Sunday, January 3, 2010

Galloo Island Cumulative Effects

I found this letter on line; I decided to post it because it directly relates to the Galloo Island Wind project.
Wolfe Island now has industrial wind turbines, the cumulative effects will be devastating to bird populations in Eastern Ontario and New York State.



Robert Miller
Canadian Renewable Energy Corp
c/o Stantec Consulting Limited
361 Southgate Drive
Guelph, Ontario K1G 3MS

CEAR 04-04-4667 Wolfe Island Wind Turbine Project: ERR

Dear Mr. Miller,

The purpose of this letter is to state my persistent concerns about the Cumulative Effects Report of Environmental Review Report (ERR) released by Stantec in support of the proposed Wolfe Island Wind Turbine Project and to request that the process be elevated to a panel review according to the federal process and an independent environmental review according to the provincial process.

ERR Cumulative Effects
The ERR Cumulative Effects (Chapter 8) refers to the transboundary effects of developments in the Point Peninsula and Upper St. Lawrence IBAs, the Ashland Bird Conservation Reserve and regionally significant shoreline and grassland habitat in Jefferson County, New York. It also includes development in Kingston and surrounding areas.

I have reviewed the section pertaining to the projected cumulative effects of the project with regard to certain and reasonably foreseeable activities at a regional level (ERR 8.1). I am concerned that the proponent has excluded the following wind turbine projects proposed within the zone of influence for the Wolfe Island ERR:

• 77 turbine project for Galloo Island, Henderson County, New York, by UpState NY Power Corp
• 80-100 turbine project for Amherst Island (owned by the proponent, CREC)

I also contend that cumulative effects of wind turbine developments in other Important Bird Areas (IBA) along the northern lakeshore of eastern Ontario should be considered in the ERR. These projects include:

• 140 turbine project offshore in Prince Edward County by Trillium Power Energy Corporation
• Point Petre, the Royal Road Project (owned by the proponent)

These projects should be added to the projects included in the cumulative effects report:

• 200 turbine projects for Jefferson County, New York by BP Alternative Energy Project and AES Acciona Wind power. Jefferson County has four proposed wind farms on the drawing board, all in various phases of planning.

The sudden, intensive concentration of turbines along the southern and northern shores of eastern Lake Ontario inside Important Bird Areas will certainly alter the Eastern Ontario environment and biodiversity through nibbling loss and spatial and temporal crowding, and will dramatically effect migratory bird populations. The current ERR indicates a significant, irreversible negative effects on avian populations as a result of foreseeable activities in the region. These “foreseeable activities” must include wind turbine projects in development for Amherst Island and Galloo Island.

Galloo Island
Galloo Island, New York, an IBA located in Eastern Lake Ontario across from Wolfe and Amherst Islands, is in the introductory stages of the approval process and is reasonably foreseeable. The Municipal Planning Board for the Town of Hounsfield has received site plans from the company which describe the construction of 77 turbines. The Planning Board is awaiting responses from lead agencies in the first step of the SEQR process. Galloo Island will impact cumulative effects related to migratory and congregatory birds as well as visual landscape, cultural and economic effects for Wolfe Island.

Galloo Island hosts an exceptional breeding concentration of colonial waterbirds, including the largest Ring-billed Gull colony in the U.S. (an estimated 60,000 pairs in 2003), New York’s only Caspian Tern colony (1,560 pairs in 2004), and the largest Double-crested Cormorant colony in New York (3,967 pairs in 2004). Smaller numbers of Blackcrowned Night-Herons (three pairs in 2004), Herring Gulls (313 pairs in 2003), and Great Black-backed Gulls (12 pairs in 2003) nest on the island as well. (Source: Audubon Society, 2007)

Amherst Island
Kingston Economic Development Corporation (KEDCO), an official stakeholder, indicated concerns that the Amherst Island project, owned by the proponent (CREC), be identified as a significant regional activity for consideration in the study. Stantec excluded Amherst Island, describing the project as “not reasonably foreseeable.” (ERR Table 8.1) Stantec also excluded developments in Prince Edward County, and additional concern for KEDCO.

Stantec states that the Amherst Island Wind Project was excluded from the CEA analysis as it is only a “prospect” and is not yet in the approval process. Public information available from residents of Amherst Island and media sources belies the assertion that the Amherst Island Project is not foreseeable. Land has been optioned for years, research has been completed by Vector and Gaia Wind companies, a previous site plan proposal is available, and the project is progressing and expanding following the acquisition of land-lease options by the proponent.

Amherst Island is included in the Visual Change Model of the ERR when considering negative effects on landscape viewing but is excluded from sections dealing with effects on avian populations.

Amherst Island is situated 4 km east of Kingston and rests between Wolfe Island to the east and Prince Edward County peninsula to the west. Amherst Island is a recognized IBA and is considered globally and continentally significant with regard to congregatory species (http://www.bsc-eoc.org/iba/site.jsp?siteID=ON062). Wolfe and Amherst Islands have gained international recognition for concentrations of wintering hawks and owls that are often present. Amherst Island is one of the few remaining breeding habitats for raptors such as Rough-Legged and Red-Tailed Hawks and owls. Short-Eared Owls are recognized under COSEWIC to be of Special Concern. Amherst and Wolfe Islands also support grassland songbirds; species with dwindling populations due to habitat fragmentation, according to the Canadian IBA Directory and the Audubon Society (2007).

The Canadian IBA Directory states that Wolfe Island and Amherst Island share the same potential and ongoing threats: disturbance, intensified management, urban and industrial development.

Negative Effects on Avian Populations in Eastern Ontario and New York IBAs
The ERR states that the project on Wolfe Island will result in significant negative effects on populations of raptors. The ancillary and access roads will fragment habitat, nests will be disturbed and the breeding and flight displays of Short-Eared Owls will make breeding pairs highly susceptible to blade strike. The ERR anticipates that the baseline population of Short-Eared Owls will decline and populations will not recover for the life of the project. A similar prediction is made with regard to Rough-legged Hawks. The ERR predicts that Bald Eagles will likely relocate permanently to avoid being “hemmed in” by the more than 200 turbines to be erected in New York and 86 turbines along western and southern shores of Wolfe Island. Mitigation strategies will not prevent the decline of SARA identified species as well as populations of grassland birds and raptors below baseline levels, according to the ERR.

“The negative cumulative effects on avian mortality and migration in the region will be long-term and irreversible” (ERR, Table 8.3 Significance of Cumulative Effects).

Questions that Remain Unanswered
• What would be the cumulative effect of the projects in Jefferson County (200 turbines) and Galloo Island (77 turbines), the Amherst Island and Wolfe Island projects (186 turbines) and the Prince Edward Point projects (153 turbines) on the baseline population of Short-Eared Owls, Rough-legged Hawks, and Bald Eagle in the Eastern Lake Ontario region?
• What would be the cumulative effect on other raptor species, grassland songbird populations and migratory birds (including waterfowl)?

The ERR states that migrating waterfowl, grassland birds and raptors will alter migration and other behaviors to avoid large concentrations of turbines. Given the density of turbines projected for the northern and southern shores:

• Where will avian populations find refuge in the region? Can the proponent identify remaining regional habitat suitable for sustaining displaced avian populations?

The CEA boundary for consideration of cumulative effects should be expanded to include Galloo Island, Amherst Island and the developments in Prince Edward Point IBA, and should include the potential effects of avian mortality, habitat fragmentation, biodiversity and changes to migration patterns. The current ERR indicates a significant, irreversible negative effects on avian populations as a result of foreseeable activities in the region.

I respectfully request that the ERR for the Wolfe Island Wind Project be elevated to a panel review according to the federal process and be elevated to an independent environmental review according to the provincial process.

Leslie Kaduck
Ottawa, ON

1 comment:

Anonymous said...

Someone please tell the birds they are not in Canada's future plans.