Not long ago Nature Canada reported that the Wolfe Island wind complex has a turbine kill rate for birds and bats seven times the industry average in Canada primarily because it is located in the wrong spot.
Wolfe Island wind has been operational since April of 2009, avian and bat mortality rates have been available since May of 2010.
Nevertheless, Acciona/ British Petroleum*chose to use data from Maple Ridge Wind farm some 40 miles away to calculate projected avian and bat mortality rates for their St. Lawrence wind complex.
However, there is more to this story the letter below points out a disturbing disparity between the proposed wind turbines in Cape Vincent and an earlier wind project proposed in the same migratory flyway (wrong spot) as Cape Vincent.
February 15, 2011
Mr. Stephen Tomasik - Project Manager
Major Projects Management Section
Division of Environmental Permits
NYS Department of Environmental Conservation
625 Broadway - 4th Floor
Albany, New York 12233-1750
We want to supplement comments regarding the St. Lawrence Wind Project Article 11application we sent you earlier (January 13, 2011). We were recently given a copy of NYSDEC's comments on the Chautauqua Wind Farm Project Proposal dated December 31, 2004 (see attached). We were impressed with the rigor of this review, conclusions and recommendations.
We also want to point out some points that were made in DEC's review that we believe have relevance to the situation here in Cape Vincent with
Acciona's Article 11 application.
In the overview DEC notes the Avian Risk Assessment (ARA) by Chautauqua “suffers from several fundamental flaws;” one of which is related to using “inappropriately derived” information from other studies (p.1). This is basically the same argument we made in our previous letter. To make projections of potential losses without considering avian mortality data from a wind farm in the immediate vicinity and time frame is also a fundamental flaw. The DEC made that point in 2004 and you need to make that point again in 2011.
In its review of the Chautauqua Wind Project, DEC touted the value of the Cape Vincent area as a migratory flyway: “The eastern and southern shore of Lake Ontario and eastern shore of Lake Erie are documented and well recognized migratory pathways, which are important within Eastern North America on a regional scale, particularly during spring migration as birds move north (p.2).” We know this opinion has not changed, but it should be stated clearly and forcefully. The importance of this flyway requires the Department to take a strong position to ensure the flyway has adequate protections. We cannot see how this can be done without first examining the complete 3-year study of avian mortality from the Wolfe Island Wind Project. If the mortality estimates for year-one in their study are lowest, then the Department may regret not having waited until the post-operational avian mortality study is completed.
In the summary comments DEC highlights the facts that the Chautauqua area “is an extremely important bird/raptor migration area,” as is the Cape Vincent area, and adds that Bald Eagles can be expected to use the project area. Again, similar to the situation we have here. Lastly, in our previous letter we argued for a cumulative assessment of wind turbine impacts for our region based on a reasonable projected turbine build-out.The same point was made in 2004 by the DEC, “The cumulative impact of all of these projects would need to be taken into consideration to truly measure “biological significance” on our bird populations (p.27).” Regardless of how it may be justified, we believe it is professionally irresponsible to not consider potential cumulative impacts from future commercial wind developments along the eastern shore of Lake Ontario.
Thank you again for the opportunity to comment and we hope you agree that waiting for the completion of the Wolfe Island studies is the appropriate position for the Department on Acciona's Article 11 application.
Thomas E. Brown – NYCDEC Retired Regional Director
Clifford Schneider – NYSDEC Retired Lake Ontario Unit Leader
Kenneth Kogut – Region 6 Natural Resources Supervisor
Link here to read DEC Letter_ Avian Turbine Risk Assessment Chautauqua 12-31-0
*Note: February 10, 2012, it was announced that British Petroleum purchased Acciona's interests in the St. Lawrence Industrial wind complex. To date nothing has changed concerning the configuration of these projects.
Additionally, British Petroleum and Acciona used the same Avian and Bat studies for their wind projects.