also, the scoping study promises view shed simulations from at
least 10 vantage points which are not offered in the DEIS, including many in
our Township.
We are gravely concerned about the information that is not available,
attainable, or part of the public record. It will take additional time to
liaise with the DEC and PSC to adequately provide our concerns.
We appeal to your office to allow our Town, which will be devastated by this
project, to have adequate time to state our concerns.
Thank you for your consideration of this request.
Yours truly,
November 10,2009
Memorandum To:
Stephen M. Toms&
NYSDEC Headquarters
625 Broadway
Albany, WY 12233
Copy to:
From:
Subject:
The Heart of Henderson organization is writing this letter to request a six-month extension to the
comment petiod, extending the W i n e h m the current December 4,2009 to the requested
June 4,2010.
As a small community only recently having become an 'interested partytin the Hounsfield Wind
Power Project, we find omelves in the unenviable position of having to analyze a very large and
complex amount of data. Since we are so newly an 'interestedparty' due to circumtaaces
beyond our control, we are Hsking to have time to review all pertinent information.
We have many concerns not the least is the the review of the huge amount of DEIS material as
mmpad to the Public Scoping Docurnent initially published in draft form on May14,2008 and
finalized September 17,2008. The process of comparison is massive, considering that the Wind
Project is under the auspices of the T a m of Howfield jurisdiction and the T m s s i o n Line is
considered a Type I1 action under SEQRA. Very little information is available to tba Town of
Henderson.
The Scoping study gives little information about the single 230kV trammission line that has been
pmject.
Thank you for your considmation of this matter.
Margaret Golovey
Heart of Henderson
hcat1365O@yahoo,com
To:
November 16,2009
Jehv stbcilth_Qlrn~.s~-n~-us
Honorable Kevin J. Casutto -Administrator Law Judge
Kev~nc a s u ~ ~ ~ . s t nv.us
ate.
Mr Andrew Davis DPS Project Manger
Andrew DaV!s@dn&state.nu.us
To:
s t m a d ~ 7- -& -a . -n~dg
~ Y
From: Henderson Harbor Area Chamber of Commerce
Economic Development Committee
SUWECT:
This letter and its attachment are entered into the public record of the November 16, 2009 Public Hearing an subject case,
hosted by the DPS in the Town of Henderson and shall be made part of the permanent Case records.
Our Board and the business members we represent are opposed to the project adjoined with Case 09-T-0049 and find
many sources of expected negative socio-economic benefit if the DPS determines public need of said Case. We also are
opposed to the project based on the environmental incompatibility when considering the ecological and environmental
resources that will be devastated, damaged, or irreversibly altered.
After review of the published data associated with this Case, as well as VVTG project DEIS, and data available from
knowledgeable third party reference sources, we are very concerned about the negative impact to our area's delicate
economy, highly dependent on tourism, recreation and agriculturat sectors, should the subject project proceed. The need
fur dependable alternative energy is very important, but not at the expense of negative socioeconomic ham leff in the
wake of developers, such as Upstate NY Power Corporation.
We have studied knowledgeable reference sources such as, Beacon Hill Institute's Cost Benefit Analysis of Wind Projects
and Appraisal Group One Wind Turbine Impact Study to postulate the extent of negative socio-economic impact to our
business members and to this diverse area commonly referred as the Golden Crescent. The attached letter from one
business member, Association island RV Resort and Marina, LLC is attached and made part of this letter. This business
is one of the highest assessed properties in Henderson, physically the closest to the W G project, the majority of the
subaquatic cable, and the landing point of the subaquatic cable. Ms. Shim's letter summarizes many points very well, that
substantiate the project developer's ineffectiveness in their project data to recognize the economic impact to the Town of
Henderson, and in some case recognition at all. The main points of her letter clearly outline the irreparable economic
harm they we will be faced with should this project proceed. The overall effect will be the reverse of Economic
Development that our Chamber of Commerce is promoting - resulting in economic sunrival. The developer provides no
indepth economic impact analysis in their project data, and we respectfully request this data be provided for the benefit of
review by the DPS, DEC and the affected Towns. The decision by our New York State lead agencies should be
delayed, until which time adequate factual data can be provided by the developer and analyzed by said parties. If b i s
project is as robust technically and camrnercially as the seasoned developer Upstate MY Power claims in their project
data, this request should be easily and timely submitted.
The creation of jobs and supply chain associated with the construction of this project is also an unknown benefitlimpact.
The W G project will have many components from foreign sources, or supplied within the developer's overall corporate
structure. This is a contentious issue, one which has received national attention, especially the recent request from
Senator Schumer to halt a project in west Texas due to large Federal subsidy essentially creating jobs on foreign shores.
We implore the DPS to consider both the VVTG project and the transmission line construction as one project when
determining job creation, effective use of federal money and long-term economic impact to the host area.
Today, you will also hear from our Chamber President, Mr. Karl Williams, who will read several other member letters, and
a Town of Henderson Planning Board member, Mr. Bob Ashodian. The latter will discuss in depth the synergy between
the Economic Development Committee and the Town of Henderson Comprehensive Land Use Plan, developed at
substantial expense and forethought as to the quality and character of development that closely matches our areas
presetvation of resources and future business expansion plans. The proposed project will severely harm our ability to
follow our Town's Plan for Economic Development, limit our Committee's ability to attract or maintain business, and
degrade our tax base by an expected sharp decline in property values, and thus business viability.
Regarding the agricultural and dairy industry, prevalent in the area, and essential to the routing of the proposed Upstate
NY Power Corporation's transmission line, we have interviewed several farmers, a few of which are candidates for the
routing of the transmission line. Overwhelmingly, their feelings to this project are very negative and considered a personal
attack on their freedoms, as a small family owned business owner. They cite disruption to their crops and livestock as
highly probable outcomes, both of which may force several of these businesses to the brink of extinction. We understand
from these interviews that the small subsidy they would receive for either lump sum settlement or lease payments would
be outstripped several fold by loss of revenue due to decreased milk production. Jefferson County has prided itself on its
well-established dairy and agricultural industry a decision to allow this project to proceed would undo two centuries of
blood, sweat and tears building a proud legacy of these farms passed from parent to child and so on.
If this project proceeds, we will be faced with an irreversible and devastating effect to our environment, local business,
dairy and agricultural economies, a degraded tax base and sharply declining real estate value. We ask that NYSDPS
rule against the public need for a 5Q.6 mile transmission facility associated with Case 09-T-0049.
Sincerely,
4,/&
C,- t +,-& d t p Robert E. Aliasso, Jr.
'
Economic Develop Committee Board Member
-7
flT..
--
Attachment: November 16, 2009 letter from Association Island RV Resort and Marina LLC
1 W51-0468
From: <DDopeters@aol.com>
To: <smtomasi@gw.dec.state.ny.us>
Date: 11/22/2009 8:32 AM
Subject:
Galloo Wind Farm
Stephen Tomasik
NYS Department of Environmental Conservation
625 Broadway - 4th Floor
Albany, New York 12233-1750
PH: (518) 486-9955
FAX: (518) 402-9168
_smtomasi@gw.dec.state.ny.us_ (mailto:smtomasi@gw.dec.state.ny.us)
Please consider this request to extend the public comment period for the
Galloo Wind farm. I believe the developer did what was legally necessary to
complete his DEIS, but I also believe that many people were not aware of
the time line and the activity going on for the past couple of years. Why did
this project not receive more press? How many people attended the
meetings? Were the people who own camps in the view shed informed? Was the full
intention of expanded development revealed, i.e. wind farms on other islands
and in the offshore waters in the "Golden Crescent"?
I've just started to review the documents on line and it will be a time
consuming event to thoroughly review them all in detail. Please consider this
request to extend the review period so I can have more time to review and
to allow concerned citizens to notify stakeholders of the impending
development.
Donald Peters
126 Circle Road
Syracuse, NY 13210
From: <OLESALTD@aol.com>
To: <smtomasi@gw.dec.state.ny.us>
Date: 11/23/2009 10:02 PM
Subject:
Request to Extend Public Comment Period for Hounsfield (Galoo) Wind
Farm Project
To:
Stephen Tomasik
N Y S Department of Environmental Conservation
625 Broadway - 4th Floor
Albany, New York 12233- 1750
pH: (518)486-9955
FAX: (518) 402-9168
smtornasi@gw.dec,state.ny.us
Re: Request to Extend the Public Comment Period Hounsfield Wind Farm Project
Please extend the public comment period on the Hornsfield Wind Farm Project (Gdloo
Island) by six (6)months. I arn not registered as an interested party, but I surely have an
interest in this massive project that has come to my attention only within the last few
weeks. Like many others in this community, I have suddenly realized this project is well
along in the approval process and will have an enormous impact on me personally, and
the ecology, history and economy of this region. Our most significant natural resource,
the very reason I live here, is at stake.
The reasons why we were not Mly aware that this project was so far along in the
approval process are many. Regardless ofthat issue, a thirty (3 0)day public comment
period is simply not sufficient for me or my community to evaluate the impact.
I urge the DEC to extend the public comment period which is scheduled to end on
December 4,2009, by six months, to June of 2010.
Copy to:
From: <DBald31624@aol.com>
To: <smtomasi@gw.dec.state.ny.us>
CC: <Bashodian@aol.com>
Date: 11/25/2009 3:14 PM
Subject:
Galloo Island Wind Power Project
Dear Mr. Tomasi,
My wife and I are members of the Henderson Harbor Yacht Club and over the
years have spent a considerable time boating in the so called Golden
Crescent part of Lake Ontario. The beauty of this area is unsurpassed.
Recently it has come to our attention that a significant wind power and
transmission line project is proposed for Galloo Island and environs. I am
writing to respectfully request that the time for comment to the DEC on this
project be extended for at least 6 months to provide a fairer opportunity
for every concerned person to more fully study the implications of the
proposal and make their informed comments known to the DEC before an irrevocable
decision is made.
Thank you for your consideration.
Sincerely,
Dennis and Gail Baldwin
From: <Jweber7@aol.com>
To: <smtomasi@gw.dec.state.ny.us>
Date: 11/27/2009 10:19 AM
Subject:
Galloo Island Wind Farm Project
Sir,
Please agree to a 6 month extension to the Galloo Island Wind Farm Project.
The importance of this project deems it necessary to extend time for
public comment.
.
Thank you,
James & Barbara Weber
To:
Stephen Tomsik
N Y S Department ofEnvironmental C o m a t i o n
625 Broadway 4th Floor
Albany, New York 12233-1750
pH: (518) 486-995 5
FAX: (5 1 8) 402-9 168
s~masi@gw.dec.state.ny,us
Re: Request to Extend the Public Comment Period Houmfield Wind Farm Projet3
Please extend the public comment period on the H o d e l d Wind Famx Project (Gatloo
Island) by pix (6)months. I am not rudered as an i n t d party, but 1 surely have an
Wht~s&eplrojeEththm~~qEittentiQElewitbnthefa&h
w&.
Like many 0 t h ~
in ~
this mmmdy, I have d d d y r d i d this project is d
l
dong in the approval process and d l have m efiormomimpact on me p s m d y , and
the d o g y , Wary a
d ecwnamy of this region. Our must significmi mural r m c e ,
the very F ~ S U Z II live h e , isat d e .
~ ~ s ~ y w e m f l O t ~ U y a m e t h a t t h i s p e o j msofardong
was
inthe
qpmdptmsmmany. ~ & e s a o f t h ; a t i ~ a ~ ( 3 0 ) d a y p l b ~ c o ~
period is simply not d c i e n t fm me or my cornto evaluate h e impact.
I r q e the DEC to extend the public comment perid which is scheduled to end on
r k e m k 4 2009,by six lncmh, to Jim of2010.
Copy to:
From: <dbgamble@westelcom.com>
To: <smtomasi@gw.dec.state.ny.us>
CC: <dbgamble@westelcom.com>
Date: 11/27/2009 8:59 AM
Subject:
Extension of Comment Period
Mr. Tomasik:
I strongly urge you to extend the public comment period for the Galloo Island wind
power project to allow more people to express their views on this enormous project. If
build, this wind development project will forever change the quality of life and the vistas
that the people of Jefferson County and the many thousands of people who come to our
area have come to enjoy. It seems to me that there must be areas, even in Jefferson
County, that could be potential sites for such development that would not have such a
negative impact on the economy, tourism and quality of life. Please extend the public
comment period, so as to allow a full consideration and discussion of the scope of such a
development. Thank you.
Robert Gamble
Henderson Harbor, NY
From: <dldp@frontiernet.net>
To: <smtomasi@gw.dec.state.ny.us>
Date: 11/28/2009 8:22 PM
Subject:
Galloo Island Wind Farm Project
Dear Sir,
Please extend the public comment period to allow local residents to research the impact.
thanks
David Poulin
12962 County Rt 123
Henderson Harbor, NY 13651
Sir;
As a summer boating resident of Henderson Harbor, NY for the past 28 years I
request that you extend the Public Comment Period regarding the project for
six months.
Respectfully
Lee T. Cagwin
From:
1.
Through our continued review of the very complex subject project,
we note an abnormality that we request be investigated. This project, when
considered cumulatively with the other five (5) Jefferson County projects
(see attached Interconnection Request for Jefferson County), and the public
HHACC-EDC
NOTES: * *The column labeled 'SP' refers to the maximum summer megawatt
electrical output. The column labeled 'WP' refers to the maximum winter
megawatt electrical output.
*
*Availability of Studies Key: None=Not Available, FES=Feasibility Study
Available, SRIS=System Reliability Impact Study Available, FS=Facilities
Study and/or ATRA Available
*
*Proposed in-service dates are shown in format Year/Qualifier, where
Qualifier may indicate the month, season, or quarter.
**
Z
*
*The column labeled 'Z' refers to the zone
*
*Type / Fuel. Key: ST=Steam Turbine, CT=Combustion Turbine, CC=Combined
Cycle, CS= Steam Turbine & Combustion Turbine, H=Hydro, PS=Pumped Storage,
W=Wind, NU=Nuclear, NG=Natural Gas, M=Methane, ST-SW=Steam Turbine-Solid
Waste, S=Solar, Wo=Wood,
F=Flywheel ES=Energy Storage, O=Oil, C=Coal, D=Dual Fuel, AC=AC
Transmission, DC=DC Transmission, L=Load
**
Proposed In-Service
*
*The column labeled 'S' refers to the status of the project in the NYISO's
LFIP. Key: 1=Scoping Meeting Pending, 2=FES Pending, 3=FES in Progress,
4=SRIS/SIS Pending, 5=SRIS/SIS in Progress, 6=SRIS/SIS Approved, 7=FS
Pending, 8=Rejected Cost Allocation/Next FS Pending,
9=FS in Progress, 10=Accepted Cost Allocation/IA in Progress, 11=IA
Completed, 12=Under Construction, 13=In Service for Test, 14=In Service
Commercial, 0=Withdrawn
nyiso_interconnection_queue Jefferson County Updated: 10/28/2009
*
To:
srntoma-w
l/Copy To:
nv.mi
From:
Subject:
1. Through our continued review of the very complex subject project, we note an abnormality that we request be
investigated. This project, when considered cumulatively with the other five (5) Jefferson County projects (see
attached Interconnection Request for Jefferson County), and the public agency announcement by NYPA of an
additional 1,000 W G , should be considered under the New York State Environmental Quality Review Act
regulations, Part 617.7.(c)(l)(xii) as a whole. Specifically we cite "two or more related actions undertaken, funded
or approved by an agency, none of which has or would have a significant impact on the environment, but when
considered cumulatively would meet one or more of the criteria in this subdivision".
We ask the NYSDEC to complete the impact analysis to their satisfaction, as to the cumulative effects of these
multiple projects as suggested in SEQRA Part 617.7.
2.
Portions of Galloo Island are included in the NYSDEC Open Spaces Plan, as are close proximity islands, Little
Galloo, and Gull Island. How does this affect the request by the developer, Upstate NY Power Corporation to
completely cover Galloo Island with an industrial VVTG complex? Has the NYSDEC modified their Open Spaces
Plan to accommodate the substantial industrial complex cited very close to three (3) notable sites?
HHACC-EDC
December I , 2009
3. Several years ago, the NYSDEC considered purchase of Galloo Island and proceeded with a final negotiation that
did not result in the purchase. During the NYSDEC review of Galloo Island leading up to their purchase offer, we
understand from discussions, the island was considered, 'fragile and delicate" and shall remain in its current
state. Has this previous determination and review by the NYSDEC been considered, or made available to the
present NYSDEC evaluating team? If so, has the NYSDEC found new information to consider the island suitable
for an industrial WTG complex?
Thank you for your consideration of this new request, which does not modify our previous request for a six (6) month
&
L
1c ' & a / m d
Attached: lnterconnedon ' ~ e q u e s kand Transmisshn Projects - Jefferson County (Source NYISO)
of lR
SP WP Type1
(MW) (MW) Fuel
Locatlon
CountylState
lnterconnectlon
Polnt
Utlllty
~~~t
AvaHablllty
Update of Studles
Proposed In-Servlce
Orlgtnal ) Current
Jefferson, NY
NM-NG
ID
Clayton Wind
418105
126
126
Jefferson, NY
NM-NG
2006122
2010112
1/12/08
210
210
Jefferson, N Y
NM-NG
20091Q4
20091Q4
250
250
NM-NG
10114108
FES
2010112
2010112
NYPA
911109
FESISRlS
2010109
2010109
207
611107
W M
JeRerson. NY
Jefferson,NY
911109
SRlS
2006112
2009112
The cdurnn labeled ' S f ' n r h s to :he rnafJmurnsumme~mEgawattelectric#! ovlput. The column labeled 'Wf' relea to the maximum *~nlsrmegavial1 ekctrtcat w!pui
Tfp9 / Fusl Key. ST=SMsm Turbme. CT=CmhusDon TurMns. CC=Combimd Cycle, CS=Steam Tvhine & ComSvstion Turbive, H ~ i f f d m PS-Pvmssd
.
Slornge. WWod, FIU=Nvcl8sr. NG=Nstufal Gss. M.MefhsTe.ST-SWzSream Turnme.Solid Waste. S d o h f . Wo=WDD11
F=Flywheel ES=Eflergy Slurage, O=W C=Cbal, D=OuslFoel.AC=AC Tlsvsm1$61on,DCsDC Transm~ss~on
L=Load
Tha colurno kbeW '7refers lo the zone
a T h column labeled 'S'mfers lo :he ststus o: :he pqecr 1n !he NYlSOh LFIP, Key, l=scopog Meehog Pend~ng.2 F E S Peodty, 3 z F E S in Pmgrsas, d=SRIS/SIS Pend~ng.5=SRIS.SlS In Prcgress. fi=SRISIS/SAppm&. 7=FSPerd~ng8=Re)sd& Cmt AJbcatmn/NexfFS Peodhg.
S=FS in Pfcgrass, IO~AccepredCast Alloca!~on~lA
In Pregfess. 7 1 =/A Completed, rz=undsr Cwshvctton. 13.117 Service tor Tesl, 14=ln Serv~ceCommercst, O=W~!hdrawawrr
AvaflabJ~ly0lStudles Key: Nooe*Nuf AvaPaole. FES=Fear~b/l:!yRudyAvallableSRIS=Sptsm Re11ab:lIty Im,oar Study Aus~lable,FS=Fsoblias Study snd?or A TRA Available
Pr~poppaedi,?-servlceOats8 a w sbown to l o m r Yerrr/Qualinsr, where Qualilisr may ~ n d ~ c alhe
a mwrlh, season, or quaner.
Updated: 7 0/29/20OQ
December 1,2009
Peter Price
Owner Henderson Storage
8048 NYS Rt. 3
Henderson NY 13650
Re:
I am a business owner and resident living in the area directly affected by the Hounsfield Wind Power Project. 1 am
writing to advise you of serious deficiencies in the SEQR review process and to request that the public comment
period for the DEIS be re-opened to allow for adequate public input on matters that were either ignored or given
inadequate attention in the DEIS. 1 am specifically seeking a written reply from DEC with regard to such
deficiencies and whether the record will be re4pened.
The deficiencies include, but are not limited to:
1. The Draft Environmental Impact Statement for the Project does not consider a thorough analysis of the
cumulative impacts of all five (5) planned projects in the affected area. Amongst other projects, the New
York Power Authority has publicly announced its intention to construct a massive wind farm in the same
region. Although the NYPA plan was announced prior to completion of the public comment period for the
Hounsfield Wind Power Project DEIS the document fails to address this large project proposed by a sister
state agency. The wind power projects currently proposed for the eastern end of Lake Ontario and the St.
Lawrence River will mllectively change the face of this important region forever. This is particularly true
where the associated transmission lines are already segmented from the project by virtue of a legal
technicality. The failure to address the cumulative impacts of the other large wind projects and the
transmission lines renders the DEIS for the Hounsfield Wind Power Project an improper exercise of
selective environmental review. The spirit and the letter of SEQR demand that DEC conduct an honest
assessment of these projects on a cumulative basis.
2. The Draft EIS does not address the issue of Environmental Justice as it relates to the low income residents
of Jefferson County, New York. If a major energy project were proposed for an urban area in downstate
New York the DEC's environmental justice policies would be applied. This project and its associated
projects and transmission lines will permanently deface a large swath of northern New York in order to
provide power to largely downstate interests. If the tables were turned and a power generation project was
proposed for Brooklyn, the Bronx, or Long Island in order to deliver power to Jefferson County the DEC
would analyze the environmental justice issues during its SEQR review. Your failure to include this issue in
the DEIS reveals a selective and discriminatory application of the DECs environmental justice requirements
and deprives the local community members of equal protection under the law.
3. The project as proposed is inconsistent with the petroleum and spill hazards presented in the DEIS. It is my
understanding that each wind turbine may contain up to 320 gallons of a petroleum lubricant that is highly
toxic to aquatic environments. The grouping of these petroleum storage devices in one small area
surrounded by a sensitive aquatic habitat should, at a minimum, require permitting under the DECs
petroleum andlor chemical bulk storage regulations. On this basis alone, the project must be denied a
permit outright. If any other business owner were to propose locating over 100 hundred 300+ gallon
storage petroleum/chemical storage containers on Galloo Island it is inarguable that the DEC would deny
them the right to do so. There does not appear to be an exemption for wind turbines in the petroleum or
chemical bulk storage regulations and yet the DElS ignores the issue and no permits have been required.
4. Portions of Galloo Island are included in the NYSDEC Open Spaces Plan, as are close proximity islands,
Little Galloo, and Gull Island. Several years ago, the NYSDEC considered a purchase of Galloo Island.
During the NYSDEC review of such action, the island was considered to be 'fragile and delicate" and the
recommendation in the report was that the island should remain it its current state. Such analysis is highly
inconsistent with the allowance of industrial wind turbine projects on the island and proximate to other
islands in the Open Space Plan. This issue must be addressed in the DElS and the public must be allowed
to comment.
5. The socioeconomic impact section of the DElS is highly misleading when compared to the actual intentions
of the project sponsors. In discussions of the project and its associated transmission line the DElS seems
to indicate that the project will "negotiate" with land owners when in fact, as the sponsors have since
confirmed, they intend to utilize the power of eminent domain to take land from its rightful owners against
their will. The taking of property against the will @flandowners would be a highly irnpacfful event upon the
socioeconomic make up of northern New York. The DElS does not include an assessment of the impacts
upon local people who have lived in the same view shed for generation upon generation, and which will
now be changed forever without even a cursory discussion of those socioeconomic impacts by the New
York DEC.
The residents of Jefferson and St. Lawrence counties do not oppose the development of renewable energy
resources. In fact, the vast majority of all of the renewable power that has been, or ever will be, generated in New
York State was generated at great cost to our local environment by virtue of the hydroelectic dams on the Great
Lakes system. It is inappropriate for the DEC to abdicate its responsibilities to conduct a thorough and Fair
environmental review in the headlong rush to develop even more renewable power for the benefit of others on the
backs of our region and its irreplaceable resources.
Please consider this letter to be a specific request to re-open the record to allow true public input into the DElS
process on the above and other issues. I also respecthlly request that you respond to this letter in a timely manner
and provide copies of your response to New York State Senator Darrel Aubertine.
Sincerely,
Peter Price
CC:
December 2, 2009
Stephen Tomasik
Project Manager
Energy Projects and Management
Division of Environmental Permits
NYS Department of Environmental Conservation
625 Broadway - 4th Floor
Albany, New York 12233-1750
Dear Mr. Tomasik:
I am writing to request the DEC extend by 6 months the public comment
period for the Hounsfield Wind Farm Project (Galloo Island). My family
has been summer residents at Clarks Point, Henderson, NY since 1939. Our
property is on the lake shore and faces directly west with a full view of
Stony Point, SW Stony Island and Galloo Island. My summers there date
back to my 1939 birth year and to the 5 months I now spend there each
summer. The view has changed minimally in all those years with our
westerly views of gorgeous sunsets off the end of Galloo Island, the
night sky full of stars, the blinking of the Stony Point light and the
more faint Galloo Island light. Tourists spend lots of money to travel
to exotic places such as Key West, FL to view those same sunsets. It
would be a shame to destroy such a sight and the pristine beauty of
eastern Lake Ontario for the benefit of a few land owners and purveyors
of wind generating machinery. One can only imagine what a plethora of
blinking red and white strobe lights, certainly visible for at least a 30
mile radius, would do to this scene!
I write this not as anti alternative forms of energy, as I favor such. I
just believe there are better and more isolated places in Northern NYS
away from an area having such raw beauty and rich recreational assets. I
hope you will see fit to extend the comment period so all factors and all
voices can be heard on this potentially damaging alteration to the
landscape in this pristine area. I would like my unique view to be there
for my children and grandchildren.
Thank you for your consideration.
Very truly yours,
Donald C. Brandt
Summer Address:
5118 Clark Point Road
Henderson, NY 13650
From: <jsalovitch@aol.com>
To: <smtomasi@gw.dec.state.ny.us>
Date: 12/2/2009 11:07 AM
Subject:
Galloo Island
Mr. Tomasik,
I am writing to request and extension on the public comment period for the Hounsfield
Wind Farm project on Galloo Island.
As a summer resident, I am opposed to this project and hope that we can somehow stop it
from happening. I grew up in the area, but now live in New Jersey. We spend our
summers there because of the natural beauty of the lake. A wind farm would detract from
the beauty of the area as well as effect our property values on the lake.
Janet Salovitch
14754 Snowshoe Road
Henderson, NY
From: <mvmarburger@aol.com>
To: <smtomasi@gw.dec.state.ny.us>
Date: 12/2/2009 11:13 AM
Subject:
request extension for public comment Hounsfield Wind Farm Project
Mary M Hoffman
PO Box 444
Henderson Harbor, NY 13651
Mr. Stephen Tomasik
Project Manager
Energy Projects and Management
Division of Environmental Permits
NYS Dept of Environmental Conservation
625 Broadway - 4th Floor
Albany, NY 12233-1750
December 2, 2009
Dear Mr. Tomasik:
The purpose of this letter is to request an extension to allow public comment on the
Hounsfield Wind Farm Project. As a property owner in the region, I am concerned about
the impact this project will have on environmental issues, agricultural use of land,
property valuation, and tourism. This project will benefit the Town of Hounsfield
financially, without impacting their farm land, their property values, or their
infrastructure. It will impact all those areas, excepting, financial gain, within the Town of
Henderson. This does not seem fair or reasonable, and therefore I believe more time is
needed to assess the costs to Henderson, both financial and otherwise, before a decision is
reached.
Rich Mangan
W. J. Arnold
Because of New Yorks home rule system, the enormity of the
combined effects of these proposed projects has heretofore not been
fully appreciated by the communities that will be impacted. The
potential implications have only been recognized very late in the
approval process. Only recently has there been any community reaction
and only recently have the citizens of these communities begun to
push back
PO Box 525
Henderson Harbor, NY 13651
www.AssociationIslandResort.com
December 3, 2009
To:
Stephen Tomasik
Project Manager
Energy Projects and Management
Division of Environmental Permits
NYS Department of Environmental Conservation
625 Broadway - 4th Floor
Albany, New York 12233-1750
PH: (518) 486-9955
FAX: (518) 402-9168
smtomasi@gw.dec.state.ny.us
From:
Subject:
My family owns and operates Association Island RV Resort & Marina, LLC and owns LJS Properties, LLC, the
property owner of Snowshoe Island and Association Island. Dr. Nak K. Shim and So Ok Shim are the Managing
Members of both LLCs. In this letter, I will collectively refer to any or all related family entities as just
Association Island. Association Island strongly opposes the development of the Hounsfield Wind Farm on
Galloo Island on the grounds that: 1) the negative visual impact of the wind farm will irreparably damage
an existing critically important and irreplaceable natural resource the beautiful waterfront viewshed over
the eastern shores of Lake Ontario; 2) the proposed telecommunications towers and transmission lines
may interfere with satellite telecommunications and FCC-regulated air waves; and 3) that destroying our
beautiful viewshed will irreparably harm the environment, our business, and the economy in the whole
1000 Islands Region.
Building wind farms to replace the countrys reliance on fossil fuels and foreign oil should not come at the
expense of sacrificing an existing natural resource and harming a regions business activity and livelihood. There
are many forms of alternative energy and you can build a wind farm in many alternative locations, but you will
never again be able to build such a beautiful waterfront viewshed as we currently have here in the waters of
eastern Lake Ontario, and particularly in the Henderson Harbor and Golden Crescent area. We ask the New
York State Department of Environmental Conservation (NYS DEC) as lead agency, the Public Service
Corporation (PSC), and the many other local, county, state and federal regulators and public officials to
deny the request of UNYPC, or any developer, to build a wind farm on Galloo Island, or on any other
property, in the waters of eastern Lake Ontario.
Page 1 of 8
Physical Address (No USPS Mail):
15530 Snowshoe Road
Henderson, NY 13650
Email: Info@AIResort.com
PO Box 525
Henderson Harbor, NY 13651
www.AssociationIslandResort.com
For background about Association Island: we are physically located at the end of Snowshoe Road in Henderson,
NY and are located 5.6 miles directly east of Galloo Island. On 65-acre Association Island, we offer a top-rated
resort for recreational vehicles (RVs) with 305 RV sites (all with full hook-ups for potable water, sewer,
20/30/50 amp electric, and basic cable TV service), marina with 70 boat slips, five 2-bedroom cottages,
Conference Center, convenience store and office, laundry, and many other facilities for recreation and amenities.
We rent our rv sites, slips, and cottages by the night, weekend, week, month, and even for the full season. After
our own long and arduous regulatory approval process which started in 1990 and after investing several million
dollars in developing our facilities, we opened for business in 2002 and just completed our eighth season. Our
season generally runs from May 15th to October 15th of each year. Our customers come to Association Island to
enjoy our unique island setting with beautiful waterfront and sunset views and to enjoy all the recreation and local
tourist attractions offered in the whole 1000 Islands Region. We are a member of the Henderson Harbor Area
Chamber of Commerce (HHACC), Sackets Harbor Chamber of Commerce, Watertown Chamber of Commerce,
Syracuse Chamber of Commerce, and active supporter of the Thousand Islands International Tourism Council.
In this letter, I will repeatedly reference statements and exhibits provided by UNYPC in their Draft Environmental
Impact Statement (Draft EIS), which is downloadable from their website at
www.upstatenypower.com/images/Hounsfield_Wind_Farm_Draft_EIS.pdf.
In support of our opposition to UNYPCs development of the Hounsfield Wind Farm at Galloo Island,
please consider the following 15 points:
Point #1: The serene, beautiful, natural, waterfront viewshed in eastern Lake Ontario provides public
enjoyment for millions of viewers and serves to attract property ownership and commerce, in the form
of tourism, to the whole 1000 Islands Region in Northern New York State. Developing one natural
resource, namely the harnessing of wind, for alternative energy should not come at the expense of
sacrificing an already existing and critically important natural resource, our waterfront viewshed.
According to the NYS DEC which is quoted in UNYPCs Draft EIS on page 2-136, the NYS DEC Visual
Policy states:
Aesthetic impact occurs when there is a detrimental effect on the perceived beauty of a place or
structure. Significant aesthetic impacts are those that may cause a diminishment of the public enjoyment
and appreciation of an inventoried resource, or one that impairs the character or quality of such a place.
Proposed large facilities by themselves should not be a trigger for a declaration of significance. Instead,
a Project by virtue of its siting in visual proximity to an inventoried resource may lead staff to conclude
that there may be a significant impact.
On page 2-136 and 2-137 of their Draft EIS, UNYPC falsely states, Given the significant distance of the
project from virtually all publicly accessible vantage points, the project will not cause the diminishment of
public enjoyment and appreciation of an inventoried resource, or impair the character or quality of such a
place. UNYPCs own photo simulations in their Draft EIS Appendix Q: Visual Resources Report and
Line-of-Sight Drawings, verify the clear visibility of the wind turbines from Ellisburg to Henderson
(including simulations specifically at Association Island) to Sackets Harbor and Cape Vincent in Exhibits A5a to A14-b (copies of which are attached). Additionally, the photo simulations fail to depict how the FAArequired red-blinking lights will turn our waterfront horizon into an industrial red-light zone at night a
severely negative aesthetic impact. The wind farm project at Galloo Island will forever damage our
waterfront and direct westward sunset views, a waterfront horizon that has been lauded for its un-touched
Page 2 of 8
Physical Address (No USPS Mail):
15530 Snowshoe Road
Henderson, NY 13650
Email: Info@AIResort.com
PO Box 525
Henderson Harbor, NY 13651
www.AssociationIslandResort.com
beauty since the historic battles of the War of 1812. The wind farm will damage the aesthetic appeal, public
enjoyment, and character of the waterfront enjoyed by the millions of visitors to 4 nearby state parks
(Southwick Beach, Robert G. Wehle, Westcott Beach, Sackets Harbor Battlefield) and the Seaway Trail, to
the thousands of annual visitors to Association Island, and to the thousands of homeowners and businesses in
the region. The Hounsfield Wind Farm will clearly violate the NYSDEC visual policy on aesthetic
impact, and will harm the public enjoyment and quality of life of our residents and businesses.
Point #2: UNYPC failed to show simulations of the FAA-required red-blinking lights which must flash in
unison on top of the 400+ feet wind turbine towers. We ask that regulators and public officials require
that UNYPC to provide these same photo simulations showing the red-blinking lights, and we ask that
the regulators and public officials imagine having the same red-lights blinking in their backyard as
they make their decision regarding the development of the wind farm.
Point #3: On page 2-138 of the Draft EIS, UNYPC states that Due to the height of the WTG, the Federal
Aviation Administration requires red flashing aviation obstruction lighting be placed atop the nacelle on
approximately 23 of the 84 turbines to assure safe flight navigation in the vicinity of the Project. Lighting
will be at the lowest intensity required for pilot safety. This federally mandated safety feature cannot be
omitted or reduced. UNYPC expects to use L-864 lighting, which they suggest are low intensity red lights
emitting 2000 candelas, on 23 of 84 wind turbines. The FAA requires the red lights to all flash in unison.
UNYPC suggests that these lights will have limited visual impact due to the distance of 5.6 miles to the
nearest shoreline and due to earths curvature. In late summer and fall of 2009, when water levels were
lower, the red lights blinking from the wind turbines at Wolfe Island (required to have red lights on ~30 out of
86 wind turbines and situated ~20 miles north-west) were clearly visible from Association Islands shoreline.
We countered our customers complaints about the obnoxious red-blinking lights by saying that at least the
red-lights are not obstructing our westward sunset views over Lake Ontario and they are only visible during
periods of low lake levels (due to the earths curvature). With the much closer proximity of 5.6 miles to
Galloo Island (versus 20 miles to Wolfe Island), distance and earths curvature will not diminish the
negative aesthetic impact. The wind turbines and FAA-required red lights will clearly be visible yearround by all areas along our shoreline, especially when you consider that the lights at Galloo Island will
be at a stronger 2000 candelas than the lights at Wolfe Island, which have brightness of 1800 candelas.
Point #4: Association Island has its own water treatment plant on-site. Our water treatment plant extracts
water from our western shoreline, purifies the water, and provides potable water to our customers which can
number up to 1,000 people during peak periods. Our 150-feet water in-take pipe is on the western shores of
Association Island facing directly toward Stony and Galloo Islands. The dispersion of sediment due to
underwater dredging and/or any oil spills from the wind turbine reservoirs will negatively harm our water
treatment filters and plant purification process, posing a health hazard to our customers if not contained or
expeditiously mitigated.
Point #5: Association Island operates a capital-intensive and labor-intensive business. In addition to the
multi-million dollar development costs, we spend several hundred thousand dollars per year in expenses for
goods and services and payroll to support our business, for upgrades in our facilities and for operations. Any
decline in Association Islands business will negatively impact our vendors and payroll needs, and
subsequently reduce county and state tax revenues.
Page 3 of 8
Physical Address (No USPS Mail):
15530 Snowshoe Road
Henderson, NY 13650
Email: Info@AIResort.com
PO Box 525
Henderson Harbor, NY 13651
www.AssociationIslandResort.com
Point #6: During Association Islands own regulatory approval process, we were required to submit an
Economic Impact Statement. Our studies showed that the economic impact of our business has a 7-to-1
multiplier impact. In other words, for every $1 dollar spent at our resort, $7 dollars are spent in the local area.
Our RV customers have RVs that range in price from a couple thousand dollars, to a couple hundred
thousand dollars, and even to 45-foot motorcoaches that cost up to two million dollars. Our customer base
has above average incomes with above average discretionary spending abilities. We can cite numerous
examples of how actual customer experience has justified this 7-to-1 multiplier effect, as our customers
regularly spend their vacation and discretionary dollars in Henderson, Henderson Harbor, Adams, Sackets
Harbor, Cape Vincent, Clayton, Watertown, Oswego, Alexandria Bay, and Syracuse. Any decline in
Association Islands business as a result of the diminished waterfront viewshed will have a 7-fold
negative impact on local businesses, with the potential of a more than a million dollars hit to the local
economy, along with the loss of associated county and state tax revenues.
Point #7: We request that regulatory authorities require UNYPC to conduct and submit a full
Economic Impact Statement, representing not only the positive effects of the wind farm on the local
and state economy, but also the negative impact on local businesses and tourism to the region and NY
state. On page 2-151 of the Draft EIS, UNYPC states that Due to the remote location of the Project, no
impact to tourism or tourism-related employment on the mainland is anticipated. Regardless, a survey
conducted in 2003 for the East Haven Windfarm in Vermont revealed that 95 percent of visitors to the states
Northeast Kingdom would not be deterred from further visits by the existence of wind turbine generators.
The survey was conducted by the Institute for Integrated Rural Tourism. We argue that the survey results in
Vermont should not be taken into consideration here, since they were evaluating a rural in-land area without
the unique waterfront viewshed which we have here on the Great Lake of Lake Ontario. We ask that prior
to approving the development of the Galloo Island wind farm, regulators must require UNYPC to
engage an independent consultant to conduct a survey to determine the impact of tourism to the Cape
Vincent area, which is situated directly across from the newly built Wolfe Island wind farm, and to
conduct a survey to Association Islands customers of the perceived impact of wind turbines and their
red lights on the waterfront horizon. On page 2-151 of their Draft EIS, after lauding their positive impact
on the economy including $2.016 million PILOT payments to the Town of Hounsfield, Jefferson County, and
the Sackets Harbor Central School District, they state No significant adverse impact in the form of net
economic losses is anticipated for commercial businesses in the Town of Hounsfield or Jefferson County.
Per our Points #4 and #5, UNYPC has neglected to analyze the negative impact to tourism to the 1000 Islands
Region. Furthermore, UNYPC does not expect the wind turbines to generate increased tourism, and due to
the remote offshore location of Galloo Island and their proposed development of internal infrastructure (onsite housing, commissary, transportation of employees via helicopter, shipping via the port of Oswego), their
employees will have little opportunity to spend time nor patronize businesses in Jefferson County. UNYPCs
arguments that the wind farm project will only add positive benefits to the economy without any
negative impacts to tourism and local businesses are capricious at best, and authorities must require
UNYPC to provide a more accurate and comprehensive analysis of the economic impact.
Point #8: In their Draft EIS Appendix Q page 8, UNYPC inaccurately states This portion of New York
State is generally rural with [only, my words not theirs] two (2) village centers located within the study area;
Cape Vincent and Sackets Harbor. The Village of Cape Vincent (population 760) is located more than 14
miles from the nearest turbine . . . The Village of Sackets Harbor (population 1,386) is approximately 12.2
miles east of Galloo Island. UNYPC completely failed to recognize Henderson within its study area
Page 4 of 8
Physical Address (No USPS Mail):
15530 Snowshoe Road
Henderson, NY 13650
Email: Info@AIResort.com
PO Box 525
Henderson Harbor, NY 13651
www.AssociationIslandResort.com
when Henderson is the closest mainland town at only 5.6 miles east of Galloo Island with a population
of 1,377 which is larger than Cape Vincent and equivalent to Sackets Harbor. How could UNYPC
neglect to recognize Henderson as an effected population when Henderson is the closest town to Galloo
Island, when Henderson is the location where their infrastructure for transmission lines and
telecommunications will come on-shore, when Hendersons properties will be dissected by their transmission
lines, and when Hendersons viewshed is the most closely and directly impacted? While Galloo Island
somehow falls under the jurisdiction of the Town of Hounsfield, how can UNYPC neglect to recognize
Henderson as a critically important jurisdictional authority? Adding further insult, UNYPCs plans for
transmission lines do not physically enter or lie within any portion of the mainland of the Town of
Hounsfield. Hounsfield will receive all the financial benefit of the wind farm, without any disruption to the
municipalitys infrastructure or residents properties.
Point #9: In the section for Inventory of Aesthetic Resources (Draft EIS on page 2-127), UNYPC fails
to fulfill the requirement that states The DEC Visual Policy requires that all aesthetic resources of
Statewide Significance by identified with any potential adverse effects on those resources resulting from
the Project. In Table 2.6-1 Potential Aesthetic Resources, they inaccurately characterize Association Island
as only having local significance. Association Island has been rated by Woodalls, a leading ratings agency
in the RV industry, in the top 3% of over 8200 private campgrounds that Woodalls rates across the United
States and Canada. With our commitment to top-rated facilities, we are considered a destination resort for
RVers and have successfully attracted customers from all 50 U.S. states, Canada, and even Europe and
Australia. While most RV campgrounds draw from a local customer base, only a small fraction of our
business is generated by local customers and an overwhelming majority of our business comes from outside
Jefferson County. Our major markets not only include the in-state regions surrounding Watertown, Syracuse,
Rochester, Buffalo, Albany, and Binghamton, but we also have a strong customer base from Pennsylvania,
New Jersey, Massachusetts, Florida, Texas, and the Canadian provinces of Ontario and Quebec. The negative
impact of wind farms to our business is not just of local significance, but will have far-reaching state-wide
significance particularly when you factor in the 7-to-1 multiplier impact. Not only will businesses suffer, but
the county and state will lose the sales taxes, gasoline taxes, highway tolls, and income taxes generated by the
revenues from our customers during their stays at, and while enroute to and from, Association Island.
Counter to the NYS DEC requirement, UNYPC completely failed to include the analysis of the adverse
economic impact for the inventoried resources that they already listed with statewide significance (including
the state parks at Southwick Beach, Robert G Wehle, Westcott Beach, Sackets Harbor Battlefield), and they
failed to characterize Association Island as having statewide significance. We ask that you require UNYPC
to complete this analysis of the potential adverse impact on inventoried resources of statewide
significance both aesthetically and economically, and in an accurate manner.
Point #10: Association Island is the largest taxpayer in the Town of Henderson and one of the largest
taxpayers in Jefferson County. After vacationing at Association Island, many of our customers have bid on
and/or purchased properties and businesses in Henderson and other local towns. Our business and our
customers help improve property values and contribute significantly to the town and countys property tax
base. A decline in Association Islands business will ultimately negatively impact the town and
countys property tax base.
Point #11: Association Island offers basic cable TV service to our customers, and our customers rely on
over-the-air HDTV service, radio, NOAA emergency weather alerts, cellular phone service, and wireless
Page 5 of 8
Physical Address (No USPS Mail):
15530 Snowshoe Road
Henderson, NY 13650
Email: Info@AIResort.com
PO Box 525
Henderson Harbor, NY 13651
www.AssociationIslandResort.com
internet data service. Within our cable system, we receive satellite service from DirecTV and over-the-air
HDTV transmissions from major US networks and transmit the signals through underground cabling to our
sites. Our customers also independently utilize their own satellite services and over-the-air HDTV
transmissions from both US and Canadian networks. According to the NOAA newsletter for Winter 2006
The Lake Breeze, The Newsletter of the Buffalo Forecast Office in the attached Exhibit B, the article titled
The Effect of Wind Power Farms on the Weather Radar, Thomas Niziol, Meteorologist in Charge,
describes how the turbines at Maple Ridge Wind Farm negatively impact data quality and so degrade the
performance of radar algorithms, and concludes the rapidly increasing number of wind farms used to
generate electricity is beginning to impact weather surveillance radar data. To date, the impacts appear to be
minimal. However experiences to date indicate the expected near-exponential growth in the number of such
installations is cause for concern. The proposed wind turbines, telecommunications towers and transmission
lines will likely interfere with satellite reception and over-the-air transmissions and create safety concerns, not
only for Association Islands customers but also for local residents and boaters in the Henderson Harbor area.
We ask the PSC to stop UNYPCs interference with weather radar, satellite TV communications, and
FCC regulated and protected airwaves. We also ask the PSC to require UNYPC to thoroughly analyze,
disclose the impact of, and eliminate any impairment resulting from their project on satellite TV, overthe-air HDTV, radio, NOAA emergency weather service, cellular service, and wireless internet data
service signals.
Point #12: Under Section 3.0 of the Draft EIS page 3-1, the SEQRA must contain a discussion of
alternatives to the proposed action. Two of their alternatives included:
a. No Action: there are approximately 21 wind power projects currently operating or under
construction in New York State. There are already 4 project proposals for wind farms, all within a
40-mile radius to Galloo Island: including 1) the Cape Vincent Wind Farm with 140 turbines on 335
acres situated 10.5 miles north of Galloo Island, 2) the St. Lawrence Wind Power Project with 86
turbines on 289 acres situated 15 miles north of Galloo Island, 3) the Horse Creek-Clayton Wind
Farm with 62 turbines on 714 acres situated 20 miles northeast of Galloo Island, and 4) the Roaring
Brook Wind Project with 39 turbines on 211 acres situated 39 miles east southeast of Galloo Island.
With all these alternative locations which are situated on in-land properties, the need for a wind farm
at this particular location, situated offshore on an island 5.6 miles into the waters of eastern Lake
Ontario, is greatly diminished. We ask that the regulators and public officials recognize No
Action as the Preferred Action, to save our natural resource of the beautiful waterfront
viewshed. We further ask that regulators and public officials force developers to seek the
development of alternative energy away from offshore locations, which will irreparably damage
the viewshed of eastern Lake Ontario, to on-shore and in-land locations.
b. Lower Turbine Height: UNYPC provides a discussion of using shorter turbines at a maximum tip
height of 339.5 feet versus the current proposal of 410 feet. Even at 339.5 feet, the project will be
required to have the FAA-required aviation obstruction lights. We ask that the regulators request
that UNYPC propose an alternative solution at much lower turbine heights that will not be
required to have the FAA-required lighting and that will not impair the visual aesthetics of our
viewshed.
Point #13: Based on the numerous negative aesthetic and economic impacts listed in Association
Islands previous Points #1-10, UNYPCs wind farm proposal may be in violation of New York States
Coastal Management Program Policy #18: To Safeguard the Vital Economic, Social and
Page 6 of 8
Physical Address (No USPS Mail):
15530 Snowshoe Road
Henderson, NY 13650
Email: Info@AIResort.com
PO Box 525
Henderson Harbor, NY 13651
www.AssociationIslandResort.com
Environmental Interests Of The State and Of Its Citizens, Proposed Major Actions In The Coastal
Area Must Give Full Consideration To Those Interests, And To The Safeguards Which The State Has
Established To Protect Valuable Coastal Resource Areas (see Draft EIS page 4-5). Contrary to
UNYPCs opinion, the Project will adversely affect the social, economic or environmental interests of the
State and its Citizens.
Point #14: The National Research Council of the National Academies prepared a report in 2007 titled
Environmental Impacts of Wind-Energy Projects, downloadable from the internet at
http://www.vawind.org/Assets/NRC/NRC_Wind_Report_050307.pdf. This project was supported by
Contract No. EC25C001 between the National Academy of Sciences and the Executive Office of the
President, Council on Environmental Quality. In the report, they list factors for the Determination of
Unacceptable or Undue Aesthetic Impacts and state:
Among the factors to consider are:
Has the applicant provided sufficient information with which to make a decision? These would
include detailed information about the visibility of the proposed project and simulations
(photomontages) from sensitive viewing areas. New Yorks SEQRA process offers an example of
clearly identifying the information required and the mitigation measures that need to be considered.
Are scenic resources of local, statewide or national significance located on or near the project site?
Is the surrounding landscape unique in any way? What landscape characteristics are important to the
experience and visual integrity of these scenic features?
Would these scenic resources be significantly degraded by the construction of the proposed project?
Would the scale of the project interfere with the general enjoyment of scenic landscape features
throughout the region? Would the project appear as a dominant feature throughout the region or
study area?
Has the applicant employed reasonable mitigation measures in the overall design and layout of the
proposed project so that it fits reasonably well into the character of the area?
Would the project violate a clear, written community standard intended to protect the scenic or
natural beauty of the area? Such standards can be developed at the community, county, region, or
state level.
The development of the Hounsfield Wind Farm on Galloo Island and the proposed transmission line will
violate all of these factors. Specifically, on the last factor listed, the wind farm turbines and transmission
lines violate the Comprehensive Land Use Plan of the Town of Henderson. Any wind farm development on
the eastern shores of Lake Ontario will violate all of these factors.
Point #15: What is the point of building additional wind energy in northern and western New York,
when the electric transmission grid in New York State is deficient and cannot transmit such additional
capacity to downstate? On December 1, 2009, the New York Power Authority (NYPA) made an
announcement that the NYPA is seeking requests for proposals to construct wind power projects on the Great
Lakes of Lake Erie and Lake Ontario. The Maple Ridge Wind Farm in Lowville, NY already generates 321
megawatts of electricity, which is enough to power 125,000 homes and businesses, or more than enough to
power all the homes and businesses in Jefferson County, St. Lawrence County, and Lewis County.
Additional wind farms are therefore on the NYPAs agenda to supply the downstate New York City
metropolitan area. However, the congestion and capacity constraints of the electric grid have already forced
Page 7 of 8
Physical Address (No USPS Mail):
15530 Snowshoe Road
Henderson, NY 13650
Email: Info@AIResort.com
PO Box 525
Henderson Harbor, NY 13651
www.AssociationIslandResort.com
the wind turbines to shut down at Maple Ridge Wind Farm on numerous occasions. Furthermore, after 5
years of seeking regulatory and public approvals, on April 6, 2009, the New York Regional Interconnect
(NYRI) terminated its proposal to construct a $5 billion state-of-the-art 190-mile, 1200 megawatt electrical
transmission line to run from the Town of Marcy, NY in Oneida County to the Town of New Windsor, NY in
Orange County. The NYRI project faced severe opposition from homeowners and public officials. It should
be obvious that upstate New Yorkers (private and public entities) do not want to have our property, farmland,
businesses, tourism, and beautiful viewsheds sacrificed for the sake of downstate New Yorkers power needs.
Attachments: Exhibit A: Exhibit A5-a to A14-b of Appendix Q of Draft Environmental Impact Statement.
Exhibit B: NOAA Winter 2006 The Lake Breeze, The Newsletter of the Buffalo Forecast Office
Page 8 of 8
Physical Address (No USPS Mail):
15530 Snowshoe Road
Henderson, NY 13650
Email: Info@AIResort.com
Exhibit A:
Visual Simulations
Hounsfield Wind Farm (08-009.10M)
Existing Condition
FIGURE A5-a
Photo Simulation
VP#64Robert G. Wehle State Park (Cliff View)
Town of Henderson
Approximately 6.4 miles from the nearest turbine
Visual Resource Assessment
January 2009
Photo Simulation
FIGURE A5-b
Photo Simulation
VP#64Robert G. Wehle State Park (Cliff View)
Town of Henderson
Approximately 6.4 miles from the nearest turbine
Visual Resource Assessment
January 2009
Existing Condition
FIGURE A6-a
Photo Simulation
VP#X67Robert G. Wehle State Park
Town of Henderson
Approximately 6.0 miles from the nearest turbine
Visual Resource Assessment
January 2009
Photo Simulation
FIGURE A6-b
Photo Simulation
VP#X67Robert G. Wehle State Park
Town of Henderson
Approximately 6.0 miles from the nearest turbine
Visual Resource Assessment
January 200908
Existing Condition
FIGURE A7-a
Photo Simulation
VP#68Southwick Beach State Park
Town of Ellisburg
Approximately 13.3 miles from the nearest turbine
Visual Resource Assessment
January 2009
Photo Simulation
FIGURE A7-b
Photo Simulation
VP#68Southwick Beach State Park
Town of Ellisburg
Approximately 13.3 miles from the nearest turbine
Visual Resource Assessment
January 2009
Existing Condition
FIGURE A8-a
Photo Simulation
VP#70Black Pond WMA
Town of Ellisburg
Approximately 10.9 miles from the nearest turbine
Visual Resource Assessment
January 2009
Photo Simulation
FIGURE A8-b
Photo Simulation
VP#70Black Pond WMA
Town of Ellisburg
Approximately 10.9 miles from the nearest turbine
Visual Resource Assessment
January 2009
Existing Condition
FIGURE A9-a
Photo Simulation
VP#78Association Island
Town of Henderson
Approximately 8.2 miles from the nearest turbine
Visual Resource Assessment
January 2009
Photo Simulation
FIGURE A9-b
Photo Simulation
VP#78Association Island
Town of Henderson
Approximately 8.2 miles from the nearest turbine
Visual Resource Assessment
January 2009
Existing Condition
FIGURE A10-a
Photo Simulation
VP#80Westcott Beach State Park (Camping AreaNorth End)
Town of Henderson
Approximately 12.4 miles from the nearest turbine
Visual Resource Assessment
January 2009
Photo Simulation
FIGURE A10-b
Photo Simulation
VP#80Westcott Beach State Park (Camping AreaNorth End)
Town of Henderson
Approximately 12.4 miles from the nearest turbine
Visual Resource Assessment
January 2009
Existing Condition
FIGURE A11-a
Photo Simulation
VP#80.1Westcott Beach State Park (Overlook)
Town of Henderson
Approximately 13.0 miles from the nearest turbine
Visual Resource Assessment
January 2009
Photo Simulation
FIGURE A11-b
Photo Simulation
VP#80.1Westcott Beach State Park (Overlook)
Town of Henderson
Approximately 13.0 miles from the nearest turbine
Visual Resource Assessment
January 2009
Exhibit B
NOAAs National Weather Service
Volume 2, Issue 2
Winter 2006
Tug Hill is in many respects the ideal location for New York's largest wind energy
project. This site consists of approximately 12,000 acres at an average elevation of 1600-1800 feet. The Tug Hill plateau experiences strong lake-effect
weather patterns and has long been
known not only for tremendous snowfall
but for its exceptional wind resource.
Computer Models
SKYWARN Training
Page 2
From: <Bashodian@aol.com>
To: <smtomasi@gw.dec.state.ny.us>
Date: 12/3/2009 10:57 AM
Subject:
Request for Public Hearing Extension - Hounsfield Wind Farm Project
Attachments:
Letter to Editor November 29.doc; Letter to the Editor Outrage and Apathy.doc
December 3, 2009
To:
Stephen Tomasik
Project Manager
Energy Projects and Management
Division of Environmental Permits
NYS Department of Environmental Conservation
625 Broadway - 4th Floor
Albany, New York 12233-1750
I have been deeply involved in the various issues surrounding the proposed
Hounsfield Wind Farm Project (Galloo Island) through the Henderson Harbor
Area Chamber of Commerce and the recently formed Coalition for the
Preservation of the Golden Crescent, an organization that includes representation
from the various towns included in the Golden Crescent.
Two issues are very clear:
- the project if it goes forward will have a profound effect on
everyone that makes the eastern end of Lake Ontario their home, an area referred
to for decades as the Golden Crescent because of the beauty and uniqueness
of the area
- for many reasons, the progress of this project went relatively
un-noticed by the communities it would impact, the potential implications were
not recognized until very late in the approval process, only recently has
there been any community reaction and only recently have the citizens of
these communities begun to push back
There are many, many unanswered questions especially related to the
potential total destruction of the delicate ecosystem on Galloo Island, the
nearby islands, the area's fisheries and the much feared negative impact on lake
front property valuations and the seasonal based businesses that are so
significant to the local economy.
Many of us have only recently learned that portions of Galloo Island are
included in the DEC open space plans and that the DEC had attempted only a
few years ago to acquire and preserve Galloo Island because of its habitat
significance for a wide variety of living creatures. Similarly near by
islands are also included in the open space plan for similar ecological
reasons.
As I and others around me have learned more about this situation, we are
appalled at the prospect that turning Galloo Island into an industrial
complex for wind generation, regardless of so called mitigating actions, will
virtually destroy the ecology of Galloo Island and can't help but have a
negative impact on other nearby islands.
In an effort to make this project more visible to a largely unsuspecting
public, our local newspaper, the Jefferson County Journal, has provided me
the opportunity of a weekly column to discuss a broad range of issues.
These articles are printed under a general heading Henderson Harbor Area
Chamber of Commerce, comments of the Economic Development Committee, which I
chair.
I have attached two recently published articles. One addresses the
potential economic significance of the Galloo Island project. The second
addresses the outrage of those who have become aware of what is going on and the
apathy of those who do not.
I have attached both columns to support my urging that the public comment
period be extended an additional six months. There are far too many people
impacted by the outcome of the project to be making hasty decisions and
far too many people who have only most recently become aware and still wish
to provide their comments.
Sincerely,
Robert E. Ashodian
PO Box 544
Henderson Harbor NY 13651
horizon by day and by night. It is only rational to ask: what is the economic impact of
destroying the very features that make our waterfront and water view properties so
valuable?
Where is the Economic Impact Study that shows any net economic benefit to our
residents in terms of their property values, their energy costs, the net taxes they will pay
now and in the future? The PILOT appears to forgive taxes for some, allocate the
benefits through some sort of negotiated formula to others in a complex process that is far
from clear to those that would be negatively impacted by the project. It is only fair to
inquire into the details and be provided a thorough explanation.
Where are the figures that show wind energy, without massive subsidies paid for by tax
payers, is efficient or cost effective? And where is there any study that shows wind
power will reduce the cost of energy for anybody in this region. And, where is there any
study showing we need additional energy production to serve the needs of this region?
A lot more work is needed to evaluate the impact of populating this region with industrial
complexes for wind generation vs. the countys own Comprehensive Economic
Development Strategy and Hendersons Comprehensive Land Use Plan.
The developer is in a big rush and he is pushing us to meet his deadlines based on his
requirements. No decisions should be made at any level of government or any agency
until the unanswered questions are fully answered.
A company with a valuable and truly unique product to sell, protects that product,
supports that product, promotes that product and enhances the appeal of that product.
That product is its future; you nurture and grow that product. You do not cannibalize the
product by making its most attractive features ugly and unwanted. You dont make hasty
decisions about your most important product. We need to do all we can to protect that
product, not rush to give it away to the greedy interests who time after time have
destroyed forever what was once beautiful.
Those that have looked see total madness the destruction of the very reason
this community and the Golden Crescent area exists. They see a project, only
viable as a result of massive federal and state subsidies, totaling over
US$300,000,000, paid for by our own tax dollars, extracted from us by our distant
governments. In our county there is pressure to approve the PILOT program,
even when no in-depth economic impact study exists. Our County Legislators
and the JCIDA have been blinded by the US$25,000,000 payments that the
developer would pay back to their coffers. In turn the County and the JCIDA
would only pay out US$3,000,000 to the Town of Hounsfield. As you can see
this is reminiscent of a Ponzi scheme, made legal by green energy credits and
the mandate to reach certain levels of Renewable Power Sources, obviously at
any cost.,
We call for the insanity to cease, stop spending Federal funds that create very
few permanent jobs and provide no economic growth potential. We also ask the
developer and its supporters to stop hiding behind Green Energy what about
the irreparable damage to our Green-Scape? Also, the argument commonly
used for wind is to rid ourselves of dependency from foreign oil sources. If one
would look, we generate very little electricity from oil, our largest trading partners
for oil are Canada and Mexico, and we have unbelievably large reserves of oil in
ANWR. You may recall, ironically, ANWR cannot proceed due to expected
damage to the environment.
For sure there are those that feel good about wind energy and justify its
subsidized existence as good for America, clean and, to some, even attractive.
Sit up, listen up and smarten up the wind projects only benefit is to the
developer and a few landowners.
But, for those who have seen what is coming they are afraid, very afraid. They
should be afraid. Galloo Island is only the trunk of the elephant. Plans are being
considered to build 2,200 wind turbines on islands and in the waters of the
eastern end of Lake Ontario.
While such angst is tearing some of us apart, there is a much larger group that
seems totally unaware and unconcerned. They might have heard towers and
transmission lines are under discussion. But, this is an issue not of interest to
them.
Hendersons town board totally neglected the implications until October 6, 2009.
The developers have done what they are legally required to do. Notices were
published, hearings were held. But, nobody cared. Nobody was looking. The
Henderson board had to know, but opted to ignore it. The original documentation
for the transmission line was sent to the Town Office. Updates and key dates
were similarly ignored. Documentation sat on a shelf in the Town Clerks office.
A town councilperson was assigned to monitor the wind tower project, which is
I am thoroughly against the wind mill project that you are encouraging to be done. I am a
sailor and spend summers on the beautiful waters of Lake Ontario. I would greatly
appreciate you looking into this matter more carefully and do what is best for the
residents and travelers in that area. I would hate to see you ruin such a wonderful,
peaceful area. Thank you, Maureen Johnson