BP outrageously states that "the project is not anticipated to have a potentially significant adverse impact..." on the community.

December 23, 2012

Honorable Jeffrey C. Cohen

Acting Secretary, New York State Public Service Commission

Three Empire State Plaza

Albany, New York 12223-1350

Re: Case 12-F-0410 - Cape Vincent Wind Power

Dear Acting Secretary Cohen:

I am a member of the Cape Vincent Town Board. I am writing as an individual to add a comment on the revised Public Involvement Program (PIP) submitted by BP on 16 November 2012.

BP outrageously states on page 7 of their submission that "the project is not anticipated to have a potentially significant adverse impact..." on the community.

In fact,  the NYS Historic Preservation Office had come to the very opposite determination in a letter from John A. Bonafide to Andrew C. Davis dated May 28, 2008 for the former St Lawrence Wind project which proposed significantly fewer turbines but in a generally similar configuration. Mr. Bonafide wrote that "sufficient information does exist to determine that under section 14.07.1 { c ) of the NYS Parks and Recreation Law the undertaking will have an Adverse Effect on cultural resources. The introduction of the sleek ultramodern turbines forever alters and changes the rural setting which serves as backdrop for the architectural cultural and scenic tourism heritage of the communities."

The project map submitted with the PIP, although it does not indicate details requested by the Cape Vincent Planning and Town Boards, is sufficient to show that the proposed project is antagonistic to the Cape Vincent Comprehensive Plan and grossly non-compliant with the Cape Vincent Zoning Law. How could the proposed 124 industrial turbines not create an Adverse Effect on the community's inspired views along the St Lawrence River and Lake Ontario, its Broadway Historic District and its many distinguished Historic Preservation properties, as well as the community's predominantly view sensitive property tax assessment base and tourism based economy?

BP writes on page 3 in paragraph B that they have reduced the number of turbines in their proposal by 11 after an extensive review because of their proximity to the river in response to community feedback. The wording of the PIP is such that one might infer that there has been some outreach in this matter by BP to the community of Cape Vincent. This is categorically not the case. There has been to date no communication between BP and either the Cape Vincent Planning Board or the Cape Vincent Town Board on any siting issues nor has there been, as I see it, any communication that could be considered genuine outreach.

For the Article X law to function properly I believe there needs to be early on outreach to potential stakeholders and interested parties. Only by engaging insincere outreach can the economy of time and the fairness aspired to in the Article X law be achieved. To date BP has engaged only in token outreach. At the 23 October 2012 meeting between BP and the Towns of Cape Vincent and Lyme I asked Richard Chandler of BP repeatedly if BP intended to comply with the Cape Vincent Zoning Law. Mr. Chandler declined to answer evasively and willfully. In the initial BP open house empty statements and evasions were constants. An easel labeled 'Sound' was not supplemented by any data either technical or otherwise. In the second BP open house on the Article X law a power point on the process involved was read but no questions specific to the Cape Vincent project were answered. On the BP website to date the box in which "Outreach" is intended to be tracked remains blank.

1 have not been able to locate in the PIP a list of neighboring communities that shall be included as stakeholders and interested parties. This is an omission that should be corrected. Because of the size and scale of the turbines and because the overall region is relatively flat, view sensitive and the fact that there are historic preservation assets in many communities, careful attention should be given to possible regional impacts and the possible cumulative effect of all of the industrial turbine projects that may be constructed. Nearby communities in which projects reportedly may be built are the Towns of Clayton, Lyme, Orleans,Theresa, Hounsfield and Henderson. In Canada construction of wind turbines has been discussed in many areas on and near Wolfe Island and along the St Lawrence River. As we have experienced in Cape Vincent with the Wolfe Island project industrial scale turbines alter the view shed in a major way.

Affected parties have a right to be advised as to what is being proposed.

More outreach should be provided for the experts on the area as an important bird flyway. Wolfe Island is a recognized Important Bird Area and so is Derby Hill in Mexico NY. The entire Cape Vincent area should be evaluated as to the impact of turbines on migratory birds. Organizations such as Audubon NY, Onondaga Audubon, and the American Bird Conservancy should be consulted.

Finally the question should be asked if BP is minimally engaged in the Article X review process. The EPA has temporarily banned BP because of dishonest business practices from bidding on US government contracts. Should the PSC not have serious reservations about BP's repeated distortions of fact and apparent lack of genuine engagement in the review process?

Sincerely,

Brooks Bragdon