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.
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
No comments:
Post a Comment