416 Bay
Street
Cape
Vincent NY
13618
April 18,
2013
Mr. Richard Chandler, Project Manager
BP - Cape Vincent Wind Farm
RE: Preliminary Scoping Statement
Mr. Chandler,
As project manager for the Cape Vincent
Wind Farm project, I am submitting these comments about the PSS to you and have
copied the PSC on this letter.
As a citizen of Cape Vincent who has
closely followed proposed industrial wind projects in our town since attending
an Open House for the St Lawrence Wind proposal in 2006, I have many concerns
about the Preliminary Scoping Statement submitted by BP. In this letter I will address a few issues
that are major ones for me because they represent what I believe is your lack
of understanding of the community.
Your
description (land use and demographic-economic attributes) of Jefferson County
and the town of Cape Vincent is very misleading and using this misinformation
as a basis for other assumptions in the proposal puts many sections of your PSS
in question.
Land Use/Demographic and Economic
Attributes: Reading Sections 1.3 and
1.3.11 you have provided your vision of the county and town that leaves out
very important information. A quick review of the Jefferson County website and
various NYS websites tells me that Jefferson county population ranks 25 of 62 counties
in NYS. That means more than half of the NYS counties have less population than
Jefferson County. Eight counties in NYS
host wind projects today and seven of those are located in counties with
smaller populations than Jefferson County. The eighth county, Erie, is ranked 8th
in the NYS county population list and hosts only 14 turbines on a former
industrial site. None of the current NYS
wind projects are located on the extensive amount of scenic shoreline of Lake
Ontario and the St Lawrence River. In
fact, I have been unable to find any
wind project in the USA that is located on a large body of
recreational/commercial river or lake. You also have failed to point out that
Jefferson County is host to a large army base at Fort Drum which provides a
significant source of financial base to our economy. Recently, Jefferson County
was listed as the “fastest” growing county in the state. Jefferson County borders the St Lawrence River
and the Thousand Islands which form the centerpiece of the region that the
official NYS Tourism office lists as the “1000 Islands Seaway” section of the
state. Jefferson County borders Canada
making it a major seasonal international point of entry. Your sentence summary is, “Jefferson County is
primarily rural and dominated by agricultural land, scattered rural homes and
farms” (p. 6) is truly misleading.
While the county clearly has rural characteristics,
I question why you use the term “primarily” when so many other factors
contribute to the society and economy of this county. Dairy farming is the
leading agricultural industry, but
you have excluded the fact that Fort Drum is the largest employer in this area
and a major contributor to many aspects of the economy. Tourism/seasonal residents also contribute
significantly to our economy. International visitors who use either the Cape
Vincent seasonal port of entry or the Alexandria Bay port of entry also
contribute to this county. The Jefferson County webpage states that 16% of all
employment in Jefferson County is related to retail trade compared to only 11%
of retail employment for the rest of the state. Tourism and Fort Drum are most
likely responsible for this significant sector of our county economy. Your
short description of land use in Jefferson County on page 6 and repeated on
page 24 of your PSS would lead any person unfamiliar with the county to believe
there is no commercial center, no tourism and basically not much else besides
farming going on in the county. This is simply not true. In Section 2.4 you state the application will
use “regional and local land use patterns and zoning” to assess the proposed
facilities and their compatibility with and impacts on land use and
zoning. This proposed project is in the
Towns of Cape Vincent (all the proposed turbines) and the Lyme (predominately
the transmission line). I believe that
the most important “land use patterns and zoning” to use as the best assessment
are those in the towns most impacted by this project.
How do you plan to complete this application
with any degree of credibility if you do not start with accurate descriptions
and definitions of the county at large and more specifically, the Town of Cape
Vincent where ALL of the proposed 124 turbines will be sited? When you start
with misconception, you will conclude with a complete misconception. As a
citizen of this town, I believe I should expect an accurate description of the
county and town. You provide correct information about dairy farming which is
significant to our county. However,
currently in the entire Town of Cape Vincent there are only about 10 working
farms and not all of them are dairy farms. The Town of Cape Vincent certainly
is not dominated by dairy farming. You have listed all the requirements of the
NY Coast Management Program, but your wording ignores the significant
contribution of tourism, especially in the Town of Cape Vincent. You discuss
access to recreational resources and simply conclude that as long as they can
be accessed there is little to no impact on these resources. You completely
disregard any issues of visual and noise impacts.
In Section 1.3.11 (Demographic and Economic
Attributes) you present correct information and leave out additional detailed information
that more clearly describes the total project area. The 2010 census data does report the Town of
Cape Vincent population as 2777. You did not note that the Village of Cape
Vincent adds 726 residents within the impact area of the project – for a total
of 3503. The Town of Lyme has 2185
residents, and the Village of Chaumont has 624 residents. You did not report
that the hamlet of Three Mile Bay in the Town of Lyme has 227 residents. The census reports a total of 6539 in the
Towns of Cape Vincent and Lyme, the Villages of Chaumont and Cape Vincent and
the hamlet of Three Mile Bay. By
omitting the populations of the Village of Cape Vincent and the hamlet of Three
Mile Bay, you fail to account for 953 residents in the project area – 14.5% of
the population. The census data for the
Town of Cape Vincent does report vacant housing units as 68 percent (1834
units) of the total 2712 housing units.
You neglected to state that 1732 (94.4%) of these units are listed in
the census report as “seasonal housing.” The census data for the Town of Lyme does
report 61% (1420 units) vacant units of the total 2317 housing units. Again, you neglect to state that 1367(96.3%)
of these vacant units are listed in the census report as “seasonal housing.” The Village of Cape Vincent has 506 housing
units with 31.2 % (158 units) listed as vacant and 114 (72.2%) of these vacant
units listed as “seasonal housing” in the census report. The Village of
Chaumont has 292 housing units with 12.7% (37) listed as vacant and 19 (51.4%)
of these vacant units listed as “seasonal housing” in the census report. The
hamlet of Three Mile Bay has 104 housing units with 11.5% (12 units) listed as
vacant and 9 (75%) of these vacant units listed as “seasonal housing” in the
census report. A review of the location
of these seasonal housing units verifies they are primarily located along the
shores of Lake Ontario and the St Lawrence River. Your statement “most of the vacant homes are
likely used for seasonal, recreational or occasional use” does not communicate
that seasonal housing is a very significant factor in the Towns of Cape Vincent
and Lyme and the Village of Cape Vincent. The Village of Chaumont and the
hamlet of Three Mile Bay do not show this trend. The Town of Cape Vincent population is doubled
(or higher) when the seasonal residents arrive. Our local grocery store (and
other businesses) would not be able to survive at all if this population was
significantly reduced. Certainly you cannot expect to ignore this vital segment
of our town economy and cannot dismiss it by simply stating that there will
still be access to the lake and river. Certainly given the land geography of
the town, most (if not all) of the proposed turbines at approximately 500’ will
be visible from all the seasonal homes. Do you know that the Wolfe Island
turbines are visible from parts of Watertown and Burrville which are 25-30
miles away? I find your pattern of presenting
“selective facts” very troublesome, but not surprising based on my experience
with wind developers over the last 6-7 years. This should be corrected in future documents
you present the PSC.
The census data on the Jefferson County
website also has a map of the 22 towns in Jefferson County showing the percentage
of seasonal housing in each town. Of the 22 county towns, Cape Vincent has the
highest percentage of seasonal housing units at 63.9%, followed by the Town of
Henderson (62.8%) the Town of Lyme at 59%.
This additional information clearly indicates that the Towns of Cape
Vincent and Lyme have a very high percentage of seasonal residents that make a very
significant contribution to the towns’ financial resources. In the Town of Cape Vincent approximately 75%
of the total town taxes collected are from the seasonal homes. The three towns with the highest percentage of
seasonal housing units are located where Lake Ontario ends and the St. Lawrence
River begins – the centerpiece of a very significant tourism area of NYS. I believe your failure to note this additional
information is an attempt to give the perception that the Towns of Cape Vincent
and Lyme have many vacant housing units that “are likely used for seasonal,
recreational or occasional use.” (p. 14) and therefore are insignificant to the
communities. In fact, this seasonal housing pattern in Jefferson County, which
varies from Cape Vincent having the highest percentage of seasonal housing
(63.9%) to the Town of LeRay (which hosts much of Fort Drum) with the lowest
percentage of seasonal housing (0.3%), demonstrates the vast difference among
the county towns. Jefferson County is much more complex than your simple
description of “primarily rural and dominated by agricultural land, scattered
rural homes and farms.” Because I understand
your agenda is to build this project at almost any cost I believe your lack of
sharing this easily attained and accurate information which more clearly defines
our complex demographics is intentionally misleading.
When asked to address issues of property
value impact, you have stated “The project will take the comment under
advisement.” Exactly what does that
mean? How will you even begin to address loss of property value near wind
turbines (up to 40% has been reported in the news) when you have barely
acknowledged this factor as a very real negative impact on our community?
When you explain your “Best Alternative
Statement” (p.47) you once again apply the land use and economic/demographic
misconception. You state, “The mouth of
the St Lawrence River offers some of the strongest and reliable wind in the
State of New York. This, in combination
with sparse population, and dominant agricultural and managed land use, make
the project in the Towns of Cape Vincent and Lyme suitable for development of a
large-scale wind power project.” US wind
maps do show wind in this area. However, note that the Wolfe Island Wind
Project (two miles away) is similar to your proposal and is currently operating
at about 20-25% efficiency with basically the same winds. The second sentence
is a myth you have tried to build for many years. Seasonal housing units have a major positive
economic impact in the Towns of Cape Vincent and Lyme. That is a fact you
completely overlook.
In this PSS document you repeat many
times that you have a “strong record of close community outreach and
engagement.” Please review the list of public comments on
the PSC website and explain why there are so many angry people. Your leaseholders represent about 3.9% of our
town population. You continue to ignore the other 96% and try to cleverly present
data that is incomplete and/or misleading to support your viewpoint.
You are misleading the public by using a
clearly outdated map. If there is some
reason this map is required by the state, a second one that is updated will be
needed for thorough citizen review. Any
citizen of the town (and neighboring towns) should be able to clearly see
turbine location on a current map and use a scale appropriate for the map to
determine the distance of any turbines from their home. An updated map with accurate turbine and
ancillary locations is essential to project evaluation.
Regarding blade length and the impact on
birds and bats in this area (the second busiest flyway in the USA according to
USA Today) I look at the overall impact. Once the 125 feet blades start
turning, the migrating and resident birds and bats will have little chance of
survival. That includes state and federally protected endangered species, which
includes our national symbol - the eagle. I have numerous times observed that
beautiful majestic bird flying along and over the St Lawrence River. What a beautiful sight! Take a careful look
at the fact that these birds and bats are already being slaughtered at an
alarming rate by the Wolfe Island Wind Farm – located (at closest point) less
than two miles from the shoreline of Cape Vincent. Since this wind project went into operation in
2009, the number of bird and bat kills has exceeded all predictions. This is
documented data. You have chosen to
ignore the proximity of this wind project because it is in Canada – but the
birds and bats do not read international boundaries as they fly through this
area.
Another way to look at this blade issue
is to imagine it as one blade. If you
assume that each turbine has 3 blades 125 feet each (total 375 feet) then 124 turbines would create a single blade
length of 46,500 feet – about 8.81 miles. Imagine you might have a tower that
could spin this 8.81 mile blade – the diameter of that circle would be 17.61
miles in length – or approximately the
distance from the Village of Cape Vincent to the Alexandria Bay Bridge. And this spins at over 100mph! How many birds
and bats could navigate safely through this?
I
am more than very concerned about the lack of any practical decommissioning plan.
I have been from the beginning and continue to be very concerned about
decommissioning plans that might leave our town with any number of non-functioning
wind turbines and without any financial support to remove them. Projected life
span of a wind turbine is about 15-20 years and I cannot support a plan that
leaves this town at risk of a financial disaster if there is not a clear plan
to remove these turbines when “there is no certainty that the Project’s power
will be marketable at the end of 20 years” (p. 183 of PSS). Our
town will never have the millions of dollars required to remove
inoperable wind turbines. Since BP has
recently put the wind sector of their business up for sale, who knows who will
own this project in the future. Also,
in NYS the oldest wind project was started in 2000 – so there is no real data
to predict life span of turbines with our winter weather impact on them. In addition, since the proposed turbines are
located on private land leased to you by the landowners, what guarantee is
there to the rest of the community that a leaseholder could just tell you to
leave the non-functioning turbine in place for all to see the blight on the
landscape forever? What would stop a
leaseholder from taking payment from BP to have a non-working turbine remain on
their land? That would be far cheaper for BP than decommissioning costs! A much simpler decommissioning plan would be
to calculate the cost of removing these 124 (or whatever number) turbines at
today are cost and place that money into an ironclad escrow account. You would recoup some of the costs by selling
the salvaged pieces at the time of decommissioning. This account would accrue interest and each
year additional funding would be added to the account to reflect any changes in
decommissioning costs. That way each
year the escrow balance will reflect the current decommissioning cost and the
responsibility of recouping some of the cost through sale of salvage pieces
would be your responsibility. It would not be the town’s responsibility.
In the past week, the Syracuse Post
Standard reported that Fort Drum is considered to be one of three potential
locations for an east coast missile defense site. In the recent past I spoke
with two communication technicians at the Cape Vincent Lighthouse who were
under contract from the former Griffiss Air Force Base and were studying the
effect the of Wolfe Island turbines on military satellite/radar/communication
systems. What contact have you had with Fort Drum officials regarding any radar
interference when you combine Wolfe Island turbines with proposed Cape Vincent
and Clayton turbines?
As a citizen who has taken the time to
read your PSS, I will expect that the concerns I have raised will be addressed
as you proceed with this Article X process.
Sincerely,
James Hill
Cc:
Honorable Jeffrey Cohen
Acting Secretary
NYS Public Service Commission
No comments:
Post a Comment