st.lawrence wind sdeis public comment letters 3 of 5

8/6/2019 St.Lawrence Wind SDEIS Public Comment Letters 3 of 5

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May 19,2009

Town of Cape Vincent Supervisor, Tom Rienbeck,Town of Cape Vincent Board Members,Town of Cape Vincent Planning Board Chairperson, Richard Edsall,Town of Cape Vincent Planning Board Members:

Upon hearing of the many health, safety and environmental issues surrounding the Acciona(8t Lawrence Wind Farm) wind turbine project, Iurge you to impose a moratorium of atleast 12 months to investigate and determine if this project is safe for our town. The issuesof accurate measurement of ambient noise levels, night time noise levels affecting sleep,project effect on our water supplies, shadow flicker effects, migratory bird impact, and thedominant visual impact of 390 foot tall turbines on our landscape need to be resolved.Health, safety, and environmental concerns should be more important than any amount ofmoney to be gained from this project.

Thank you.


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TO: Town of Cape Vincent Planning BoardFROM: Donald J. Metzger, Jr. (Year round resident/property owner Town

of Lyme and business owner in Cape Vincent)DATE: May 26,2009

SUBJECT: My comments on St. Lawrence Wind Power ProjectTowns of Cape Vincent and Lyme SDEIS.I want to thank the Cape Vincent board members for all of the work that you have putinto the proposed St. Lawrence (Acciona) Wind Project for the towns of Cape Vincentand Lyme.I also respectfully request that you continue your due diligence on this proposedproject, as you will be setting a precedent with this project. Kindly keep in mind thatfollowing St. Lawrence Wind Power Project (Acciona/Spain) will be the BP AlternativeEnergy (British Petroleum) proposed Cape Vincent Wind Power Project of anadditional 140 turbines in the Town of Cape Vincent alone.The British Project (140 turbines) will make the Spanish Project (53 turbines) seemsmall. Please keep in mind that the ground rules you set in place for the Spanishproject will be setting the precedent for ground rules for the huge British project. Ifstrict, comprehensive, clear, ground rules, that will stand up in court, are put in place,then this will help prevent the towns of Cape Vincent and Lyme from becoming"Company Towns".Volume #1, Section 2.2 page 2~3"After the public comment period on the SDEIS, two alternative_procedural pathwayswould be available to the lead agency. The town of Cape Vincent Planning Boardcould require preparation of a Final EIS (FEIS). If that alternative pathway is chosen,the following steps would be taken": Step #5 "10-day public consideration period"A 10 day public consideration period is simply not enough time for the citizens of thetowns of Lyme and Cape Vincent to consider and comment on a project of the size,scope and complexity of St. Lawrence Wind. Iwould respectfully request that the"consideration period" (comment period) be a minimum of 30 days.The second of the "two alternative procedural pathways that would be available to thelead agency" is not defined, explained or discussed. What is the second of the twoalternative procedural pathways available to the lead agency? If the secondalternative pathway is chosen, what are the steps that would be taken?Volume #1, Section 2 8.1 page 2~21,the decommissioning of the nine mile long 115,000volt, high tension overhead transmission line from Cape Vincent Project collectorsubstation Favret Road to the National Grid substation on County Route 179,Chaumont, is not mentioned. There is a lot of infrastructure involved in this aspect ofthe project that involves two towns ie. Lyme and Cape Vincent, hundreds of woodenpoles that are bored 15 feet into the ground and extend approximately 80 feet above

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the ground (approximately twice the height of roadside utility poles) Volume #1 Sec2.5.5 pg 2-9 and 2-10. There will be three wires for the three phase current and onewire at the top of the poles that functions as a static wire/shield wire for lightingprotection with a project data communication line inside.Four suspended wires for nine miles means, 36 miles of wires in the air. Thisoverhead transmission system will connect to a yet to be built by Acciona,Transmission Owner Interconnection Substation to be located between the east bankof the Chaumont River and the west side of county RT. #179 Town of Lyme. This newattachment substation will be called "Rockledge" (Volume #2 Appendix K) and willconnect to the existing National Grid substation on the east side of county RT #179,Town of Lyme.The nine mile long overhead transmission line will have a 100' wide easementiright ofway (Volume #1, Table 2-1 pg 2-13 and will cross five roads in the town of Lyme andtwo roads in the Town of Cape Vincent (Volume #2, Appendix K). Several streams,creeks and the Chaumont River will also be crossed.Volume #1 Sec. 2.8.1.4 page 2-22 Discusses decommissioning overhead collectionlines. These overhead collection lines are not to be confused with the overheadtransmission lines. The overhead collection lines are part of the 37 mile system ofburied and overhead wires that connect the turbines with the Project CollectionSubstation on Favret Road, Cape Vincent.Volume #1 Sec 2.8, pg 2-20 Decommissioning "Except for the underground collectionsystem, which is provided for under a perpetual easement, SLW's lease agreementswith the landowners provide that all wind project facilities will be removed to a depthof four feet (48") below grade following the end of the project's useful llfe."Volume #1 Sec. 2.8.1.3 2-22 Underground collection cables "The cables andconduits ....will be cut back to a depth greater than 48". All cable and conduit buriedgreater than 48" will be left in place and abandoned". This statement seems tocontradict itself and conflicts with Sec. 2.8 pg 2-20.Sec 2.8.1 pg 2-21 "The decommissioning and restoration process comprises ...removal of below ground structures to a depth of 48" or greater." This statementseems to conflict with Sec. 2.8.The Decommission section pg 2-21 specifies removal of overhead collection lines butsays nothing about decommissioning the huge nine mile long overhead transmissionline infrastructure in Lyme and Cape Vincent. Reading the SDEIS on the subject ofdecommissioning, leads to confusion in several areas. Unless there is a clear concisespecific statement on decommissioning, I fear that the decommissioning processcould leave a lot to be desired, especially in regard to the overhead transmission lineand the Transmission Owners Interconnection Substation, Rockledge. Remember thishuge infrastructure involves many landowners, two towns, NYS Wildlife ManagementArea, and Development Authority of the North Country (DANC). [The transmission linehas to coexist or be built along the same easementiright of way as the WesternJefferson County Regional Fresh Waterline, that runs 25 miles from Cape Vincent toGlen Park and is operated by DANC.] Further complicating the decommissioning of

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the transmission line infrastructure is the fact that if BP Alternative Energy builds theproposed Cape Vincent Wind Power Project (Volume #1, Sec. 4, Table 4-1.), then theywill be sharing the same nine mile long transmission line facilities with Acconia.With so many entities involved, and a decommission statement that is confusing andincomplete, I predict lots of trouble in 15 years when the project has reached the endof its' serviceable useful life. I am especially skeptical about the decommissionprocess, after hearing some horror stories from other project sites.Volume #1, Sec. 2.6.5, pg 2-16, Exhibit 2.6.3, shows buried interconnect cables at adepth of 3'S", which is equal to 44". On the same page 2-16 it states" ... the cable willbe placed at a minimum depth of 4S"."Volume #1, Sec. 2.S.1.2, pg 2-22, Turbine Foundation Removal. This section can bemisleading, if citizens do not realize that the 50'-60' diameter and 7'w10'thick octagonalshaped concrete foundations that contain approximately 40 truck loads of concrete foreach foundation (approximately 320 cubic yards of concrete) with steel rebar will liemore than 4S" below ground level and will not be decommissioned (removed). Whatwill be removed to a depth of 4S" is the mounting pedestal that projects up from thetop of the center of the flat concrete foundation to which the steel tower is attached.See Volume #1, Sec. 2.6.4, Exhibit 2.6.1, pg 2-14.The point is that the main concrete foundation stays in place. It is not removed. Thissituation needs to be made very clear in the decommissioning section, as I believemany citizens will be under the false impression that the entire steel reinforcedconcrete foundation will be removed. I fear that the decommissioning process couldturn into a field day for the lawyers. Please do not let this scenario happen.Volume 1, Sec. 3.6.1.1 pg.3-102. "An existing Development Authority of the NorthCountry (DANC) 12-inch (interior diameter) (fresh) water line, the Western JeffersonCounty Regional (fresh) water line is located within the abandoned railroad right-of-way proposed for the overhead transmission line route. This (fresh) water lineprovides water to homes (and businesses) in five towns, four villages, the GeneralBrown High School" (and many fire hydrants).Havi ng the 115,000 volt overhead transm lsslon line share the same rig ht of way withinfrastructure as critical to public health and safety as the DANC water line could putthe water line at risk. Transmission poles will be bored 15 feet down in close proximityto the water line that is only 5 feet below the ground.Heavy construction machinery will be running over and near the line. Poles will beplaced by auguring a bore hole approximately three feet wide and 15 feet deep. Thepotential exists for physical trauma to the water line from construction, maintenance,repairs and decommissioning of the overhead transmission line. The fresh water linehas been operating wonderfully for the past ten years and is a critical piece ofinfrastructure that provides for our health and safety. Volume #1 Sec. 3 pg. 3-10S.Please insure that the Spanish (Acciona) and the British (BP Alternative Energy) takeevery precaution necessary, to ensure the safety of our fresh water line. Water is thebasis of life. We can live without electricity, but we can't live without water.

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The subject of stray voltage is only mentioned briefly in the SOEIS. I respectfullysuggest that you require language that requires the developer to test every six monthsfor stray voltage throughout the project areas, at the developer's expense, until theproject is decommissioned.Testing should be initiated immediately at any farm where the farmer requests testingand suspects stray voltage is the cause of some problems with the animals. I haveheard stray voltage referred to as "free electricity", but I am sure farmers do not wantany "free electricity" around their animals.The SOEIS states that stray voltage will not be a problem, as the installation will beproperly grounded according to the electrical code. This is good, but as time goes on,the grounding can be compromised thru a number of causes and stray voltageproblems can be the result.Volume #2, Appendix M, pg #2 deals with the Complaint Resolution Board, it mentionsthat one of the three board members will be "a Town Officer or Employee appointed tothe position annually". Who appoints the Town Officer or Employee annually, and howis the appointment made? What "Town" is represented, Cape Vincent of Lyme? Thisis a two town project.The last sentence on the Complaint Resolution Plan Volume #2, Appendix M, pg. #2states: "The decision of the Complaint Resolution Board shall be final and bindingupon SLW and the Town". Again, I ask which Town, Cape Vincent or Lyme? This is atwo town project.Based on my recent conversations with our neighbors on Wolfe Island, home to an 86Turbine project, I now realize the importance of an effective Complaint ResolutionBoard. In my conversations, I was warned about the term "if feasible" appearing inany contracts, leases, agreements, etc.Volume #2 Appendix N "In certain locations in and around the wind facility certain TVchannels may be distorted or lost once the wind turbines are installed." I respectfullyrequest that pre-construction tests be done at developer's expense for the quality andstrength of all electromagnetic radiation signals throughout the two towns for TV, cellphone, wireless internet, AM Broadcast Radio, FM Broadcast Radio and UHF-VHFradio used by fire department, ambulance, law enforcement agencies (local/statepolice, sheriff, border patrol etc.), town highway snow plows, trucks and school buses.A post-construction test at developer's expense throughout the two towns shall alsobe done for signal quality and strength for all forms of electromagnetic radiationsignals used. It is especially important that the post-test be done for all the differentwind directions (at least eight points of the compass).Each turbine has a rotor swept area of 5,281 square meters (1.3 acres). Volume #1Table 2-1 pg. 2-7. This means each turbine occupies 1.3 acres of the sky. 53 turbinesx 1.3 acres = 69 acres. The wind direction determines how the 69 acres will beoriented in the sky and therefore what signals will be diffused, distorted, deflected,attenuated or lost by that particular wind direction/rotor orientation.

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Any degradation of signal strength/quality for any form of communication, for anywind direction, shall be made good, at developer's expense, by such things asboosters, antennas, translators, repeaters, cable, satellite receivers, etc.Volume #2, Appendix J, pg. 2, Saratoga Associates should issue an apology to thecitizens of Lyme and Cape Vincent for inferring that we are late risers. SaratogaAssociates state" ...shortly after sunrise when affected residents are typically asleeQwith shades drawn." We are a hard working community and an agriculturalcommunity.Many of the citizens of our towns are routinely up before sunrise, hard at work in theirbarns, traveling to or from work, driving school busses, snow plows, etc. What planetare the people of Saratoga Associates from? They insulted us, and at the very least,should correct the statement in their analysis.The Volume #1 Sec. 3 Pg. 3-23 states that fresh water wells will be tested pre and postproject construction for quality and quantity of water for wells within 500' of theturbines. I respectfully request that all wells in the towns of Lyme and Cape Vincent betested. With a project of this magnitude that requires blasting, auguring, pneumaticjacking, hydraulic fracturing, boring, drilling, digging and excavating there is a realpossibility that the underground fresh water aquifers in our limestone Karstenvironment could be adversely affected. The developer should be responsible formaking good any well that is compromised in quality or quantity of water. Thismitigation might possibly consist of drilling a new well, redrilling an old well, buildinga cistern and fill the cistern by tanker trucks, bottled water delivery etc. Citizens ofLyme and Cape Vincent have been getting water from their wells long before Accionaand BP ever heard of our towns. Please don't let the developers compromise our freshwater wells.

When studying the SDEIS, Iwould respectfully request that you keep in mind thecumUlative effect of all the proposed projects for our area,Volume #1, Sec. 4, Table 4-1, pg. 4..3, shows a total of 425 Commercial Turbines to beinstalled within 17 miles of Cape Vincent. This number includes the 86 turbines onWolfe Island, but does not include any turbines that may possibly be installed in Lyme.Please keep the big picture in mind. It is not just about the 53 Acciona turbines inCape Vincent. It is also about the hundreds of turbines to follow. The bigtransformation of our area will have to be done in a Regulated and Responsiblemanner:

Regulated and Responsible sighting of turbines and infrastructure Regulated and Responsible erection of turbines and infrastructure Regulated and Responsible operation and maintenance of project facilities Regulated and Responsible decommissioning of facilities

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Thank you again for the hard work you have put into Wind Power Projects proposedfor Lyme and Cape Vincent. r wish you well in your future endeavors on thismomentous project. A friend of mine describes the proposed projects as the biggestthing to come to Jefferson County since the Ice Age, when a huge glacier covered ourregion!!If you have any questions, please do not hesitate to contact me.

Respectfully submitted,D~f914~Donald J. Metzger, Jr.9050 County Route 5Chaumont, NY 13622

cc: All members of Town of Cape Vincent Planning BoardAll members of Cape Vincent Town BoardAll members of Town of Lyme Planning BoardAll members of Lyme Town Board

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Darrell Burton(.315) 654-37442386 Bruns Dr.

Cape Vincent, New York13618

E-Mail [email protected] 26, 2009Town of Cape VincentPlanning BoardRe: SDEISIt's unfortunate that you as Planning Board and the public have been told of so manyhorror stories. I know it will be hard for you all to review the results of the studies thatwere done and the comments of the public. There are so many untruths about windpower. I know of people that live very close to them and say they do not hear them, andthen we are told of others that can't stand the noise. We were told at the hearing about ashort eared owl in the area but the study did not observe any. Who do you believe?The stories go on and on.My opinion is that there are people in our community that just do not want Wind Powerin the area. They make up stories to back up their opinions.I have observed the members of our Planning Board in action since this project started. Ibelieve you all have been very open minded and conducted business properly.

I think the results of the SDEIS are an adequate report. The Wind Companies would notwant to do anything to harm the environment of the Town of Cape Vincent intentionallyor to jeopardize their own company. Furthermore if something unpredictable happens Iam sure the Wind Companies would do anything to correct the situation.

Darrell Burton, full time resident


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Mr. Richard EdsallTown of Cape Vincent Planning Board ChairmanP.O. Box 680Cape Vincent, NY 13618

May 26,2009

Dear Sir:I have a comment about SLW'S SDEIS pertaining to ice throw. SLW'S remarks on dealing withice are as follows: "Impacts from ice shedding compliance with setbacks and measures to controlpublic access, such as fences and warning signs, will minimize public safety risks associatedwith ice shedding" I would like it noted that this statement about ice shedding does not satisfymy previous comment submitted to the planning board about the lack of ice studies.In their DEIS, SLW used a report by (Morgan, Bossani, and Siefert 1988 ASSSSMENT OFSAFETY RISKS ARISING FROM WIND TURBINE IeEING) to support its data on ice.Upon downloading the complete report not just reading excerpts lifted for SLW's DEIS I foundthat the report called for ice studies to be done in three stages.

"I. Occurrence of icing conditionsAn estimate should be made of the time (number of days per year) during which icingConditions occur at the turbine site:"Heavy icing"- more than 5 days, less than 25 days icing per year."Moderate icing"-more than 1 day, less than 5 days icing per year>"Light icing"-less than 1 day icing per year."No icing't-no appropriate icing conditions occur

SLW'S rendition for their DEIS also reports "it should be noted that there has never been areported injury from ice shed by wind turbines, despite the installation of more than 6,000 mw ofwind energy worldwide." What the report actually says is this: "The lack of previous work byothers on the subject may reflect the fact that there has been no reported injury from ice thrownfrom wind turbines." This report is now eleven years old and since it was written there havebeen many documented cases of injury from turbine ice shed. I was able to find a web site withdocumented data on turbine fatalities, accidents and ice throw injuries and it provides detailedinformation as to the nature of the incident, i.e. size and quality of ice, damage to persons orproperty, and provides sources to check the accuracy of the information. I found 2.3reportedturbine ice throw "incidents" one of which was fatal.http://www.caitlmesswindfarms.co.uk!fullaccidents.pdfGiven the fact that St.Lawrence Wind introduced the Morgan, Bossani, and Siefert report toprovide assessment of safety risks arising from Wind Turbine Icing into their DEIS and the townplanning board accepted the DEIS, I would think that they would have to stand by the completereport, not just favorable excerpts"Kathryn A Hludzenski29174, Stoney Point RoadCape Vincent, NY~ ' ' c . .(j;;/ ."??~\L7. /; / [ , : / 1 . : / / / 1
http://www.caitlmesswindfarms.co.uk%21fullaccidents.pdf/http://www.caitlmesswindfarms.co.uk%21fullaccidents.pdf/


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Marlene Burton2386 Bruns Dr

Cape Vincent, NY13618

May 26, 2009Town of Cape VincentPlanning BoardRe: SDEISI am definitely in favor of Wind Energy. I believe it to be environmentallysafe. I also believe any problems that may come about in the future will beaddressed and corrected accordingly by the wind companies,I believe the SDEIS was properly conducted in order to make our part of theworld a healthier, cleaner and safer place for us, our children, andgrandchildren.

Anti groups state the wind turbines are a threat to our health (unproven), It'sa well known fact that coal mines cause more health problems to the coalminers and create health problems with carbon monoxide in the atmospherefor everyone.I truly believe Tom Rienbeck, Rich Edsell and the Board Membersare doing an honest, legally, thankless job and should be applauded for thework they have done.

Sincerely, 7~/l~' ..'! (/{t,l .. , ~_ / J !{ll4-fl~ ~t17-{_/Mar~ e Burton


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To: Thomas Rienbeck and all town officials.The SDEIS should be accepted and the project moved forward. I am not anexpert, but if the credentials of the investigating parties are valid, I believethe report is sufficientThe very vocal minority in this town would have you believe the turbinesare a menace to our health. I believe that there will be people who willdevelop health problems due the turbines. These are the people who areconvinced they will. The truth is, the positive benefit to our health from theclean power far outweighs the negative self-induced of the few. The same istrue for the birds, bats and all other wildlife. Also, as we have heard frompeople who have turbines in their areas that proclaim noise pollution andflicker problems. These people just happen to have been opposed to theturbines before construction.The vocal minority has tried to stop the turbines with; maliciouspropaganda, at the voting booth, and in the courts. Please do your civic dutyand uphold the rights of the majority.Thank you,Lj! Docteur /)r/!~;?~.


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May 19, 2009


Upon hearing of the many health, safety and environmental issues surrounding the Acciona(St Lawrence Wind Farm) wind turbine project, I urge you to impose a moratorium of atleast 12 months to investigate and determine if this project is safe for our town. The issuesof accurate measurement of ambient noise levels, night time noise levels affecting sleep,project effect on our water supplies, shadow flicker effects, migratory bird impact, and thedominant visual impact of 390 foot tall turbines on our landscape need to be resolved.Health, safety, and environmental concerns should be more important than any amount ofmoney to be gained from this project

Thank you. . 0~~ Y'v\ ~AJ\5lrL~ox- \LyC _ C A ~ . \ { \ ~ C 'J f\A _t .

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PD ..Box 204Cape Vincent, NY 13618

May 29, 2009

Mr. Tom Rienbeck, Town of Cape Vincent SupervisorP 00 Box 680Cape Vincent, New York 13618Dear Mr. Rienbeck:In Cape Vincent the two proposed wind farm developers of a combined 193 wind turbines areattempting to move forward rapidly .. It is imperative that they properly complete their pre-operational studies before any consideration is given to approvaL My comments relate only tothe Acciona S1.Lawrence Wind Farm pre-operational studies and the SDEIS. They havesubmitted a great many pages of often unrelated and unnecessary data without resolving the realissues related to having a town ful1 of 390' wind towers. Areas of interest to me, and I hopeDEC, are the extremely inadequate studies of animals, invasive plants and noise.The following turtles and birds are of special interest to me:

Blandings Turtles-NYS EndangeredBats-all bats especially Indiana Bats (Federally Endangered)Hawks-all hawks especially Northern HarrierShort-eared Owls-NYS EndangeredBreeding BirdsMigrants-including Ducks and Geese

The developer of the St. Lawrence Wind Farm (Acciona) is required to determine what species ofplants and animals are present in the area affected by their activities, they are also required todetermine the potential affects of their activities on those same plants and animals and finallythey should show how they will avoid or mitigate any adverse affects. None of these steps havebeen adequately completed, but the town is rushing ahead as if all had been satisfactorilycompleted.The problem as I see it in Cape Vincent is: The developer hires people to provide data to enhancetheir preconceived idea that the project will enhance all ofthe Cape Vincent habitat The abovementioned turtles and birds will then be preserved according to their logic. NOT TRUE.. Onlyproper utilization of sound and unbiased studies and resulting data will protect our town.


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Page TwoMay 29, 2009We have deep rooted problems in attempting to resolve the wind tower issue in this town. TheTown Board is conflicted as is the Zoning Board (including the Chairman), These people thathave little or no biological training are making decisions favoring the developer that will affectthe town drastically in the future. Favorable decisions are often rendered no matter how poor orwrong the information is that is provided,The bird and turtle studies are inadequate and never even develop an accurate portrayal of thevarious populations as they exist today. The developer fills many pages with information aboutother wind farms that don't apply to Cape Vincent and then neglects local information such asthe data generated in the 1980 to 1984 NYS Breeding Bird Atlas.Studies and examples of deficiencies:

BLANDINGS TURTLES: The developer and paid consultants have been unable todetermine where the turtles exist in town so they have no idea of population size. Yet,they want us to believe that once the wind towers are in place the turtles will survive.Additional effort is required to locate this species. Once location and numbers areknown they can move forward and determine possible adverse affects and develop awind turbine placement plan that will avoid the turtle habitat or mitigate the problem.BATS: Studies have been completed. Several Indiana Bats were captured in 2006, butin the SDEIS there is no report of follow-up studies on the Indiana Bat The studies doneare too narrow in scope and avoid review of such problems as white nose syndrome andhow that relates to expected mortality rates caused by wind tower blades. Much more andbetter information is necessary in order to mitigate turbine mortality of bats.Cape Vincent is near the Glen Park, NY hibemaculum and at least 3 years of sound pre-construction bat studies should be required to learn how the wind towers will effect thevarious populations of bat species.HAWKS: The studies done to date are minimal. A case in point is the Northern Harrierthat is NYS threatened and not adequately studied. These birds nest in our town and willrequire protection" Acciona consultants are not providing population status and nomitigation to protect the species can be applied at this time,Other hawks such as Rough-legged, Sharp-shinned, Coopers and American Kestreldepend on areas such as Cape Vincent for their survival, Rough-legs require over-wintering habitat while the other three species successfully nest here. The fact that alllocal hawks are stressed means more and better studies are required.


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Page ThreeMay 29,2009

OWLS: Cape Vincent habitat is of particular importance to Short-eared Owl survivaL Itis inconceivable that people hired to study birds in the Acciona wind tower area nevereven located ONE! The developer either hired unqualified people to collect bird data orthey simply don't care. I have personally shown Short-eared Owls to many bird watchersand nature lovers that visited the area in recent years" Yes, they are here and requireprotection from wind towers.The developer has not located the species and therefore is unable to determine thenumber of Short-eared Owls present Once they know where the Owls are and how manythey can begin the process of mitigating potential damage. Several years will be required ..MIGRATING BIRDS: The studies of migrating birds are especially poor. The countersare not able to identify ducks and geese in flight and this is compounded by short studytimes and too few counts. Information is required on all bird migration and what can bedone to avoid collisions. Wind tower siting should not be anticipated until this iscompleted.Note: In 2005, I spent one May morning watching birds on Gosier Road in Cape VincentThis site is in the Acciona footprint Large numbers of ducks and geese were migratingnorth and I decided to make an impromptu count Over 20,000 ducks and geese werecounted that morning ..Of these, over 1,000 were Snow Geese, a few hundred wereMallard Ducks and approximately 19,000 Canada Geese were tallied. This was in a onemile wide area that I selected because I could satisfactorily identify and count birds in theflight path. Many additional geese were not counted because they were outside the countarea ..I believe that more birds migrated through the area that morning than wererepresented in all studies conducted and reported on in the OEIS and the SDEISrBREEDING BIRDS: This study should start from scratch. A good place to start is the2000 to 2004 New York State Breeding Bird Atlas,Major problem identified in bird studies: Adequate bird studies can't be completedunless you have competent bird counters that can identify birds by sight and sound ..Counts of hawks, owls, ducks, geese, gulls and songbirds were all poorly done and shouldbe expanded and repeated,INVASIVE PLANTS: The disturbed earth created by wind farm construction willcompromise the ongoing SWALLOW-WORT control effort in the entire Town of CapeVincent This invasive species is being controlled with funding by NYS at the presenttime, There is no specific mention in the SDEIS of this control effort which is funded fortwo more years. Stopping the possible spread of Swallow-wort and other invasive speciesshould be given high priority, Methodology for implementing this stoppage must bedeveloped prior to wind tower approval.


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Page FourMay 29,2009

NOISE: The noise issue is the most interesting and confounding issue of the CapeVincent wind tower sites, The developer hired a consultant (Hessler) that appears toknow exactly what decibel levels are required for maximum placement of wind towers,Amazingly, the data provided by this consultant came out at just the proper level formaximum wind tower placementThis information on decibel background levels and the methodology Hessler used isbeing challenged by several noise experts, I believe the consultant hired by the Town ofCape Vincent (Cavanaugh Tossi Associates, Inc.) carne up with lower decibelbackground levels. It is imperative that the Town Board and Zoning Board members getthis right because ALL the residents will be affected by the noise levels,In addition to the consultant Cape Vincent hired, another consultant was hired (Shomerand Associates) and neither of these (Shomer or Cavanaugh) agreed with the resultsproduced by Hessler. Paul Carr a local noise expert also does not agree with Hessler.Is tills whole issue about how many wind towers can be crammed into Cape Vincent?How about protecting the non-participating residents? Elected officials and theirappointees (zoning officials) are expected to do right by all of their voters .. In my opinionthis in not being done ..

Sincerely,

jJ


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TO: Town of Cape Vincent Planning BoardFROM: Donald J. Metzger, Jr. (Year round resident/property owner Town

of Lyme and business owner in Cape Vincent)DATE: May 26,2009SUBJECT: My comments on St. Lawrence Wind Power ProjectTowns of Cape Vincent and Lyme SDEIS.I want to thank the Cape Vincent board members for all of the work that you have putinto the proposed St. Lawrence (Acciona) Wind Project for the towns of Cape Vincentand Lyme.I also respectfully request that you continue your due diligence 0 1 " 1 1 this proposedproject, as you will be setting a precedent with this project. Kindly keep in mind thatfollowing st. Lawrence Wind Power Project (Acciona/Spain) will be the BP AlternativeEnergy (British Petroleum) proposed Cape Vincent Wind Power Project of anadditional 140 turbines in the Town of Cape Vincent alone.The British Project (140 turbines) will make the Spanish Project (53 turbines) seemsmall. Please keep in mind that the ground rules you set in place for the Spanishproject will be setting the precedent for ground rules for the huge British project. Ifstrict, comprehensive, clear, ground rules, that will stand up in court, are put in place,then this will help prevent the towns of Cape Vincent and Lyme from becoming"Company Towns".Volume #1, Section 2.2 page 2-3"After the public comment period on the SDEIS, two alternative_procedural pathwayswould be available to the lead agency. The town of Cape Vincent Planning Boardcould require preparation of a Final EIS (FEIS). If that alternative pathway is chosen,the following steps would be taken": Step #5 H10-day public consideration period"A 10 day public consideration period is simply not enough time for the citizens of thetowns of Lyme and Cape Vincent to consider and comment on a project of the size,scope and complexity of St. Lawrence Wind. Iwould respectfully request that the"consideration period" (comment period) be a minimum of 30 days.The second of the "two alternative procedural pathways that would be available to thelead agency" is not defined, explained or discussed. What is the second of the twoalternative procedural pathways available to the lead agency? If the secondalternative pathway is chosen, what are the steps that would be taken?Volume #1, Section 28.1 page 2-21, the decommissioning of the nine mile long 115,000volt, high tension overhead transmission line from Cape Vincent Project collectorsubstation Favret Road to the National Grid substation on County Route 179,Chaumont, is not mentioned. There is a lot of infrastructure involved in this aspect ofthe project that involves two towns ie. Lyme and Cape Vincent, hundreds of woodenpoles that are bored 15 feet into the ground and extend approximately 80 feet above

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the ground (approximately twice the height of roadside utility poles) Volume #1 Sec2.5.5 pg 2-9 and 2-10. There will be three wires for the three phase current and onewire at the top of the poles that functions as a static wire/shield wire for lightingprotection with a project data communication line inside.Four suspended wires for nine miles means, 36 miles of wires in the air. Thisoverhead transmission system will connect to a yet to be built by Acciona,Transmission Owner Interconnection Substation to be located between the east bankof the Chaumont River and the west side of county RT. #179 Town of Lyme. This newattachment substation will be called "Rockledge" (Volume #2 Appendix K) and willconnect to the existing National Grid substation on the east side of county RT #179,Town of Lyme.The nine mile long overhead transmission line will have a 100' wide easement/right ofway (Volume #1, Table 2-1 pg 2-13 and will cross five roads in the town of Lyme andtwo roads in the Town of Cape Vincent (Volume #2, Appendix K). Several streams,creeks and the Chaumont River will also be crossed.

Volume #1 Sec. 2.8.1.4 page 2-22 Discusses decommissioning overhead collectionlines. These overhead collection lines are not to be confused with the overheadtransmission lines. The overhead collection lines are part of the 37 mile system ofburied and overhead wires that connect the turbines with the Project CollectionSubstation on Favret Road, Cape Vincent.Volume #1 Sec 2.8, pg 2-20 Decommissioning "Except for the underground collectionsystem, which is provided for under a perpetual easemen,t SLW's lease agreementswith the landowners provide that all wind project facilities will be removed to a depthof four feet (48") below grade following the end of the project's useful life."Volume #1 Sec. 2.8.1.3 2-22 Underground collection cables "The cables andconduits ....will be cut back to a depth greater than 48". All cable and conduit buriedgreater than 48" will be left in place and abandoned". This statement seems tocontradict itself and conflicts with Sec. 2.8 pg 2-20.Sec 2..8.1 pg 2-21 "The decommissioning and restoration process comprises .,.removal of below ground structures to a depth of 48" or greater." This statementseems to conflict with Sec. 2.8.The Decommission section pg 2-21 specifies removal of overhead collection lines butsays nothing about decommissioning the huge nine mile long overhead transmissionline infrastructure in Lyme and Cape Vincent. Reading the SDEIS on the subject ofdecommissioning, leads to confusion in several areas. Unless there is a clear concisespecific statement on decommissioning, I fear that the decommissioning processcould leave a lot to be desired, especially in regard to the overhead transmission lineand the Transmission Owners Interconnection Substation, Rockledge. Remember thishuge infrastructure involves many landowners, two towns, NYS Wildlife ManagementArea, and Development Authority of the North Country (DANC). [The transmission linehas to coexist or be built along the same easement/right of way as the WesternJefferson County Regional Fresh Waterline, that runs 25 miles from Cape Vincent toGlen Park and is operated by DANe.] Further complicating the decommissioning of

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the transmission line infrastructure is the fact that if BP Alternative Energy builds theproposed Cape Vincent Wind Power Project (Volume #1, Sec. 4, Table 4-1.), then theywill be sharing the same nine mile long transmission line facilities with Acconia.With so many entities involved, and a decommission statement that is confusing andincomplete, I predict lots of trouble in 15 years when the project has reached the endof its' serviceable useful life. I am especially skeptical about the decommissionprocess, after hearing some horror stories from other project sites.Volume #1, Sec. 2.6.5, pg 2-16, Exhibit 2.6.3, shows buried interconnect cables at adepth of 3'8", which is equal to 44". On the same page 2-16 it states " ... the cable willbe placed at a minimum depth of 48"."Volume #1, Sec. 2.8.1.2, pg 2-22, Turbine Foundation Removal. This section can bemisleading, if citizens do not realize that the 50'-60' diameter and 7'-10' thick octagonalshaped concrete foundations that contain approximately 40 truck loads of concrete foreach foundation (approximately 320 cubic yards of concrete) with steel rebar will liemore than 48" below ground level and will not be decommissioned (removed). Whatwill be removed to a depth of 48" is the mounting pedestal that projects up from thetop of the center of the flat concrete foundation to which the steel tower is attached.See Volume #1, Sec. 2.6.4, Exhibit 2.6,1, pg 2-14.The point is that the main concrete foundation stays in place. It is not removed. Thissituation needs to be made very clear in the decommissioning section, as I believemany citizens will be under the false impression that the entire steel reinforcedconcrete foundation will be removed. I fear that the decommissioning process couldturn into a field day for the lawyers. Please do not let this scenario happen.Volume 1, Sec. 3.6.1.1 pg. 3-102. "An existing Development Authority of the NorthCountry (DANC) 12-inch (interior diameter) (fresh) water line, the Western JeffersonCounty Regional (fresh) water line is located within the abandoned railroad right-of-way proposed for the overhead transmission line route. This (fresh) water lineprovides water to homes (and businesses) in five towns, four villages, the GeneralBrown High School;' (and many fire hydrants).Having the 115,000 volt overhead transmission line share the same right of way withinfrastructure as critical to public health and safety as the DANC water line could putthe water line at risk. Transmission poles will be bored 15 feet down in close proximityto the water line that is only 5 feet below the ground.Heavy construction machinery will be running over and near the line, Poles will beplaced by auguring a bore hole approximately three feet wide and 15 feet deep. Thepotential exists for physical trauma to the water line from construction, maintenance,repairs and decommissioning of the overhead transmission line. The fresh water linehas been operating wonderfully for the past ten years and is a critical piece ofinfrastructure that provides for our health and safety. Volume #1 Sec. 3 pg. 3-108.Please insure that the Spanish (Acciona) and the British (BP Alternative Energy) takeevery precaution necessary, to ensure the safety of our fresh water line. Water is thebasis of life. We can live without electricity, but we can't live without water ... ,-J-


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The subject of stray voltage is only mentioned briefly in the SDEIS. I respectfullysuggest that you require language that requires the developer to test every six monthsfor stray voltage throughout the project areas, at the developer's expense, until theproject is decommissioned.Testing should be initiated immediately at any farm where the farmer requests testingand suspects stray voltage is the cause of some problems with the animals. I haveheard stray voltage referred to as "free electricity", but I am sure farmers do not wantany "free electricity" around their animals.The SDEIS states that stray voltage will not be a problem, as the installation will beproperly grounded according to the electrical code. This is good, but as time goes on,the grounding can be compromised thru a number of causes and stray voltageproblems can be the result.Volume #2, Appendix M, pg #2 deals with the Complaint Resolution Board, it mentionsthat one of the three board members will be "a Town Officer or Employee appointed tothe position annually". Who appoints the Town Officer or Employee annually, and howis the appointment made? What "Town" is represented, Cape Vincent of Lyme? Thisis a two town projectThe last sentence on the Complaint Resolution Plan Volume #2, Appendix M, pg. #2states: "The decision of the Complaint Resolution Board shall be final and bindingupon SLW and the Town". Again, I ask which Town, Cape Vincent or Lyme? This is atwo town project.Based on my recent conversations with our neighbors on Wolfe Island, home to an 86Turbine project, I now realize the importance of an effective Complaint ResolutionBoard. In my conversations, I was warned about the term "if feasible" appearing inany contracts, leases, agreements, etc.Volume #2 Appendix N "In certain locations in and around the wind facility certain TVchannels may be distorted or lost once the wind turbines are installed." I respectfullyrequest that pre-construction tests be done at developer's expense for the quality andstrength of all electromagnetic radiation signals throughout the two towns for TV, cellphone, wireless internet, AM Broadcast Radio, FM Broadcast Radio and UHF-VHFradio used by fire department, ambulance, law enforcement agencies (local/statepolice, sheriff, border patrol etc.), town highway snow plows, trucks and school buses.A post-construction test at developer's expense throughout the two towns shall alsobe done for signal quality and strength for all forms of electromagnetic radiationsignals used. It is especially important that the post-test be done for all the differentwind directions (at least eight points of the compass).Each turbine has a rotor swept area of 5,281 square meters (1.3 acres). Volume #1Table 2-1 pg. 2-7. This means each turbine occupies 1.3 acres of the sky. 53 turbinesx 1.3acres = 69 acres. The wind direction determines how the 69 acres will beoriented in the sky and therefore what signals will be diffused, distorted, deflected,attenuated or lost by that particular wind direction/rotor orientation.

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Any degradation of signal strength/quality for any form of communication, for anywind direction, shall be made good, at developer's expense, by such things asboosters, antennas, translators, repeaters, cable, satellite receivers, etc.Volume #2, Appendix J, pg, 2, Saratoga Associates should issue an apology to thecitizens of Lyme and Cape Vincent for inferring that we are late risers. SaratogaAssociates state ~'..shortly after sunrise when affected residents are typically asleepwith shades drawn." We are a hard working community and an agriculturalcommunity.Many of the citizens of our towns are routinely up before sunrise, hard at work in theirbarns, traveling to or from work, driving school busses, snow plows, etc. What planetare the people of Saratoga Associates from? They insulted us, and at the very least,should correct the statement in their analysis.The Volume #1 Sec. 3 Pg. 3-23 states that fresh water wells will be tested pre and postproject construction for quality and quantity of water for wells within 500' of theturbines. I respectfully request that all wells in the towns of Lyme and Cape Vincent betested. With a project of this magnitude that requires blasting, auguring, pneumaticjacking, hydraulic fracturing, boring, drilling, digging and excavating there is a realpossibility that the underground fresh water aquifers in our limestone Karstenvironment could be adversely affected, The developer should be responsible formaking good any well that is compromised in quality or quantity of water. Thismitigation might possibly consist of drilling a new well, redrilling an old well, buildinga cistern and fill the cistern by tanker trucks, bottled water delivery etc. Citizens ofLyme and Cape Vincent have been getting water from their wells long before Accionaand BP ever heard of our towns. Please don't let the developers compromise our freshwater wells.

When studying the SDEIS, Iwould respectfully request that you keep in mind thecumulative effect of all the proposed projects for our area.Volume #1, Sec. 4, Table 4-1, pg, 4-3, shows a total of 425 Commercial Turbines to beinstalled within 17 miles of Cape Vincent. This number includes the 86 turbines onWolfe Island, but does not include any turbines that may possibly be installed in Lyme.Please keep the big picture in mind. It is not just about the 53 Acciona turbines inCape Vincent. It is also about the hundreds of turbines to follow, The bigtransformation of our area will have to be done in a Regulated and Responsiblemanner:

Regulated and Responsible sighting of turbines and infrastructure Regulated and Responsible erection of turbines and infrastructure Regulated and Responsible operation and maintenance of project facilities Regulated and Responsible decommissioning of facilities

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Thank you again for the hard work you have put into Wind Power Projects proposedfor Lyme and Cape Vincent. Iwish you well in your future endeavors on thismomentous project. A friend of mine describes the proposed projects as the biggestthing to corne to Jefferson County since the Ice Age, when a huge glacier covered ourregion!!If you have any questions, please do not hesitate to contact me.

Respectfully submitted,

/ 5 t > r t 4 R 4 r r t Ld ; ; 1 f 1 ~Donald J. Metzger, Jr.9050 County Route 5Chaumont, NY 13622

cc: All members of Town of Cape Vincent Planning BoardAll members of Cape Vincent Town BoardAll members of Town of Lyme Planning BoardAll members of Lyme Town Board

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May 19, 2009


Upon hearing of the many health, safety and environmental issues surrounding the Acciona(Sf Lawrence Wind Farm) wind turbine project, I urge you to impose a moratorium of atleast 12 months to investigate and determine if this pro,iectis safe for our town. The issuesof accurate measurement of ambient noise levels, night time noise levels affecting sleep,project effect on our water supplies, shadow flicker effects, migratory bird impact, and thedominant visual impact of 390 foot tall turbines on our landscape need to be resolved.Health, safety, and environmental concerns should be more important than any amount ofmoney to be gained from this project

st.lawrence wind sdeis public comment letters 3 of 5

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