Town of Cape Vincent to the PSC ~ BP’s "public involvement" efforts are inadequate and inconsistent

TOWN OF CAPE VINCENT

Jefferson County. New York 13618

April 4, 2013

Honorable Jeffrey C. Cohen

Acting Secretary, NYS Board of Electric Power Generation Siting and Environment

Three Empire State Plaza Albany, New York 12223-1350

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

Dear Secretary Cohen:

We seek again to impress upon the Siting Board and staff regarding the glaring inconsistencies and inadequacies in the "public involvement" efforts of BP in connection with their proposed project.

In our previous letter to you we advised that John Harris, BP's attorney, finally sent a letter(March 7. 2013) to the Towns of Cape Vincent and Lyme, in which he addressed some of the items raised at a January 22 meeting in Cape Vincent attended by Mr. Harris and Mr. Richard Chandler, BP's Project Manager. In our letter to you we itemized four significant problem areas in Mr. Harris' letter - problems with his responses or lack thereof.

An additional shortcoming in Mr. Harris' letter demands that we draw your separate attention to it.

On January 22, , when visiting Cape Vincent, Mr. Chandler stated that he was not going to involve Wolfe Island as a stakeholder because he didn't want to involve a community across an international boundary. Aside from that excuse being without good reason or even relevant, it also reveals that BP is indifferent to the fact that Wolfe Island is on record as requesting to be involved by BP.

Yet, in paragraph 6 of his letter Mr. Harris writes regarding setbacks from the Town of Lyme's border (also discussed at the January 22 meetings) that, "No separate setbacks

from Town borders is contemplated as this is a political boundary as opposed to an item that might dictate a health or safety setback."

BP can't have it both ways. Aside from a narrow shared river, the boundary that separates Cape Vincent from the Township of Frontenac Islands (Wolfe Island and others) is nothing more than a political boundary as well.

Early In the process it was specifically suggested to BP in writing by Siting Board staff that they should engage neighboring stakeholder communities in their pre-application public involvement program efforts. Siting Board staff specifically and properly identified Wolfe Island and Clayton as obvious stakeholder communities.

Both the statements of Mr. Chandler and Mr. Harris reflect BP's desire to artificially contain the size of the area impacted by their project as much as possible. That may serve their developmental interests but it does not serve the real interests of our immediate neighbors and the region. BP cannot pick its own stakeholders. They are here. Municipal stakeholders would surround their project, close by in every direction, and not least among them, Wolfe Island. BP cannot pretend otherwise. The dotted lines on a jurisdictional map don't change the real impacts of a major new industrial complex.

Obviously, BP's wind project would have area-wide consequences, both on and along the Cape Vincent/Lyme border and far beyond the Cape Vincent and Lyme town borders, including neighboring, and very nearby, Ontario.

Though the actual footprint of the BP project would be confined to Cape Vincent and Lyme, a half dozen other townships have a very real stake in the outcome of BP's proposal. The economic and environmental concerns of nearby towns, and of the Thousand Islands as an integrated region, should be given considerable weight.

Any large-scale development project in one part of the Thousand Islands Region will affect every part of the Thousand Islands Region. That is particularly true for a modern large-scale wind farm that is so visually imposing. The many qualities of our area that make it attractive and appealing to so many, and upon which the local economies of our region directly and indirectly depend We must trust that New York State Siting Board will be sufficiently circumspect to appreciate that the ramifications of large-scale wind development, particularly in our area, would not be confined to the boundaries of the municipality in which turbines are put up. We ask you to give these additional considerations your fullest attention.

Respectfully yours,

Urban Hirschey - Town Supervisor,

 Brooks Bragdon - Deputy Supervisor, 

John Byrne - Town Council,

J. Clifford Schneider - Town Council,

Michelle Oswald-Town Council