ST. Lawrence Wind FEIS I

FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT

TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK
1.0 INTRODUCTION
This Final Environmental Impact Statement (FEIS) has been prepared on behalf of the Applicant,
St. Lawrence Windpower, LLC (SLW), for the proposed Saint Lawrence Windpower Project
(the Project). The document is intended to continue the environmental review process in
accordance with the New York State Environmental Quality Review Act (SEQRA) and provide
a means for inclusive public review and informed decision-making. The Project, as originally
proposed, was described in the Draft Environmental Impact Statement (DEIS) and, as revised, in
a Supplemental Draft Environmental Impact Statement (SDEIS). The DEIS was accepted by the
Town of Cape Vincent on January 10, 2007 and the SDEIS on March 25, 2009. The FEIS
incorporates information provided in both the SDEIS and DEIS and addresses Project changes
and analysis that occurred after the SDEIS was released for public review and comment on April
4, 2009. New information presented in this document regarding the Project layout,
environmental setting, and associated impacts supersedes that presented in the SDEIS and is not
intended to duplicate information that remains accurate and unchanged from the SDEIS and
DEIS. This document also includes responses to substantive public and agency comments and
questions received throughout the SEQRA process. The FEIS, SDEIS and DEIS collectively
provide a comprehensive analysis of the environmental impacts anticipated to result from the
proposed Saint Lawrence Windpower Project. All references to sections, appendices and figures
within this document pertain to this FEIS unless otherwise noted.
1.1 State Environmental Quality Review Process

SLW submitted a Full Environmental Assessment Form (EAF) to the Town of Cape Vincent
Planning Board, the Lead Agency, on November 8, 2006, which initiated the SEQRA process for
the proposed action. The DEIS was submitted to the Town of Cape Vincent Planning Board on
January 10, 2007, which was accepted as complete by the Lead Agency on January 24, 2007.
The Lead Agency filed a Notice of Acceptance of the DEIS and Notice of Public Hearing on
February 7, 2007. Copies of the DEIS were distributed to all interested and involved agencies
and made available to the public at the Town of Cape Vincent Town Clerk’s Office, the Public
Library, and SLW’s local office in Cape Vincent, NY. SLW also posted the entire DEIS on the
Project’s website (www.stlawrencewind.com). On March 24, 2007, the Town of Cape Vincent
Planning Board held a public hearing on the DEIS at the Cape Vincent Recreation Center on
South James Street. The public comment period ended on June 15, 2007.
After the public comment period on the DEIS, the Town of Cape Vincent Planning Board
requested preparation of a SDEIS. The SDEIS was submitted to the Lead Agency on January 14,
2009 and accepted on March 25, 2009. The Lead Agency filed a Notice of Acceptance of the
SDEIS and Notice of Public Hearing on April 4, 2009. A public hearing on the SDEIS were held
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on May 16, 2009 at Recreation Park, Cape Vincent. The public comment period on the SDEIS
ended on May 30, 2009.
This FEIS has been prepared to comply with the requirements of SEQRA (6 NYCRR 617). The
purpose of the FEIS is to incorporate information pertaining to the proposed Project’s design and
likely impacts that was made available subsequent to the issuance of the SDEIS. This additional
information is provided in Section 2.0 below. Section 3.0 of this FEIS contains a summarized
list of all comments received. Comments in their entirety are provided in Appendices D (public
meeting transcripts) and E (written comments). A Response Summary was also prepared as part
of this FEIS to address all substantive oral and written comments received on the SDEIS and
DEIS and is provided in Section 4.0. It contains responses to the comments and questions posed
at public hearings and/or received in writing during all public comment periods for the Project.
Additional studies and plans have been prepared in support of the Project. They provide detailed
information on specific issues associated with the Project and were prepared to assist in the
SEQRA evaluation. They include the following:
x Supplemental Wetland Delineation Report, St. Lawrence Windpower, LLC, St. Lawrence
Wind Farm, Towns of Cape Vincent & Lyme, Jefferson County, New York
x 2009 Pre-Construction Grassland and Sensitive Bird Species Study
x Biological Assessment
x Final Shadow Flicker Analysis
x Final Noise Modeling Assessment
x Final Off-Air TV Station Assessment
x Transportation Route Evaluation Study
x Transmission Line Engineering Study Scope
x Draft Wildlife Protection Plan (WPP)
x Residential Well Study and Mitigation Plan
x Storm Water Pollution Prevention Plan (SWPPP)
x Spill Prevention, Control, and Countermeasure (SPCC) Plan
x Unanticipated Discoveries Plan
x FAA Final Lighting Plan
x Revised Complaint Resolution Plan
x Draft Outline of Construction Environmental Monitoring Plan
The final steps in the SEQRA process for the Saint Lawrence Windpower Project will include
the following:
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x FEIS acceptance by the Cape Vincent Planning Board

x Final notice of completion of FEIS
x Distribution of FEIS and a copy of the public notice to involved and interested parties
x Ten-day public consideration period
x Cape Vincent Planning Board issues Findings Statement, completing the SEQRA process
x Involved agencies issue Findings Statements
1.2 List of Required Permits and Approvals

Development of the proposed Project will require the following permits and/or approvals from
local, state, and federal agencies:
Table 1-1 (Sheet 1 of 2)

Permits and Approvals for the St. Lawrence Wind Energy Project
Agency Description of Permit or Approval Required
Towns
Administration of SEQRA Process, and issuance of findings (as Lead
Town of Cape Vincent Agency under SEQRA).
Planning Board Site Plan Approval for construction of wind energy project and transmission
line to Town boundary
Issuance of building permits/certificates of compliance.
Town of Cape Vincent Departments
Review and approval of highway work permits/road agreements.
Town of Lyme
Participation in SEQRA Process as an involved agency
Planning Board
Town of Lyme Special Use Permit (Zoning Board of Appeals) and other land use
Zoning Board of Appeals considerations for construction of transmission line to substation
Town of Lyme Issuance of building permits.
Departments Review and approval of highway work permits/road agreements.
Jefferson County
Completion of a NYS General Municipal Law Section 239-m review and
Planning Department
issuance of recommendations.
Highway Department County road work permits.
New York State
Consultation regarding special status species.
Article 11 (Fish & Wildlife Law) Permit (6NYCRR Part 182).
Article 17 SPDES General Permit (6NYCRR Part 750) for stormwater
discharges including creation of a Stormwater Pollution Prevention Plan
Department of Environmental
(SWPPP) and a SPCC/Oil Contingency Plan.
Conservation
Article 24 Freshwater Wetland Permit (6NYCRR Part 663).
Clean Water Act Section 401 Water Quality Certification (6NYCRR Part
608).
Issuance of SEQRA Findings as an involved agency.
Department of State
Coastal Zone Management Act Consistency Determination
Division of Coastal Resources
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Table 1-1 (Sheet 2 of 2)

Permits and Approvals for the St. Lawrence Wind Energy Project
Agency Description of Permit or Approval Required
Federal Agencies
Department of Transportation Special Use Permit for oversize/overweight vehicles. Highway work permits.
Participation in SEQRA Process as an interested agency.
Department of Agriculture & Agricultural District Law Article 25AA, Section 305-a
Markets Coordination of local planning and land use decision-making with the
agricultural districts program
Public Service Commission Participation in SEQRA Process as an interested agency.
NYSOPRHP (SHPO) Cultural Resources Consultation.
FAA Notice of Construction and Aviation Lighting Plan.

USACE Nationwide Section 10 Permit for aerial crossing of the Chaumont
River.
U.S. Army Corps of Engineers
USACE Section 404 Nationwide Permit for placement of fill in federal
jurisdictional wetlands/waters of the United States.
U.S. Fish and Wildlife Service Consultation regarding special status species.
Occupational Safety and Health 29 CFR 1910 regulations (standard conditions for safe work practices during
Administration (OSHA) construction).
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2.0 PROJECT MODIFICATIONS AND SUPPLEMENTAL INFORMATION

This section describes modifications that were made to the Project since the SDEIS was filed in
March 2009 and provides supplemental information regarding existing conditions, potential
environmental impacts, and mitigation measures that have become available since the March
2009 filing.
2.1 Revised Project Layout/Details

The revised Project layout, shown in Figures 1 and 2, includes 51 turbines, approximately 16.5
miles of temporary access roads, 14.7 miles of permanent access roads, 36 miles of buried cable
and an Operations and Maintenance Exhibit 2.1.1 – Example of Acciona-built O&M
(O&M) Building. An example of a Building at EcoGrove Wind Farm, IL
potential design for the O&M building is
illustrated in Exhibit 2.1.1. A maximum
of five meteorological towers will also be
installed during the construction and
operations phases of the Project to
monitor wind resources. They will be
supported by three to four guy wires and
rest on concrete footings. SLW will add
bird deflectors to the supporting guy
wires to increase visibility to avian
species. Placement of these deflectors is
shown in blue in Exhibit 2.1.2.
The proposed Project includes relatively minor modifications to the layout presented/described
in the SDEIS. These modifications include elimination of two wind turbine generators (WTGs),
selection of the alternate location for one WTG, revised locations for most WTGs, and relocation
of associated roads and underground interconnects. In addition, the rotor diameter for WTG 28
was reduced to 77 meters to accommodate turbulence interference. Most proposed locations for
WTGs in the revised Project layout were only shifted about 100 feet from the locations
previously provided in the SDEIS. Although substitution of one WTG for the alternate WTG
location resulted in a 2.9 mile change from its original location.
Specific changes were made to minimize impacts associated with noise, agriculture, wetlands,
New York State Department of Environmental Conservation (NYSDEC) Wetland Adjacent
Areas, or sensitive species including:
x Elimination of WTG 11 to reduce noise impacts below reasonable thresholds;
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x Elimination of WTG 38 in response to a

Exhibit 2.1.2 – Met Tower Bird Deflector
Placement NYSDEC request to move turbines
outside of a state endangered species
habitat area.
x Relocation of WTG 3, 14, 16, 17, 24,
25, 37, 39, 40 and 41 to address wind
turbulence.
x Rerouting of cables connecting WTG 23
to 26 to avoid wetlands.
x Rerouting of cables connecting Turbines
26 and 28 to reduce wetland impacts.
x Modification of cable routes and access
roads associated with WTGs 14, 24, 25,
32, 39, 40, 41, 47, and 53 to
accommodate turbine relocations or
eliminations.
x Relocation of access roads to WTGs 32,
48, 50, 51, and 52 to reduce wetland and
agriculture impacts.
x Relocation of work pad for WTG 28 to
reduce wetland adjacent area impacts.
The revised Project layout complies with, or exceeds, the following Planning Board of Cape
Vincent’s setback criteria stipulated in their June 11, 2007 letter to SLW (See Figure 3):
x 1,500 feet from the Village of Cape Vincent boundary line;
x 1,000 feet to a non-participating property line;
x 1,250 feet to a non-participating residence; and
x 750 feet to a participating residence.
2.2 Environmental Setting, Impact Analysis and Mitigation Measures

2.2.1 Water Resources
2.2.1.1 Supplemental Existing Conditions Information
Groundwater
SLW conducted a pre-construction survey of residential wells. This survey involved
determining the location of groundwater wells within 500 feet of the proposed wind turbine
locations. A total of 22 wells have been documented within the study radii. SLW will conduct
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habitat area.
turbulence.
32, 39, 40, 41, 47, and 53 to
eliminations.

Groundwater
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additional pre- and post-construction studies of identified wells to determine individual well
characteristics. Results of the initial well survey and a description of the more detailed pre- and
post-construction well studies are presented in Appendix C-6.
Surface Waters and Wetlands

The presence or absence of surface waters and wetlands were evaluated for all re-located facility
components (Appendix C-1). These re-located components primarily occur in previously
established study areas. If a turbine or an ancillary facility was located outside of the previous
study area, the new footprint of disturbance was assessed for the presence or absence of surface
waters and wetlands during the field surveys conducted during the summer of 2009. At all
revised component locations, St. Lawrence Windpower LLC conducted avoidance and
minimization assessments for both temporary and permanent surface water and wetland impacts.
Delineated surface waters and wetlands associated with the revised project layout are presented
in Figure 4.
2.2.1.2 Revised Impact Analysis

Groundwater
Construction activities can generate ground-transmitted vibration forces that may result in
ground disturbance and potentially affect existing groundwater features proximal to the activity.
These generated vibrations attenuate over distance from the source. The magnitude of the
vibration and the attenuation rate are related to the construction method used for excavation (e.g.,
mechanical, blasting), type of construction equipment (e.g., hydraulic excavators, front end
loaders), and conductivity of the surface and subsurface substrates (e.g., sands, clays, frozen
soils, bedrock). In determining the distance from turbines for pre-construction surveys of private
water supply wells, it was assumed that standard excavation equipment would be used and no
blasting would be required. Using such equipment and techniques vibration effects typically are
below levels of perception at distances of 500 feet from the source (Amick and Gendreau, 2000).
Even considering the use of controlled blasting, construction vibrations would be well below the
threshold for residential damage at a distance of 500 feet from the blasting activity. However,
since site-specific geologic and hydrogeologic investigation has not been performed in the
Project Area, the radius to be used for the pre- and post-construction well survey will be
established based upon the results of the site-specific surveys and the final choice of construction
method for each foundation. The radius to be used for those surveys may be adjusted either
nearer or further from the source.
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Based on modifications to the Project layout there is a slight decrease in overall temporary and
permanent wetland impacts as compared to the layout evaluated in the SDEIS. Permanent
filled/excavated wetlands amount to 13,816.3 square feet (0.32 acre) while temporary
filled/excavated wetlands amount 49,637.7 square feet (1.14 acres). This represents a total
reduction of 23,666 square feet (0.54 acre) of fill/excavation impacts to wetlands, 558.5 square
feet (0.01 acre) of which are permanent impacts and 23.107.5 square feet (0.53 acre) of which
are temporary impacts, since the submission of the SDEIS.
2.2.1.3 Supplemental Mitigation Measures

Groundwater
In the unlikely event that a residential water well is compromised within the Project area, SLW
has developed a mitigation plan (See Appendix C-6). The main elements of this plan include:
x Notification of SLW of a potentially compromised well.
x Supply of alternate potable water source through the Cape Vincent Fire Department, on-
site water storage tank, or connection to municipal water.
x For documented Project related well damage, reimbursement of property owner’s
expenses and either provision of a new well at no installation expense to the property
owner or connection to municipal water. SLW will pay all costs related to municipal
water expenses henceforth.
x SLW will develop a Project Blasting Plan prior to construction. This plan will include
the use of controlled blasting to assure that construction vibrations would be maintained
below the threshold for well and residential damage. This plan will also include
conventional seismic monitoring at wells or homes within the identified potential impact
zone to mitigate potential seismic impacts associated with blasting.

No additional mitigation will be required as a result of the changes to the project since issuance
of the SDEIS; however, the U.S. Army Corps of Engineers (USACE) has selected one of the
proposed sites as adequate for compensatory wetland mitigation. Site E was identified as the
best location to ensure success and is shown in Exhibit 2.2.1. It would provide an expansion of a
wetland associated the Kent’s Creek. The vegetation plantings proposed for the compensatory
wetland would also provide shade cover to stream and improve the water quality. The riparian
zone improvement would also improve the wildlife corridor associated with Kent’s Creek. The
soils mapped in the area are Rhinebeck Silt loam, a non-hydric soil. The source for the
appropriate hydrological conditions would be from the combination of: surface runoff and the
surrounding landscape; stormwater runoff/diversions to the mitigation site; and, the high flow
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and overflowing of Kent’s Creek. The

Exhibit 2.2.1 – Wetland Mitigation Location
mitigation site is situated adjacent to the
floodplain of Kent’s Creek. Use of this site
would result in fewer soil impacts compared to
use of other potential mitigation sites since
mitigation could be accomplished by re-grading
existing topography instead of removal of
significant amounts of soil. Confirmed
hydrology adjacent to this location also
increases the probability of successfully
converting this site to wetlands. Temporary
construction impacts at this location would also
be minimized since the site is readily accessible
from existing local roads. The field surrounding
the mitigation site consists of various crop
grasses including reed canary grass (an
invasive). The construction of the mitigation
site would impact the amount of cropland managed by the landowner; however it is located
along the length of an existing field. The property owner has indicated an interest in being a
participant in the Project in this fashion. Please see Appendix C-1 for details of the
compensatory wetland mitigation plan.
2.2.2 Ecological Resources

Vegetation
Based on existing land use/land cover data (NAIP 2001), most of the revised Project Area
consists of grassland and agriculture habitats. The Project Area also includes scattered forest and
second growth scrub/shrub habitat (Table 2-1). As compared to the layout proposed in the
SDEIS, the current layout will affect fewer and smaller forested areas and will result in larger
blocks of forested area remaining intact. Table 2-1 presents impacts to vegetative cover resulting
from the Project.
Threatened and Endangered Species

Indiana Bat – SLW has completed a Biological Assessment (BA) for the Indiana Bat in support
of its USACE application for a Nationwide Permit No. 12. A BA is an impact assessment
designed to address impacts to species designated under the Endangered Species Act and critical
habitat for such species. The federal action being evaluated under the BA is the USACE granting
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Vegetation
from the Project.

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Table 2-1
1
Approximate Area of Vegetation Disturbance
Sub-Station/ Collector Construction

Access Roads Turbine Met Towers
Habitat/Land Use O&M Lines Areas Total
(Acres) (Acres) (Acres)
Permanent Impacts
Developed, Open Space 0.06 0 0 - 0 - 0.06
Developed, Low Intensity 0.41 0 0.26 - 0 - 0.67
Deciduous Forest 0.7 0.02 0 - 0 - 0.72
Scrub-Shrub 0.63 0 0 - 0 - 0.63
Grassland 0.93 0.02 0 - 0 - 0.95
Pasture/Hay 17.43 0.51 10.98 - 0 - 28.92
Crops 9.74 0.27 0.28 - 0 - 10.29
2
Forested Wetlands 0.19 0 0 - 0 - 0.19
Total 30.17 0.82 11.52 0 0 0 42.51
Temporary Impacts
Developed, Open Space 0.17 0 - 0.37 - 0.18 0.72
Developed, Low Intensity 1.02 0 - 0.79 - 0.13 1.94
Deciduous Forest 1.61 1.89 - 1.37 - 0.04 4.91
Scrub-Shrub 1.38 1.11 - 0.62 - 0.26 3.37
Grassland 2.18 2.3 - 1.22 - 0 5.7
Pasture/Hay 40.17 51.9 - 29.55 - 5.25 126.87
Crops 22.55 24.65 - 15.91 - 8.28 71.39
2
Forested Wetlands 0.42 0.68 - 0.05 - 0 1.15
Total 69.5 82.53 - 49.88 - 14.14 216.05
1
Data were obtained from the US Geological Survey National Land Cover Data (NLCD). This data set provides standardized land
use and land cover data acquired by remote sensing techniques (Landsat Thematic Mapper Satellite) including the use of
conventional aerial photography. These data represent a generalized land cover classification.
2
Wetlands were field delineated and results provide a more accurate determination of impacts for these covers types which include a
total of 0.31 acre of permanent impacts and 1.14 acres of temporary impacts to forested, scrub-shrub and emergent wetlands.
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Nationwide Permit authorization for facilities of the proposed Project to cross waters of the U.S.
The BA is provided in Appendix C-3.
Grassland Birds – An additional summer breeding bird survey was conducted during 2009 in
the proposed Project Area to determine the presence, absence, and site use by rare, threatened or
endangered (RTE) bird species. Target RTE species were either state-listed threatened species or
state species of Special Concern in New York associated with grassland habitats. Survey
locations were selected to maximize the detection of target RTE species through selection of
sampling points within the best available habitat present within and adjacent to the Project Area.
The study provided data for describing the temporal and spatial use by sensitive bird species
primarily affiliated with grassland communities in the Project Area. The survey protocol was
based on the NYSDEC Region 6 Grassland Bird Survey Protocol and survey points were
established in consultation with NYSDEC Region 6 biologists. A copy of the report for this
survey is provided in Appendix C-2.
Henslow’s sparrow was detected during the surveys, including four individuals in three groups
during the point count surveys and one individual during time spent on site by the observer.
Vesper sparrow and upland sandpiper were also observed infrequently during both point counts
and incidentally. Sedge wren was not observed. These results, coupled with those from
previous pre-construction survey efforts (Kerns et al 2007), suggest these species are rare within
the Project area. However, northern harrier and grasshopper sparrow were observed with
relative frequency.

Vegetation
The revised Project layout will result in impacts to 162.44 acres of grassland/pasture/hay (29.87
acres permanently, 132.57 temporarily), 81.68 acres of agricultural row crop cover (10.29 acres
permanently, 71.39 temporarily), 5.63 acres of upland forested cover (0.72 acres permanently,
4.91 acres temporarily), and 4.0 acres of upland scrub-shrub cover (0.63 acres permanently, 3.37
temporarily. In addition, the US Geological Survey National Land Cover Data indicate impacts
to 1.34 acres of forested wetland (0.19 acres permanently, 1.15 acre temporarily), while results
of field delineation of wetlands indicated that 1.46 acres of forested, scrub-shrub, and emergent
wetlands will be affected (0.32 acres permanently, 1.14 acre temporarily). These impacts are
summarized in Table 2-1
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Indiana Bat – The SLW Project will result in the loss of some Indiana bat habitat
(approximately 2.5 acres) but this loss is not expected to lead to harassment or harm of Indiana
bats to an extent that would meet the definition of “take” of the Indiana bat. In addition, Indiana
bat habitat impacts will be minimized and avoided by cutting trees when Indiana bats would not
be present on site. Loss of habitat impacts from the SLW Project will not lead to take of
individual Indiana bats and this potential impact is not likely to adversely affect Indiana bats.
Operation of the project could potentially lead to direct mortality of Indiana bats if they were to
collide with a turbine blade or die from barotrauma. Using the best available information and a
suite of assumptions, SLW estimates that the Project could lead to the death of between 0 and 3
Indiana bats per year. If the threshold of zero is passed, this impact will meet the definition of
“take.” SLW will conduct a rigorous monitoring program to determine mortality and assess its
causes; implement a number of conservation and mitigation measures to offset or compensate for
any take; and adaptively manage the biological outcome to ensure a “net-benefit” impact on the
Indiana bat. Consequently, the Project is not likely to jeopardize the continued existence of the
Indiana bat. The estimated impacts to Indiana bats, proposed mitigation and avoidance
measures, and an assessment of the impacts of the Project on the species are set forth in the BA.
See Appendix C-3.
Grassland Birds – Construction and operation of the Project could potentially affect grassland
species including short eared owl, northern harrier, upland sandpiper and Henslow’s sparrow.
The revised Project layout incorporates a number of NYSDEC recommended changes to avoid
and minimize some of the impacts on these species (specifically Short-eared owl); however, the
measures to avoid and minimize impact are not anticipated to prevent all take of state-listed
endangered/threatened species. Construction of the Project will result in the direct take of 29.87
acres grassland that is permanently converted to roads and turbine pads. In addition, temporary
disturbance to 132.57 acres will result in “disturbance-related" impacts such as fragmentation
and displacement. To address the potential incidental take of these species, SLW has applied for
an incidental take permit under Article 11 of the N.Y. Environmental Conservation Law.

Vegetation
Vegetation impacts will be mitigated through preservation of forested habitat and grassland
habitat as described in the following section for Threatened and Endangered Species.
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Indiana Bat – Conservation measures have been proposed to address the impacts to Indiana
bats. These measures include the following:
x The Project was redesigned to minimize impacts to potential Indiana bat habitat including
deciduous forest and wetlands to the maximum extent possible. The current design would
result in approximately 2.5 acres of deciduous forest impact. No turbines will be located
in forested habitat. Impacts to forests will arise only from access roads and the
transmission line. No known roost trees will be cut for the Project. In addition, impacts
to wetlands will be minor, arising only from crossing of waters with roads and collector
lines. The SLW Project design also will minimize risk to Indiana bat roosting areas
because all turbines will be located approximately ½ mile or more from identified roost
trees.
x SLW proposes to include a conservation easement to protect known Indiana bat habitat as
part of the Project. A block of forest in the Project area will be maintained for the life of
the SLW project through a conservation easement with the land owner to insure that there
are no future impacts to the forest habitat. The conservation easement would include
roughly 56 acres. The conservation easement would insure that the site is excluded from
further development pressure or tree cutting for the life of the wind project.
x To avoid potential take of roosting Indiana bats, all tree clearing will occur between
October 1 and April 15 when Indiana bats are not expected to be within their
spring/summer range or on site.
x To minimize potential harm or harassment impacts, night time construction will be
minimized and lighting will be restricted to safety lighting required around hazardous
equipment or materials as required by law.
x Development of an adaptive management plan to avoid take of Indiana bats. The primary
objectives to meet this goal are to: 1) determine the level of Indiana bat mortality and
identify the circumstances and conditions under which fatalities of Indiana bats occur;
and 2) develop a set of project management actions (alternatives) that when implemented
provide effective means by which the impacts can be reduced, offset, or eliminated, thus
avoiding/minimizing potential impacts.
x SLW will also engage in monitoring as part of the adaptive management program and as
required by the federal and state agencies. Pursuant to the adaptive management program
SLW will engage in a minimum 3-year monitoring program to determine the level of
impact and circumstances under which impacts to Indiana bats occur from the SLW
project. As part of compliance monitoring, SLW will monitor for a designated period
required as a condition of the USACE permit.
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x As part of the overall monitoring study, SLW will implement research projects designed
to provide information related to risk of the wind project to Indiana bats in the Cape
Vincent region. These projects will include banding and radio-tracking study of late
summer/early-fall Indiana bats to determine dispersal patterns and behavior in relation to
known winter hibernacula and to determine if there are any additional hibernacula in the
region, and a banding study of little brown bats to determine impacts to summer resident
bats.
x Acciona Energy, the parent company of SLW, has provided funds to the Emergency
White Nose Syndrome Fund. In addition, SLW will provide continued funding to on-
going research on white nose syndrome geared toward determining causes and corrective
actions to offset the high levels of mortality, with the overall objective of species
conservation.
x Acciona Energy is also a contributing member to the Bat-Wind Energy Cooperative
(BWEC) to fund studies on monitoring impacts from wind turbines and investigate
mitigation strategies such as adjusting turbine cut-in speed and bat deterrent methods.
Acciona will continue to contribute to BWEC on an annual basis for five years, unless the
cooperative is disbanded prior to five years.
Grassland Birds – To address potential impacts to grassland birds, SLW has committed to
compensating for potential Project related direct habitat take associated with the disturbance of
grassland acreage that is permanently converted to roads and turbine pads and additional acreage
impact associated with “disturbance related" factors such as fragmentation and displacement. To
accomplish this SLW proposes to set aside approximately 166 acres of land as a conservation
easement (See Exhibit 2.2.2). This land will be managed to replace habitat affected by direct
and or indirect impacts. Land will be to be dedicated as grassland bird habitat. Key components
of this mitigation include:
x NYSDEC approval of locations and acreage; a plan to enhance grassland quality and or
restore grassland lost to succession; and a plan to perpetuate the restored lands as
grassland.
x SLW funding of a Landowner Incentive Program-like mitigation through a third party
(such as Ducks Unlimited) that would handle the fund and administer the program, while
requiring DEC participation and sign off on the selection of projects.
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Exhibit 2.2.2 – Proposed Grassland Bird Conservation Easement
2.2.3 Noise
SLW has conducted a Final Noise Modeling Assessment of the revised Project layout. This
assessment is provided in Appendix C-4. The primary basis for evaluating noise impacts is the
Program Policy “Assessing and Mitigating Noise Impacts” published by the New York State
Department of Environmental Conservation (NYSDEC, 2001). The NYSDEC guideline
document states that “increases ranging from 0-3 dB should have no appreciable effect on
receptors. Increases from 3-6 dB may have potential for adverse noise impact only in cases
where the most sensitive receptors are present. Sound pressure increases of more than 6 dB may
require closer analysis of impact potential depending on existing SPLs (sound pressure levels)
and the character of surrounding land use and receptors.” What this essentially says is that an
incremental increase of 6 dBA or less over the ambient sound level is unlikely to constitute an
adverse community impact. Ambient levels were derived as described in Section 3.10.1 of the
SDEIS.

Construction and Operational Impacts
Construction related impacts remained unchanged from those discussed in the SDEIS. SLW
conducted a Final Noise Modeling Assessment for the revised Project
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layout consisting of 50 1.5 MW Acciona AW-82/1500 wind turbines and 1 1.5 MW AW-
77/1500 wind turbine to assess operational impacts. Sound power data was obtained from the
WTG manufacturer and the critical operational design level was determined for use in the
acoustic noise modeling analysis. The critical operational design level is the worst case in terms
of potential noise impact and perceptibility as it occurs when the differential between the
background level and turbine sound power level is greatest. At higher wind speeds turbine sound
power levels increase, while the masking background sound level also increases significantly.
Table 2-2 shows the comparison of the conservative wintertime L90 background to the wind
turbine sound power levels (SPL) over a range of wind speeds to determine the critical
operational design level. The IEC 61400-11 standard only requires the measurement of SPLs
between 6m/s and 10m/s.
Table 2-2
Comparison of Conservative Wintertime L90 Background and Turbine Sound Levels
Wind Speed
6 m/s 7 m/s 8 m/s 9 m/s 10 m/s
Acciona AW-82/1500 Sound Power Level at 101.7 102.5 102.2 101.8 101.5
Reference Wind Speed
Wintertime L90 Background Sound Level (dBA) 37 39 42 44 47
Differential (dBA) 65 63 60 58 54
The worst case acoustic condition for the proposed Project occurs at a wind speed of 6 m/s, with
the highest differential occurring between the background sound level of 37 dBA and turbine
sound power level (LW) of 101.7 re 1 pW at this wind speed. Table 2-3 shows the estimated
frequency content of the turbine sound power level at 6 m/s.
Table 2-3
Acciona AW 82/1500 Sound Power Level Spectrum at 6 m/s
Octave Band Center

31.5 63 125 250 500 1k 2k 4k 8k dBA
Frequency (Hz)
Estimated Lw
107 104.3 103.8 102.8 100.4 96.8 90.2 82.8 72.7 101.7
(dB re 1 pW)
The Acciona AW-82/1500 WTG sound power level spectrum at the critical design wind speed of
6 m/s speed as well as other wind speeds were inputted into CadnaA (ver. 3.6.115), DataKustik’s
acoustic modeling program. CadnaA conforms to ISO 9613-2 Acoustics – Attenuation of sound
during propagation outdoors and enables the Project and its surroundings, including terrain
features, to be realistically modeled in three-dimensions. Modeling of the current Project layout
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as of March 2010 assumed the nominally maximum downwind sound level from each turbine in
all directions simultaneously. In other words, although physically impossible, omnidirectional
sound propagation was assumed for all modeled wind speeds. In addition, a conservative ground
absorption coefficient of 0.5 was selected for the acoustic modeling analysis to represent the
rural farming land in the Project area. The ISO standard accounts for ground absorption rates by
assigning a numerical coefficient of 0 for acoustically hard, reflective surfaces and a coefficient
of 1 for absorptive surfaces. If the ground is hard-packed dirt, typically found in industrial
complexes, pavement, or for sound traveling over bodies of water, the absorption coefficient is
defined as G=0. In contrast, ground covered in snow, vegetation, including suburban lawns,
livestock and agricultural fields (both fallow with bare soil and planted with crops), will be
acoustically absorptive and aid in sound attenuation, i.e., G=1.0. It has been found that a middle
value of 0.5 is appropriate for rural farming country in the sense that predicted sound levels
agree very well with measurements of turbine-only sound levels over a variety of wind
conditions.
Modeling results at the critical 6 m/s design wind speed were compared to the NYSDEC
cumulative incremental increase guideline of 6 dBA, which conservatively equates to a Project-
only sound level of 42 dBA, as a basis for Project compliance. This is because a Project-only
level of 42 dBA combined with the wintertime L90 background level of 37 dBA would result in a
total cumulative sound level of 43 dBA, an increase of 6 dBA relative to background. Modeling
results evaluating compliance with the State guideline are shown in Exhibit 2.2.3 and in the form
of a sound contour map. The area inside the 42 dBA sound contour line (in purple) represents the
region where sound from the Project may equal or exceed the NYSDEC’s 6 dBA screening
criterion. These figures indicate that all residences, whether participating or not, lie outside of
the 42 dBA sound contour line and will be short of the 6 dBA NYSDEC threshold.
Acoustic modeling was also completed at a wind speed of 7 m/s, which corresponds to the wind
turbine maximum sound power level output. Modeling results for this wind speed were also
compared to the NYSDEC 6 dBA incremental increase guideline, which equates to a Project-
only sound level of 44 dBA. Exhibit 2.2.4 displays these results and show that no residences
(participating or non-participating) will result in exceedances of the NYSDEC criterion at these
wind speed conditions. The reason for the decrease in potential impacts at wind speeds higher
than 6 m/s is that while the wind turbine sound power level may change slightly as wind speed
increases, the background sound level also increases, resulting in acoustic masking effects. This
trend would continue as wind speeds continue to increase; therefore, at wind speeds higher than
7 m/s the Project would also remain below the NYSDEC impact threshold.
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Exhibit 2.2.3 – Noise Modeling Results – Predicted Mean Sound Contours 42 dBA Threshold
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Exhibit 2.2.4 – Noise Modeling Results – Predicted Sound Contours 44 dBA Threshold
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Results of the acoustic modeling analysis indicate that the Project would be in full compliance
with the NYSDEC 6 dBA incremental increase guideline at all non-participating residences
under the 6 m/s critical design wind speed and well short of this threshold at all higher wind
speeds. However, wind and weather conditions (i.e., temperature inversions and low level
jetstreams) may develop from time to time causing Project sound levels to increase, sometimes
substantially, over the nominally predicted level. Field experience indicates that these
unavoidable and inevitable excursions are infrequent and short-lived; for the vast majority of the
time sound levels will be close to the mean predicted value. It should also be noted that Project
audibility does not cease at the 6 dBA threshold but extends further out for some distance
depending on wind, weather and atmospheric conditions. Beyond the threshold, however, the
typical prominence of Project sound emissions above background is significantly lower and
much less likely to be regarded as objectionable.
A modeling analysis of the potential for cumulative sound level impacts from the proposed BP
Cape Vincent Wind Farm Project to the southeast of the Project indicates that, if both the BP
project and the SLW Project are constructed, some residences are likely to experience slightly
higher sound levels than if only the St. Lawrence Project were in operation (See Exhibit 2.2.5).
Increases of 1 or 2 dBA might occur at several homes if the BP project were also operational. It
should be noted that a change of at least 3 dBA is normally required before any real difference in
sound level begins to be perceptible. Therefore, cumulative sound level increases in the Project
area would be fairly minor and would not represent a substantial or particularly tangible change
in the potential impact from the Project when combined with the proposed BP project.
Sound Related Health Impacts

Issues related to health concerns associated with sound from utility-scale wind turbines have
been raised in public comments on the SLW Project. Potential health concerns associated with
sound from wind turbines are most often linked to infrasound and low frequency sound. A
discussion of Project low frequency sound levels was presented in the SDEIS and is also
provided in Appendix C-4.
Low frequency sound is in the frequency range of 20 to 200 Hertz (Hz); infrasound remains
below 20 Hz, which is below the audible threshold. Infrasound is prevalent in the natural
environment (e.g., ocean waves and wind). Infrasound emitted from wind turbines is also well
below the audible threshold. Many types of sound sources (e.g., road traffic) also emit low
frequency sound. Low frequency sound from wind turbines occurs in levels that are generally
close to the hearing and/or masking threshold. Low frequency sound may be produced by wind
turbines under certain meteorological conditions but actual sound levels depend on the separation
distance between the listener and the wind turbine.
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Exhibit 2.2.5 – Noise Modeling Results – Cumulative Impact from Proposed Neighboring Windfarm
2-17
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In December 2009, a report was published by a panel composed of professionals of varied

backgrounds (e.g., audiology, acoustics, environmental medicine, etc.) from the United States,
Canada, Denmark, and the United Kingdom that completed research and an extensive review of
peer-reviewed and non-peer reviewed literature. The objective of this undertaking was to
produce an authoritative reference document for legislators, regulators, and others who want to
make sense of conflicting information about wind turbine sound. This report concluded that sub-
audible, low frequency, and infrasound from wind turbines do not present a risk to human health
(Colby et al., 2009). The findings of this report are supported by operational measurements
completed by other qualified consultants and researchers with results compared to national and
international noise standards developed to address the low frequency portion of wind turbine
sound emissions. As part of this study, the panel also considered the quality of epidemiologic
evidence required to prove harm. They determined that:
“In epidemiology, initial case reports and uncontrolled observations of disease

associations need to be confirmed through controlled studies with case-control or
cohort methodology before they can be accepted as reflective of casual
connections between wind turbine sound and health effects. In the area of wind
turbine health effects, no case-control or cohort studies have been conducted as of
this date. Accordingly, allegations of adverse health effects from wind turbines
are as yet unproven. Panel members agree that the number and uncontrolled
nature of existing case reports of adverse health effects alleged to be associated
with wind turbines are insufficient to advocate for funding further studies.”
The panel concluded that:
x Sound from wind turbines does not pose a risk of hearing loss or any other
adverse health effect in humans.
x Subaudible, low frequency sound and infrasound from wind turbines do not
present a risk to human health.
x Some people may be annoyed at the presence of sound from wind turbines.
Annoyance is not a pathological entity.
x A major cause of concern about wind turbine sound is its fluctuating nature. Some
may find this sound annoying, a reaction that depends primarily on personal
characteristics as opposed to the intensity of the sound level.
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Mitigation measures proposed for Project construction remain unchanged. To address potential
operational impacts, SLW has redesigned the Project to minimize environmental noise during
Project operations by reducing the number of wind turbines (most recently, eliminating Turbine
11) and siting wind turbines as far away from existing residential receptor locations as
practicable, while keeping the Project an economically viable source of clean renewable energy.
During project operations, SLW has committed to implementing a complaint resolution program
whereby neighboring residents can contact SLW with their concerns. Complaints will be logged
and promptly investigated in order to resolve any verifiable issue or exceedance condition, and
mitigation may be taken on a case-by-case basis. The details of the complaint resolution program
are provided in Appendix C-11.
2.2.4 Shadow Flicker

The shadow flicker analysis was rerun to address micrositing changes to the Project layout.
Results of the revised study are provided in Appendix C-10.

Of 177 shadow receptors located within 10 rotor diameters:
x 67 (37.8%) will be affected less than 1 hr/yr;
x 84 (47.5%) will be affected 1-10 hrs/yr;
x 19 (10.7%) will be affected 11-20 hrs/yr; and
x 7 (3.9%) will be affected 21-30 hrs/yr
No residences will be affected more than 30 hours per year. All residences that are projected to
be affected more than 20 hours per year are participating in the Project. Based on the limited
number of hours any structure will be affected, shadow flicker is not expected to create an
adverse impact on nearby residential dwellings. For residences where shadow flicker is greatest,
this impact might be considered an annoyance by some, but be unnoticed by others.

Based on the results of the shadow flicker study, no non-participating landowners near the
Project area will be affected by more than 20 hours of shadow flicker per year. No mitigation is
necessary.
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2.2.5 Transmission Line

A 115 kV overhead transmission line will be used to transport power from the collection
substation on Swamp Road in the Town of Cape Vincent to the existing 115kV National Grid
owned substation on Route 179 in the Town of Lyme (See Figure 1). SLW has proposed that the
transmission line will primarily follow the abandoned railroad bed which contains an existing
regional water line owned and operated by the Development Authority of the North Country
(DANC). The total parallel shared ROW of the regional water line and the proposed transmission
line is 7.69 miles. This is the same route proposed and discussed in the SDEIS.
SLW has been working with DANC to identify the construction practices and setback
requirements from the existing water line. On September 30th, 2009 and November 12th, 2009,
representatives from DANC and SLW met to discuss concerns, plans and design standards for
the proposed transmission line. SLW engaged in preliminary engineering with Sargent & Lundy
LLC to determine the design requirements and pole locations for the proposed transmission line.
The focus of the engineering analysis was to design a transmission line that meets all industry
standards and codes, protects the integrity of the water line, allows safe operation and
maintenance of the water line by DANC employees and does not inhibit the operation of the
water line.
DANC has expressed a desire that the proposed transmission line setback the maximum distance
possible from the regional water line, that the vertical clearance between the water line and the
transmission line be maximized, and that the number of times the transmission line crosses the
water line be minimized.
DANC engineers have been involved in reviewing the scope of work for the preliminary
engineering study and the credentials of the engineering firms selected to perform the work.
Three conference calls have taken place where representatives from DANC have reviewed,
discussed and commented on the progress of the preliminary engineering analysis. The
Engineering Concept Report for the proposed transmission line (See Appendix C-7) was
delivered to DANC on April 26, 2010 for their review. DANC has determined that SLW’s
proposed concept design meets their specified minimum requirements (See Appendix A-8).
SLW will continue to work with DANC on the final design, plans and schedule for the proposed
transmission line. Prior to construction of the transmission line, SLW will negotiate a written
agreement with DANC and, at a minimum, will commit to:
x Provide DANC with documentation that appropriate easements have been secured from
property owners;
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Exhibit 2.2.6 – Plan View of Proposed Transmission Owner Interconnection Substation
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Exhibit 2.2.7 – Profile View of Proposed Transmission Owner Interconnection Substation
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x Provide construction plans and specifications for DANC’s approval;

x Coordinate with DANC during construction to allow for access to the regional water line
for maintenance and emergencies; and
x Ensure DANC’s involvement in progress meetings regarding Project construction in the
regional water line ROW.
The transmission line will terminate at a transmission owner interconnection substation located
on County Route 179 where it will interconnect to an existing 115 kV transmission line at the
operating National Grid substation in the Town of Lyme. Plan and profile views of the proposed
substation are provided in Exhibits 2.2.6 and 2.2.7.
SLW has also been in communication with BP regarding sharing of the transmission line for
BP’s proposed project and will continue to work with BP on an agreement for co-use of the
transmission line (See Appendix A). The poles that are proposed for the SLW Project will be
physically adequate to carry lines that may be needed by BP's proposed project.

It is a very common practice for utilities to share road ROW in urban and rural locations. Water
lines are also typically located in the shared ROWs often outside the pavement in the shoulder
area with the transmission line. These lines run parallel and are close together, in some cases
very close. While the routing has not changed from that proposed and discussed in the SDEIS,
SLW has developed a preliminary design that establishes the horizontal and vertical clearances
of the transmission line. The design criteria address safety and operational issues associated with
the DANC water line and the proposed transmission line. The preliminary design analysis has
established the following separations:
x A minimum horizontal clearance of 8 feet, 4 inches from edge of the transmission pole to
the outer edge of the water pipe; and
x A minimum vertical clearance of 38 feet, 10 inches for the ground surface to the lowest
conductor height.
In addition, no transmission poles will be located on the top of the railroad bed and no guy wires
will be located on or span across the railroad bed to avoid DANC maintance equipment. To
ensure that the water line will not be disturbed during installation of the transmission line poles,
no blasting or detonation of explosives will be performed if rock is encountered while digging
holes. Construction will only utilize rock drilling methods that have minimum impact on the
water line.
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The preliminary design provides for a transmission line route that maximizes the horizontal
distance from the regional water line, minimizes the number of crossings and provides the
appropriate vertical clearance taking into consideration the environmental, land, agricultural and
water line maintenance constraints. This distance is more than needed based on the conservative
analysis and design criteria.

To offset unavoidable visual impacts resulting from the transmission line, the Project has
proposed a visual mitigation plan for the Town of Lyme. SLW proposes to fund renovation of
two community vaults in the Three Mile Bay Cemetery, and to use the remainder of the funds for
vegetative screening of historic resources.
To compensate for potential impacts to wildlife habitat associated with construction of the
transmission line through Ashland Wildlife Management Area (WMA), SLW has committed to
purchasing a 25-acre parcel contiguous to the nearby Point Peninsula WMA in the Town of
Lyme. The WMA provides valuable natural and recreational resources that benefit a wide
variety of wildlife species while being enjoyed by millions of visitors each year. Protection and
enhancement of WMAs in general, thru acquisition, is critical to long term stewardship of these
resources. In particular, the proposed 25-acre Point Peninsula WMA addition will enhance the
area's value as wildlife habitat in general and as a major winter raptor concentration area. The
grassland, wetland and forest complex found on this WMA provides habitat for many common
wildlife species such as white-tailed deer, Canada goose, great blue herons and snapping turtles,
along with less common, endangered and threatened species such as short-eared owl, northern
harrier and Blandings turtle. Adding these lands to the WMA's existing 1000 plus acres will also
improve the potential for popular north country public access activities such as hunting and bird
watching.
SLW is committed to ensuring the communities’ quantity and quality of water is maintained
during construction and operation of the Project, including construction of the transmission line
adjacent to the regional water line. The following steps will be implemented to avoid the
possibility of a breach in the water line during transmission line construction:
x SLW will obtain DANC’s approval of its construction plans near the regional water line
prior to the commencement of construction.
x The main line and all laterals will be marked prior to the initiation of any construction
activities associated with the transmission line.
x A safe buffer distance will be established and maintained during construction of the
transmission line.
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x All construction workers will be informed of the location of the water line and safe
working distances.
x The presence of the water line and construction safety will be emphasized during daily
health and safety briefings for all crew members.
x Emergency numbers will be obtained prior to the initiation of construction and made
readily accessible to all crew chiefs.
In the unlikely event of a breach of the water line the following will be implemented:
x The work area will be shut down and secured.
x DANC will be notified immediately.
x The local police will be notified immediately.
x Best reasonable efforts will be made to repair a breach in the water line within 8 to 12
hours of notice to SLW.
x .SLW will develop a plan to provide water in the event of a water line breach prior to
start of construction. This plan will be approved by DANC and the New York State
Department of Health. This plan will also indentify a contractor responsible for
implementing the approved plan.
2.2.6 FAA/NTIA (Communications)

FAA
Per SLW request, the Federal Aviation Administration (FAA) conducted an aeronautical study of
the 51 proposed turbines and their locations under the provision of 49 U.S.C., Section 44718 and
Title 14 of the code of Federal Regulations, part 77, as applicable. Correspondence documenting
SLW’s request is provided in Appendix A.
NTIA
SLW notified the United States Department of Commerce, National Telecommunications and
Information Administration (NTIA) of the revised Project layout and requested any concerns the
agencies represented in the Interdepartment Radio Advisory Committee (IRAC) may have
regarding blockage of their radio frequency transmissions. SLW’s request is provided in
Appendix A.
Over-the Air TV
A Final Over-the-Air TV Station Assessment was conducted to determine impacts of the final
Project layout to any over-the-air TV broadcast signals (Appendix C-16). Jefferson County is
located in the Watertown, NY Designated Market Area (DMA). Three of four U.S. full service
digital TV facilities in the Watertown DMA place a predicted FCC
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primary service signal over the Project area (Table 2-4). In addition, seven Canadian TV
broadcast stations are predicted to serve the Project area (Table 2-5).
Table 2-4
U.S. Digital TV Stations Predicted to Serve Project Area
Sign City of Power Ant. Height Distance Azimuth
Affiliate Channel
Network License (KW) (m HAAT) (km) (°T)
WWNY-TV CBS 7 Carthage, NY 24.9 219 47.7 116.7
WWTI ABC, CW 21 Watertown, NY 25 331 52.5 124.4
WPBS-DT PBS 41 Watertown, NY 59 369.5 53.1 126.5
Table 2-5
Canadian TV Stations Predicted to Serve Project Area
Sign Analog Digital Distance Azimuth
Affiliate City of License
Network Channel Channel (km) (°T)
CKWS-TV CBC 11 11 Kingston, ON 13.6 279.4
CBLFT-13 Radio-Canada 15 15 Belleville, ON 77.9 284.0
CICO-TV-53 TV Ontario 53 26 Belleville, ON 77.9 284.0
CBC - - 32 Kingston, ON 23.7 312.0
CBLFT-14 Radio-Canada 32 36 Kingston, ON 23.7 312.0
CICO-TV-38 TV Ontario 38 38 Kingston, ON 23.7 312.0
CJOH-TV-6 CTV 6 49 Deseronto, ON 65.3 269.7

FAA
The FAA determined that the proposed turbines do not exceed obstruction standards and would
not be a hazard to air navigation provided that the turbines are marked and/or lighted in
accordance with FAA Advisory Circular 70/7460-1K Change 2, Obstruction Marking and
Lighting, white paint/synchronized red lights - Chapters 4, 12 and 13 (turbines). Correspondence
documenting its determinations is provided in Appendix A.
NTIA
The agencies represented in the IRAC did not identify any concerns regarding radio frequency
blockage; therefore the Project will have no impact radio frequency transmissions. The response
from the NTIA is provided in Appendix A.
Over-the Air TV
There is some possibility of multipath interference to over-the-air reception of some of the
distant stations in Watertown, NY and Belleville, ON. Residential viewers in the vicinity of the
Project that point their outdoor antennas through the turbines, utilize “rabbit ears” type antennas,
or own TV sets more than approximately five years old are likely to be most affected. Most
modern HDTV sets should successfully handle the described anomalies.
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Most of the multipath effect should be dissipated for locations farther than approximately three
miles from a turbine, but some residual problems could be noted for TV receivers that are
located below the grade level at the turbine base. Approximately 10 percent of receiver locations
are affected to some extent within three miles of a wind turbine farm. The usual effect is
intermittent “pixelating” or “freezing” of high definition (HD) TV picture, and “tearing” of an
analog picture.
Approximately 4,000 U.S. households are within an area likely to be affected (roughly within 12
kilometers from the center of the turbine area). Conservatively estimated, at least 50 percent of
the households in the area are likely served by cable or satellite TV and thus would not be
affected by wind turbine disruption. Based on the 10 percent criteria described previously, it is
most likely that up to 200 digital TV receiver households could be affected.

FAA
A lighting plan has been developed in accordance with FAA Advisory Circular 70/7460-1K
Change 2; Obstruction Marking and Lighting, white paint/synchronized red lights - Chapters 4,
12 and 13 (turbines). This plan is provided in Appendix C-15.
NTIA
The Project will have no impact on radio frequency transmissions of agencies represented in the
IRAC. Therefore, no mitigation measures will be necessary.
Over-the Air TV
Possible mitigation methods (listed from most effective to least effective) to be applied at the TV
receiving household following Project construction are:
x Relocation of the antenna to receive a better signal
x Installation of a higher-quality outside antenna, or one with a higher gain
x Purchase of a new HDTV set or converter box
x Installation of satellite or cable TV.
SLW will utilize the Complaint Resolution process for handling this and other complaints related
to construction of the Project.
2.2.7 Transportation/Traffic
The revised primary and secondary equipment delivery routes and private access roads are
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003649
provided on Figure 2-5 and Figure 2-6, respectively. SLW also completed a Transportation
Route Evaluation Study (Appendix C-5). The purpose of this study was to determine the
probable local travel routes and potential improvements required for delivery of major wind
turbine components during the construction of the Project. A number of intersection
improvements were been identified. A logistics firm and/or transportation provider experienced
with oversized loads will be engaged in the final route analysis and permit process. The study
also provides a preconstruction photo log that establishes the pre-existing conditions as basis for
the remediation plan.

Twenty-three intersections and five segments of roadways associated with the Project will
require improvements to or movement of existing signage, utility poles, overhead wires,
overhead signals, culvert/drainage structures, rights-of-way of non-participating property
owners, curve/intersection widening, existing trees/vegetation, or road conditions (Table 2-6).

SLW is committed to working with the Towns, County, and State agencies to confirm necessary
transportation improvements needed before delivery of equipment to the Project and any
restoration and/or remediation needed after completion of the Project, and that such
improvements will be stipulated in the Project approval. These could include:
x Additional route and condition surveys.
x Temporary removal of obstacles and replacement in kind.
x Completion of improvements before the Project.
x Restoration and/or remediation after the Project.
In addition, road use agreements will be developed with the transportation departments
responsible for public roads during the site plan review process. These agreements will include
adequate detail for evaluating the pre-construction condition of existing roads, standards for
required improvements and restoration, and a mechanism for establishing that restoration has
been satisfactorily completed to the agreed upon standards.
2.2.8 Miscellaneous
Agency Correspondence
Documentation of agency correspondence subsequent to the SDEIS approval is provided in
Appendix A.
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Table 2-6
Potential Impacts Associated with Roadway Improvements
Participating Property
Existing Sign Impacts
ROW Impacts to Non-

Intersection Quadrant
Utility Pole Impacts
Impacts to Existing
Curve/Intersection
Culvert/ Drainage
Trees/Vegetation
Overhead Signal
Road Condition
Overhead Wire
Impacted by Route
Improvement
Clearance
Clearance
Widening
Structure
Owners
Intersections
1) Route 104/Route 104B
2) Route 180/Route 3/County Rd 66 Ɣ
3) Route 180/Route 12F Northeast Ɣ Ɣ Ɣ Ɣ
Southeast Ɣ Ɣ Ɣ Ɣ
4) Route 12F/I-81 Exit 46 NB Ramp Northwest Ɣ Ɣ Ɣ
Northeast Ɣ Ɣ Ɣ
5) Route 342/I-81 Exit 48 NB Ramp Southeast Ɣ Ɣ Ɣ
6) Route 12/Route 342 Northeast Ɣ Ɣ Ɣ Ɣ
7) Route 12/County Rd 9 Southeast Ɣ Ɣ Ɣ
Southwest Ɣ Ɣ Ɣ Ɣ
8) County Rd 9/McKeever Rd Southwest Ɣ Ɣ Ɣ
9a) County Rd 8/McKeever Rd NB Southeast Ɣ Ɣ
9b) County Rd 8/McKeever Rd SB Southeast Ɣ Ɣ
10) County Rd 8/Mason Rd Northeast Ɣ
Southeast Ɣ Ɣ Ɣ
Intersections
11) Mason Rd/Gosier Rd Northwest Ɣ Ɣ Ɣ
12) Favret Rd/Mason Rd Southwest Ɣ Ɣ Ɣ
13a) Favret Rd/Hell St NB Northeast Ɣ Ɣ Ɣ
13b) Favret Rd/Hell St SB Southeast Ɣ Ɣ
14) Hell St/Constance Rd Northwest Ɣ Ɣ Ɣ Ɣ Ɣ
15) Favret Rd/Wilson Rd Southeast Ɣ Ɣ Ɣ
16) Route 12E/Favret Rd Northeast Ɣ Ɣ
17) Route 12E/Deerlick Rd Southeast Ɣ Ɣ Ɣ
Segments
Constance Road Ɣ
Wilson Road Ɣ
NY Route 12
at NY Route 180 Ɣ
at County Road 179 Ɣ
at County Road 4 Ɣ
Note: Selected quadrant represents the least impacts based on a review of the participating property owners
and existing intersection constraints.
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Property Values
The concern that property values will be adversely affected by development of the Project has
been expressed by a number of residents. Recent analysis of nearly 7,500 single-family homes
sales between 1996 and 2007 did not uncover conclusive evidence of the existence of any
widespread property value effects that might be present in communities surrounding wind energy
facilities (Hoen, B., R. Wiser, P. Cappers, M. Thayer, and G. Sethi, 2009). For this study homes
were situated within 10 miles of 24 existing wind facilities in nine different states with the
closest pricing models, as well as both repeat sales and sales volume models. A hedonic model
is a statistical analysis method used to estimate the impact of house characteristics on sales
prices.
The study concluded that neither the view of the wind facilities nor the distance of homes to
those facilities was found to have any consistent, measurable, and significant effect on the selling
prices of those homes. Though the analysis cannot dismiss the possibility that individual homes
or small numbers of homes have been negatively affected, it finds that if these impacts do exist,
they are either too small and/or too infrequent to result in any widespread, statistically
observable effect.
Storm Water Pollution Prevention Plan (SWPPP) for the St. Lawrence Windpower Project
This plan (See Appendix C-8) provides the measures SLW will implement to comply with the
State Pollutant Discharge Elimination System (SPDES) requirements for the General Permit for
Stormwater Discharges Associated with Construction Activities (GP-0-08-001). It identifies
potential sources of sediment and other pollutants that affect the quality of stormwater discharge,
and includes plans and measures to:
x Reduce or eliminate erosion and loading of sediment and other pollutants that effect the
quality of stormwater discharges to water bodies during construction;
x Control of the impact of stormwater runoff on the water quality of the receiving waters;
x Control of the increased volume and peak rate of runoff during and after construction;
x Maintain stormwater controls during and after completion of construction;
x Waste and material management for construction activities;
x Implement site inspections, monitoring and personnel training; and
x Identify any post-construction measures that would be required.
Unanticipated Discoveries Plan

This plan (See Appendix C-9) details the protocol that SLW will follow in the event that
previously unidentified archaeological resources, including human remains, are discovered
during the construction process.
2-30
003652
Revised Complaint Resolution Plan

This revised plan (Appendix C-11) outlines protocols for dealing with construction and operation
complaints associated with the St. Lawrence Windpower Project.
Spill Prevention, Control, and Countermeasure Plan (SPCC)

This plan (See Appendix C-12) outlines the requirements for oil spill prevention, preparedness,
and response to prevent oil discharges to navigable waters and adjoining shorelines associated
with the St. Lawrence Windpower Project
Draft Wildlife Protection Plan (WPP)

This plan (See Appendix C-13) describes principles that have been designed to provide guidance
to SLW employees, transparency to agencies, and trust to special interest groups in how SLW
will develop, construct, and operate the St. Lawrence Windpower Project. The document details
how SLW will perform work to identify, monitor, reduce, and account for mortality of wildlife
species at the proposed facility.
Draft Outline of Construction Environmental Monitoring Plan

This plan (See Appendix C-14) provides a comprehensive framework for site-specific
environmental procedures and requirements to ensure compliance with federal, state, and local
environmental laws and regulations. The environmental compliance program also includes
training, pre-construction coordination, and construction and restoration inspection activities,
associated with the St. Lawrence Windpower Project. After permits are acquired, SLW will
develop the body of this Plan to comply with all permit conditions and internal policies.
FAA Final Lighting Plan

This plan (See Appendix C-15) outlines the lighting of turbines associated with the St. Lawrence
Windpower Project for increased conspicuity to ensure safety to air navigation.
2-31
003653
3.0 COMMENT MATRIX

Comments received throughout the SEQR process for the Saint Lawrence Windpower Project
area summarized in Tables 3-1 and 3-2. Summaries of DEIS comments are provided in Table 3-
1 and SDEIS comments are provided Table 3-2. Comments were generally provided in letters to
the Planning Board; however, numerous oral comments were received during the Public
Hearings held for both the DEIS and SDEIS. Transcripts of the DEIS and SDEIS Public
Hearings are provided in Appendix D and copies of all written comments received are provided
in Appendix E in their entirety.
3-1
003654
Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Results of the 2006 bat survey and Avian and Bat Study Plan
need to be included in the SDEIS to support conclusions
Tomasik, Steven for stated in the DEIS; SDEIS should also include discussion of
1 1 NYSDEC
Jack Nasca mitigation measures that might be implemented if adverse
impacts are identified in the bat fatality monitoring program
(adaptive management strategy)
DEC does not agree that a more expanded cumulative
analysis is not warranted because "bird collisions with wind
projects represent a very small portion of all bird collisions
Tomasik, Steven for
1 2 NYSDEC with man-made objects," or that the other two proposed wind
Jack Nasca
projects in the region are "speculative". Using existing
available information, the SDEIS should provide a fuller
discussion of cumulative impacts.
SDEIS should include wetland delineation reports for any
areas that would be impacted by project construction; SDEIS
Tomasik, Steven for should discuss wetland avoidance and impact minimization
1 3 NYSDEC
Jack Nasca and proposed techniques to be used to minimize temporary
wetland impacts; feasibility study should be included to make
recommendations in regard to alternatives
If unavoidable wetland impacts result from project
construction, the SDEIS must discuss the overriding
economic and social needs for the project that outweigh the
Tomasik, Steven for
1 4 NYSDEC environmental costs of impacts on wetlands, describe
Jack Nasca
compensatory mitigation being considered, and how the
proposed mitigation will conform to DEC wetland mitigation
guidelines
Tomasik, Steven for The distinction between "temporary" and "permanent"
1 5 NYSDEC
Jack Nasca wetland impact needs to be clarified in the SDEIS
Tomasik, Steven for
1 6 NYSDEC SDEIS should include an Invasive Species Control Plan
Jack Nasca
Section 2.6.4. SDEIS needs to include a description of
Tomasik, Steven for specific processes that will be implemented to ensure that
1 7 NYSDEC
Jack Nasca concrete is handled properly during construction to limit
impacts to surface waters, wetlands and underground waters
3-2
003655
Table 3-1
Section 2.7 and 2.8. Environmental impacts associated with
major turbine repair or replacement, including recurrence of
"temporary" wetland impacts associated with access road re-
widening, not adequately discussed; SDEIS should include a
Tomasik, Steven for
1 9 NYSDEC project-wide long-term environmental management plan, a
Jack Nasca
contingency plan, and assessment and mitigation of
environmental impacts during the decommissioning process;
Environmental management plan should include an adaptive
management plan
Section 3.2.3.3 does not adequately describe the range of
Tomasik, Steven for
1 10 NYSDEC mitigation measures to be considered if project construction
Jack Nasca
results in unavoidable wetland impacts.
DEC recommends that a Blanding's turtle habitat and nest
Tomasik, Steven for site survey be included as part of wetland delineation
1 11 NYSDEC
Jack Nasca activities conducted in the project area. If appropriate habitat
is found, a trapping and tracking survey would be warranted.
DEC recommends that a comprehensive survey of karst
features be conducted in the project development area; DEC
Tomasik, Steven for
1 12 NYSDEC recommends that a plan be prepared that specifies
Jack Nasca
procedures for conducting detailed subsurface investigations
at locations that may interface with limestone/karst features.
Section 3.7.2. Survey to inventory architectural cultural
resources within one mile of the project is not included in the
Tomasik, Steven for
1 14 NYSDEC DEIS; furthermore, the survey's one-mile study area is
Jack Nasca
inadequate; DEC visual policy establishes a recommended
five-mile study area for visual impacts.
DEC recommends that the visual setting of each affected
significant resource in the project area and five-mile visual
impact area, including newly identified significant historic
Tomasik, Steven for resources, be analyzed, and where feasible at specific
1 15 NYSDEC
Jack Nasca impacted resources, direct mitigation options such as
screening or selective turbine re-location should be applied.
Offsets should be employed if these types of mitigation
would be uneconomic or only partially effective. Direct
3-3
003656
Table 3-1
mitigation and offsets need to be fully discussed in the
SDEIS. Mitigation for visual impacts should be developed in
concert with a mitigation strategy for impacts identified
according to the cultural resources assessment.
SDEIS needs to consider a cumulative assessment of visual
Tomasik, Steven for
1 16 NYSDEC impacts of this project and the two other wind power projects
Jack Nasca
proposed in the general area.
SDEIS should discuss the status and results of any historic
Tomasik, Steven for preservation studies undertaken; correspondence with
1 17 NYSDEC
Jack Nasca OPRHP detailing that agency's rationale for making an
impact/effect determination should be included in the SDEIS
Tomasik, Steven for Archeological studies should be completed prior to, and
1 18 NYSDEC
Jack Nasca incorporated in, the SDEIS
The SDEIS should describe a compliance and monitoring
Tomasik, Steven for
1 19 NYSDEC program to include planning, training, pre-construction
Jack Nasca
coordination, and construction/restoration inspection
DEC may require that the Stormwater Pollution Prevention
Tomasik, Steven for Plan prepared for the project to comply with the SPDES
1 13a NYSDEC
Jack Nasca Stormwater General Permit for Construction Activities be
reviewed by DEC staff prior to implementation
Appendix C. The Visual Impact Assessment (VIA) does not
include consideration of properties identified in the project
Tomasik, Steven for Cultural Resources Survey for this project which are not
1 13b NYSDEC
Jack Nasca currently inventoried, but which may be determined to be
National Register Eligible (Doesn't include results from 5-mile
study).
Section 2.3. No data provided to support statement that the
Stilwell, David and Tim
2 1 USFWS project will improve air quality by offsetting emissions
Sullivan
produced at fossil fuel burning power plants
Section 2.3. The DEIS indicates that the project will reduce
sulfur dioxide, nitrogen oxide, and other pollutants; however,
2 2 USFWS wind energy projects do not deliver the environmental
Sullivan
benefits typically described by project sponsors. Almost no
sulfur dioxide or nitrogen oxide would be eliminated from the
3-4
003657
Table 3-1
operation of wind energy projects.
It is not specified whether will be one or two meteorological
towers, nor is it mentioned what type of structure will be
Stilwell, David and Tim constructed; USFWS recommends that no guy wires be used
2 3 USFWS
Sullivan on the towers as they have been known to be flight hazards
for wildlife; monopole or self-supporting towers should be
installed
USFWS recommends that the siting of wind turbines avoid
Stilwell, David and Tim forested areas and structures instead by placed along the
2 4 USFWS
Sullivan edges of forests or be eliminated to limit habitat
fragmentation
Stilwell, David and Tim Section 2.5. USFWS found little data to support the need for
2 5 USFWS
Sullivan the project size
Section 2.5. DEIS does not indicate the locations of the best
2 6 USFWS wind resource; therefore they cannot determine what options
Sullivan
the project sponsor has to move turbine locations
Section 2.5. Data should identify areas where birds and bats
2 7 USFWS are concentrated, and thus, provide data to support alternate
Sullivan
turbine locations
Section 2.6. Since birds are likely to occur throughout the
Stilwell, David and Tim project site during the construction period, the USFWS
2 8 USFWS
Sullivan questions how impacts to breeding birds will be avoided
(stated in Table 1-1, Sheet 3 of 8).
Section 2.6. USFWS suggests that applicant reduce the final
2 9 USFWS proposed width of access roads to 16 feet, consistent with
Sullivan
access road width for other wind projects in the State.
Section 2.6. USFWS recommends that the project sponsor
Stilwell, David and Tim design the project so that more project facilities are
2 10 USFWS
Sullivan collocated. Currently only 3.4 miles of the 44 miles of buried
interconnect cable would be collocated along access roads.
Section 2.6. The project sponsor should reduce impacts to
Stilwell, David and Tim habitat as much as possible. Vegetation is proposed to be
2 11 USFWS
Sullivan cleared to a width of 25 feet where underground cable will be
buried but the actual cable trench would only be 1 to 3 feet
3-5
003658
Table 3-1
wide.
Section 2.6. Directional drilling should be used to cross all
2 12 USFWS perennial streams and wetlands to reduce the potential for
Sullivan
water quality impacts.
Section 2.6. The proposed route of the overhead
transmission line has not been determined, information vital
Stilwell, David and Tim to determine the potential impacts to wildlife. The
2 13 USFWS
Sullivan transmission line should be routed around forests to protect
existing habitat value, reduce fragmentation, and maintain
interior core areas.
Section 3.0. USFWS recommends that no turbines are sited
2 14 USFWS within peat muck areas as these soils may support rare and
Sullivan
irreplaceable habitat.
Stilwell, David and Tim Section 3.0. Karst features may provide unknown
2 15 USFWS
Sullivan hibernacula for bats and should be avoided.
Section 3.0. DEIS should specifically state that alvar
2 16 USFWS landscapes, located at Chaumont Barrens and Three Mile
Sullivan
Creek Barrens, will not be impacted by the project.
Section 3.2. The report should include biotic and water
2 17 USFWS quality data along with a discussion of potential impacts from
Sullivan
project construction.
Section 3.2. Project sponsor should identify which water
bodies will be crossed; the current condition of each; whether
they are perennial, intermittent, or ephemeral; and the exact
amount of temporary, permanent, direct, and indirect impact
Stilwell, David and Tim to each. This should include an analysis of impacts to water
2 18 USFWS
Sullivan quality, habitat conditions, and aquatic life. Mitigation
measures to compensate for lost or degraded habitat should
be discussed. Permanent stream crossings should consist of
bridges or bottomless culverts. In disturbed areas, stream
banks should be seeded and planted to prevent erosion.
A field delineation of wetlands should be completed and then
2 19 USFWS project design adjusted so that impacts are avoided and
Sullivan
minimized to the greatest extent practicable. The DEIS
3-6
003659
Table 3-1
should be revised with information on wetland extent; size;
physical characteristics; community type, function, and value;
and potential direct and indirect impacts to each.
Turbines should be located away from wetlands and water
2 20 USFWS bodies to avoid changing the character and function of these
Sullivan
features for wildlife.
DEIS does not identify if the wind project will impact the
efforts to establish St. Lawrence Wetland and Grassland
Management District (SLWGMD) nor does it mention if the
proposed project is compatible with the purpose of the
2 21 USFWS SLWGMD. This information should be provided to the
Sullivan
USFWS for review. Since waterfowl and grassland birds
may collide with turbines, and because the purpose of the
SLWGMD is to increase production of avian populations in
these areas, the two projects may not be compatible.
DEIS should provide the methodologies used to determine
Stilwell, David and Tim natural resource impacts. Habitat types in the project area
2 22 USFWS
Sullivan should be field checked so that impact assessments are
accurate.
No discussion of reptiles and amphibians potentially found in
the project area is included in the document. Nor is there
2 23 USFWS any discussion of potential impacts to these species. The
Sullivan
New York State Amphibian and Reptile Atlas (NYSDEC)
should be consulted.
The discussion of affected mammals is inadequate, as no
survey data or existing information sources were provided.
The Lead Agency should require the project sponsor to
Stilwell, David and Tim include this information in a revised report. The statement
2 24 USFWS
Sullivan that "no threatened or endangered mammals, or their critical
habitat, are located within the project area" should be
removed as insufficient studies have been conducted to
determine the presence of listed bats.
Stilwell, David and Tim Section 3.3.3. The fact that the Indiana bat is a State- and
2 25 USFWS
Sullivan Federally-listed endangered species should be clarified.
3-7
003660
Table 3-1
The statement that Indiana bats have not been recorded in
Stilwell, David and Tim the project area is misleading. Results from the acoustic
2 26 USFWS
Sullivan monitoring have not been presented and no mist-netting has
occurred within the proposed project area.
The distances to Indiana bat locations are incorrect. Multiple
Indiana bat spring/summer roosts have been documented
2 27 USFWS within 10 miles of the project area. The Glen Park
Sullivan
hibernaculum is approximately documented 17 miles
southeast of the project area.
Further analyses regarding potential impacts to bats from the
proposed project are needed. There is nothing to support
the claim that "Predicting bat fatality impact is difficult based
2 28 USFWS on available knowledge of bat interactions with wind facilities
Sullivan
but is expected that impacts to bats at the Saint Lawrence
Wind Energy Project would be similar to other regional wind
projects"
The USFWS does not agree that Section 3.3.7 provides an
adequate assessment of potential impacts to the Indiana bat.
Stilwell, David and Tim Large numbers of bats have been killed by wind turbines in
2 29 USFWS
Sullivan the East and the potential cumulative impact on populations
could be significant. Should the proposed project be
constructed, a bat fatality monitoring program is necessary.
Section 3.3.4 DEIS does not disclose that Derby Hill has
among the highest number of raptors observed during spring
migration in the Northeast. Also, the text does not
Stilwell, David and Tim adequately address the fact that large numbers of raptor
2 30 USFWS
Sullivan species, such as bald eagles, golden eagles, northern
harriers, and peregrine falcons move along the Lake Ontario
shoreline toward the project area. An adequate assessment
of risk to these species should be provided.
Section 3.3.4. It is unclear how the project sponsor can
2 31 USFWS claim that the project design minimizes impacts to migrating
Sullivan
birds when avian migration data is not yet available.
2 32 USFWS Stilwell, David and Tim Section 3.3.5. Project-specific breeding bird data should be
3-8
003661
Table 3-1
Sullivan included in a revised report. This should include information
on the potential impacts to grassland nesting birds endemic
to the region. Sponsor should evaluate project compatibility
with Service' efforts to increase productivity of grassland and
waterbirds in the area.
Section 3.3.6. There are a large number of wintering raptors
Stilwell, David and Tim other than bald eagles in the region. This information should
2 33 USFWS
Sullivan be considered by the project sponsor in siting the project
features.
Section 3.3.6. The project sponsor should review the
Stilwell, David and Tim Service's "Interim Guidelines to Avoid and Minimize Wildlife
2 34 USFWS
Sullivan Impacts from Wind Turbines" (Guidelines) (USFWS 2003)
during design of the project.
Section 3.3.6. A risk assessment that includes information
on bird abundance and distribution over multiple seasons
and years, avian avoidance behavior of turbines, weather
data, and information on migration, breeding, wintering, and
2 35 USFWS stopover habitat should be included in the environmental
Sullivan
documents. Insufficient data were collected at the project
site to determine use of the project airspace by flying animals
to conduct a risk assessment and predict wildlife mortality for
this project.
A post-construction monitoring protocol should be provided
to the NYSDEC and USFWS for review. If turbines are
Stilwell, David and Tim located within blocks of grassland habitat, turbines should
2 36 USFWS
Sullivan not have a cut-in speed of less than 6 meters per second
and operation should be curtailed between July 15 and
September 15 for 5 hours after sunset.
A construction environmental monitoring program should be
Stilwell, David and Tim implemented, which includes a training component for
2 37 USFWS
Sullivan workers on how to identify and handle injured or dead
wildlife.
Stilwell, David and Tim Section 3.3.7. Copy of the current draft protocols from the
2 38 USFWS
Sullivan recently issued Draft Revised Indiana Bat Recovery Plan for
3-9
003662
Table 3-1
information on this species and mist-netting procedures
enclosed.
The FEIS should address the potential effects of the action
on the Indiana bat and bald eagle in far greater detail than
2 39 USFWS the DEIS. Additionally, the Corps or applicant should
Sullivan
prepare a Biological Assessment (BA) for the proposed
project.
Section 3.3.7. Adverse impacts to Blanding’s turtle are
unclear. The turtles use upland areas for many activities
2 40 USFWS including basking and nesting. Further discussion with the
Sullivan
NYSDEC is necessary to determine the potential for impacts
to Blanding's turtles.
Section 3.3.7. The statement "Based on the wintering bald
eagle's use of the St. Lawrence River, the Project is not
expected to have an adverse affect on eagle foraging or
substantially increase the risk of eagle foraging or
substantially increase the risk of eagle collisions with
2 41 USFWS turbines" is confusing and unsubstantiated. Section should
Sullivan
address eagle nesting, wintering, and migration occurrences
and behaviors, and link those to potential effects to the eagle
from turbine construction and operation. Increased potential
for collision during adverse weather conditions should also
be discussed.
Section 3.3.7. The statement "Although dispersal of the
Indiana bat is in the range of the proposed Project, impacts
are considered unlikely as Indiana bats typically fly low to the
2 42 USFWS ground, below the rotor sweep are" is unsubstantiated at this
Sullivan
time. Mist-netting should be done performed. Potential
impacts due to construction and operation of the proposed
project will need to be analyzed in much greater detail.
Section 4.0. The DEIS should provide a general description
Stilwell, David and Tim of where the other 2 proposed wind energy projects are
2 43 USFWS
Sullivan located in the region; the assumption should be made that
these projects will be constructed; more discussion should be
3-10
003663
Table 3-1
provided on the potential effects on wildlife, particularly avian
and bat species.
Section 7.0. Wind data were not provided for the project
Stilwell, David and Tim area; therefore, alternative turbine locations could not be
2 44 USFWS
Sullivan determined. The project design, including project size,
should reflect efforts to avoid and minimize impacts.
State of New York
Section 2.6.5. The minimum burial depth in agricultural
Department of
3 1 Brower, Matthew areas should be 48 inches for all methods, unless bedrock is
Agriculture and
encountered at less than 48 inches.
Markets
The Department recommends that the 34.5 kV lines be
buried in agricultural fields. If lines must be installed
State of New York
overhead, they should be located outside field boundaries
Department of
3 2 Brower, Matthew wherever possible. When these lines cross farmland,
Agriculture and
spanning distances should be no less than 400 feet. Line
Markets
location and pole placements should be reviewed with the
Dept. prior to final design.
State of New York
Department of Recently revised "Guidelines for Agricultural Mitigation for
3 3 Brower, Matthew
Agriculture and Windpower Projects" is enclosed
Markets
The DEIS does not include in sufficient detail the specific
State of New York
project components necessary for project operation; specific
4 1 Department of Public Davis, Andrew
knowledge of the proposed turbine sizes, make and model is
Service
appropriate for consideration in a DEIS.
Project components not described in the DEIS include:
communications equipment associated with turbine field
operations, typically including SCADA communication cables
State of New York from each turbine to substations and the O&M facilities;
4 2 Department of Public Davis, Andrew substation communication equipment to downstream electric
Service transmission substations; the 9-mile long overhead line,
substation equipment for low-voltage step-up to transmission
voltage and transmission interconnection facilities at the
NMPC Lyme Substation; and any downstream improvements
3-11
003664
Table 3-1
to the NMPC transmission system to accommodate the
electrical output of the project. All subsequent analyses of
project impacts should specifically address the size, location,
and nature of impacts associated with those project
components.
Added information to the project website subsequent to
State of New York issuance of the DEIS has not been adequately noticed or
4 3 Department of Public Davis, Andrew formally issued to involved agencies or to the public.
Service Documents should be circulated with notice of the
appropriate comment period.
Section 2.5.2. The town should consider the size and scale
of the proposed turbines in establishing appropriate setback
State of New York
distances from adjacent properties; a buffer of 75 feet from
adjacent property lines would likely represent the smallest
Service
setback yet specified for any major wind turbine siting project
in NY.
Section 2.5.2. Increased setback distances from the St.
Lawrence River and Lake Ontario, the Seaway Trail Scenic
Byway, historic properties listed or eligible for the State and
State of New York National Register of Historic Places, designated Coastal
4 5 Department of Public Davis, Andrew Zone areas including Significant Coastal Fish and Wildlife
Service Habitats and Local Waterfront Revitalization areas, and
designated Wildlife Management Areas should be seriously
considered and addressed in detail as project planning and
environmental review proceeds.
Section 2.6.3. The Guidelines for Agricultural Mitigation
included in the DEIS are outdated; and the application of
State of New York
agricultural protection and mitigation measures will be
required for implementation in Agricultural Districts by any
Service
Certificate of Public Convenience and Necessity issued by
the PSC.
State of New York Section 2.6.5. Disturbance specifications and impact
4 7 Department of Public Davis, Andrew characterizations would probably significantly under
Service represent impacts and installation methodologies where soil
3-12
003665
Table 3-1
is limited. Burial depth for cables is likely to encounter
bedrock at many areas; bedrock cutting and additional steps
would be necessary for installation at the recommended
depths in agricultural lands. SDEIS should include a careful
analysis of soils characteristics and limitations, based on field
surveys of soils cover depth for proposed facilities sites.
Where soils depth or wetness limitations influence
consideration of overhead, rather than underground
gathering line placement, those locations should be identified
and analyzed for related effects on land use, visibility , and
co-location with other utility equipment such as overhead
electric lines and telephone cables.
Section 2.6.7. The location of the Project substation is within
or directly adjacent to the Warren Wilson House Historic
District, which warrants consideration of alternative locations
to avoid any adverse effect on the Historic District.
State of New York
Additional information should be provided including a site
plan and profile drawings of the arrangement and types of
Service
equipment proposed for the substation, depiction of its
appearance and the relation to the defining characteristics of
the Historic District. Alternative locations should be and
results reported in a Supplemental DEIS.
Section 2.6.8. The DEIS provides limited information
regarding the proposed overhead transmission line. The
location of facilities should be specified, and alternatives,
including consideration of the costs and benefits of
State of New York
underground location for all or part of the line should be
addressed. Consideration of underground placement should
Service
address the crossing of the Chaumont River, any regulated
wetlands or Wildlife Management Areas, Important Bird
Areas, locations visible from the Seaway Trail Scenic Byway,
Historic Districts, and other locations as appropriate.
State of New York If the abandoned railroad grade from Cape Vincent through
4 10 Davis, Andrew
Department of Public Lyme to near the Chaumont River, analysis of the line and of
3-13
003666
Table 3-1
Service ROW location should address: clearing of forest and shrub
cover; relation of the line location to existing water main
within the RR grade; access limitations where bridge
crossings are insufficient or no longer exist.
Transmission facility information which should be provided
into the SDEIS includes: facility design, including structure
types, height and width; expected electromagnetic and
electric field levels at facility centerline, ROW edge and
State of New York
nearest residence; assessment of clearing needs and
vegetation management specifications; relation of facility
Service
location to other overhead and underground utilities and
other existing infrastructure; ROW access improvement
needs and limitations, such as for stream or wetland crossing
locations.
Section 3.1. SDEIS should include an overlay of the project
facilities on a map of floodplain locations; and analysis of
State of New York floodplain limitations on facility location, design and
4 12 Department of Public Davis, Andrew mitigation needs should be provided. Appropriate design
Service criteria should be specified to assure conformance with
floodplain regulations and any requirements of local or
federal floodplain insurance programs.
Discussion of streams, rivers and lakes, wetlands and
State of New York ecological resources does not include any consideration of
4 13 Department of Public Davis, Andrew several Coastal Zone Significant Fish and Wildlife Habitats
Service within the general project area, and downstream from much
of the proposed project area.
SDEIS should include detailed consideration of: the French
Creek Marsh, St. Lawrence River Shoreline Bays, Wilson
Bay and Marsh, and the avian and waterfowl habitats
State of New York
supported by other Coastal Zone Significant Habitats
including Fox Island - Grenadier Island Shoals, Carlton
Service
island, Point Peninsula, and Point Peninsula Marsh. Habitat
impairment tests should be completed for each of the
Significant areas in the project vicinity.
3-14
003667
Table 3-1
State of New York
A Coastal Zone Consistency Analysis should be included in
the SDEIS
Service
State of New York The Avian and Bat Studies Interim Report (May 2007) should
4 16 Department of Public Davis, Andrew be included in the SDEIS and circulated to involved agencies
Service with appropriate notice to involved agencies and the public.
A single fall season of field observation is not a sufficient
State of New York basis for drawing conclusions regarding impacts, average
4 17 Department of Public Davis, Andrew population characteristics or usage of the project area from
Service birds and bats. Additional seasons of data should be
collected, analyzed, and reported in the SDEIS.
State of New York Characterizations of avian and bat impact should also note
4 18 Department of Public Davis, Andrew recent information reported from other NYS locations,
Service including the Maple Ridge project in Lewis County.
Consideration of the use of the area by migratory species
should include the broader area including Wildlife
State of New York Management Areas and the Coastal Zone Significant
4 19 Department of Public Davis, Andrew Habitats. Study locations were focused on the northerly -
Service westerly portions of the project area, while there are large
areas of wetlands and grassland habitats along the easterly
side of the project area.
Mitigation measures should be replaced with responsible
consideration of mitigation based on results of on-going field
State of New York studies. A commitment to adopting adaptive management
4 20 Department of Public Davis, Andrew principles and detailed plans for facility operation and
Service management, including measures to avoid significant
adverse impacts on bird and bat populations and habitats
should be specified.
The statements that "131 birds known to breed in the Project
area" and "total number of birds varies between 104 and
State of New York
117" should be clarified to reflect the numbers of bird species
encountered. If only 131 individual birds were counted in
Service
surveys of the Project area, then the studies should be
started over during periods when there are actually breeding
3-15
003668
Table 3-1
or migratory populations present.
Survey results reported to date do not address over-
wintering species presence or use patterns even though the
State of New York
DEIS states that "survey results will identify specific species
that winter at the site and their use patterns of the site" and
Service
the project will "minimize impacts to wintering roosting and
foraging birds."
State of New York
The May 2007 Interim Report does not provide page 29 for
review.
Service
The discussion of threatened and endangered species and
Areas of Critical Concern dismisses any potential adverse
impacts, despite the surveys for the listed species not having
State of New York been completed, and despite the preliminary description of
4 24 Department of Public Davis, Andrew the project components and facility locations. More detailed
Service consideration of the endangered Indiana Bat, the
endangered short-eared owls, and other rare, threatened
and endangered species is warranted than in the cursory
discussion in the DEIS.
Recent management activities at the Ashland Flats Wildlife
State of New York
Management Area, including habitat manipulation and
clearing of forest cover for grassland species management,
Service
should be reported and considered in detail.
Section 3.4. Discussion of transportation and traffic impacts
State of New York should be expanded to specifically address the potential to
4 26 Department of Public Davis, Andrew adversely affect traffic on Route 12E, the Seaway Trail
Service designated Scenic Byway and tourism route. Safety
concerns warrant additional consideration.
Section 3.4. Effects of the appearance of the project
State of New York facilities from the Route 12E Seaway Trail Scenic Byway
4 27 Department of Public Davis, Andrew should be considered as a potential effect of facility
Service operations on traffic. Turbines will have the potential to
distract drivers' attention from safe vehicle operation.
4 28 State of New York Davis, Andrew Section 3.4. Consultation with NYSDOT regarding facility
3-16
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Table 3-1
Department of Public construction routing and equipment delivery, and facility
Service operational considerations is recommended, and specific
traffic controls and mitigation planning options should be
reported in the SDEIS
Section 3.4. Discussion of potential impacts to local roads
State of New York
should also include potential grading to reduce high spots to
accommodate the extremely long delivery trailers (e.g.,
Service
approach to the proposed substation along Swamp Road)
Section 3.5. The discussion of project area land use does
not acknowledge the significant areas with the project area
towns which are wetland or habitat reserves. These areas
State of New York
should be addressed as natural areas with significance at
local, regional and statewide scales, as acknowledged in the
Service
designations as Wildlife Management Areas, NYS-regulated
wetlands, and Coastal Zone Significant Fish and Wildlife
Habitats.
Section 3.5. The discussion of the Coastal Management
Program is not a complete consideration of the
responsibilities on New York State agencies in consideration
of actions affecting the designated State Coastal Zone.
Responsibilities of the State Agency include consideration of
State of New York
direct effects on coastal resources and potential indirect
effects on resources such as visual effects on coastal areas
Service
and impacts on historic resources located within the coastal
zone; or effects of construction on coastal resources, such as
sedimentation and erosion from a project site on vulnerable
significant habitat locations downstream from the
construction site.
Section 3.5. The DEIS does not include a Coastal Zone
Consistency evaluation. Within this, discussion of the Scenic
State of New York
Quality Policies should address visual effect of the project on
viewpoints within the Coastal Zone; Recreation policies
Service
discussion should address effects of the project on coastal
zone recreational areas and parks, cultural, historic and
3-17
003670
Table 3-1
architectural resources; potential project effects on
Significant Coastal Zone Fish and Wildlife Habitats should be
addressed.
The SDEIS should include a complete Coastal Zone
State of New York
Consistency Review, and should document address the full
range of Coastal Policies as listed in 19 NYCRR Section
Service
600.5
Section 3.7. The discussion of Cultural Resources does not
indicate that the project proposes to site turbines, gathering
lines and the gathering and step-up substation within and
State of New York
within close proximity of Historic Properties listed on the
National Register of Historic Places (i.e., Warren Wilson
Service
House and N. Cocaigne House). Potential direct project
impacts on Historic Properties and District locations should
be conveyed explicitly in the DEIS
The project area of potential effect (APE) should be
State of New York expanded to address the proposed substation
4 35 Department of Public Davis, Andrew interconnection in the town of Lyme, and the route of the
Service proposed 115 kV transmission line from the Cape Vincent
substation to the Lyme substation.
The analysis of project visibility from historic resources
State of New York
should be coordinated with the project visual assessment,
since the tall wind turbines, substations, and overhead will be
Service
prominent visual intrusions into the project area.
Supplemental surveys should include all component
State of New York resources and landscapes within listed, eligible or potentially
4 37 Department of Public Davis, Andrew eligible historic properties or districts, as appropriate, to
Service demonstrate the extent of impacts of the project on those
resources.
Phase 1A and 1B reports should be provided to involved
State of New York
agencies when available, for review and comment. Posting
reports on the project website should not be relied on for
Service
purposes of service on involved agencies.
4 39 State of New York Davis, Andrew The APE should include the viewshed of the proposed
3-18
003671
Table 3-1
Department of Public overhead transmission line and substation facilities.
Service
Section 3.8 and Appendix C. The discussion of Visual
Resources and Community Character does not adequately
address the scale and scope of potential project impacts on
State of New York
the project area, the affected local community, or several
resources of regional or statewide significance. Additional
Service
studies are appropriate to more fully address the potential
project visibility and visual impact on important resource
locations
Section 3.8 and Appendix C. Cumulative assessment of the
project on the Seaway Trail Scenic Byway should be
developed, by a sequential representation of several
viewpoints with direct views toward the project area, as
would be experienced by touring visitors traveling along the
Route 12E corridor. The VIA does include representations
from 3 or 4 locations along the Scenic Byway, but the
State of New York presentation does not provide an orientation to the various
4 41 Department of Public Davis, Andrew points, and does not provide consideration of the various
Service cultural, historic, recreational, and scenic resources which
cumulatively comprise the setting and experience of traveling
along the Seaway Trail. The analysis of impacts should
consider corridor management principles and guidelines for
the Seaway Trail, and provide additional consideration to
minimizing the project impacts due to the close proximity of
many of the proposed turbines to this scenic resource of
statewide significance.
Section 3.8 and Appendix C. The DEIS does not address in
State of New York
a comprehensive manner the relation of the Seaway Trail
Scenic Byway to the landscape and the various resources
Service
which contribute to the corridor adjacent to the Trail.
State of New York Section 3.8 and Appendix C. The VIA does not address in a
4 43 Department of Public Davis, Andrew meaningful way the potential project visibility from the
Service designated Coastal Zone areas, such as from within the St.
3-19
003672
Table 3-1
Lawrence River, or from Lake Ontario. Additional
simulations should be presented which represent project
view simulations from both middle-ground and fore-ground
distances from the Coastal Zone water surface, representing
views across locations with both developed and undeveloped
shorelines, to represent the nature of views experienced by
recreational boaters. Demonstration of the consistency of
the proposed project with relevant Coastal Zone Policies for
scenic and visual resources should be provided in a SDEIS.
Section 3.8 and Appendix C. Wider field of view simulations
should be used; viewpoints represented in the VIA are
limited to less than what is experienced at many locations in
State of New York the project landscape. Additional viewpoint and simulation
4 44 Department of Public Davis, Andrew views should be created from locations such as the vicinity of
Service the Thousand Islands High School oriented southerly from
County Route 9. The current photograph is taken from a
topographically inferior position, which limits views of
background distance zone turbine positions.
The discussion of project impact mitigation should consider
project alternative layout and project arrangement, which
State of New York would remove turbines from the most prominent locations
4 45 Department of Public Davis, Andrew near the Coastal Zone areas, the Seaway Trail Scenic
Service Byway, Historic Properties listed or eligible for listing on the
State or National Register of Historic Places, and other
resources of scenic and aesthetic importance to the State.
Section 3.13. The document should include discussion and
details of security measures including limitations on access
State of New York to electrical equipment and substations, including
4 46 Department of Public Davis, Andrew specifications for station fencing and access gates; any
Service proposed security lighting at substation locations measures
to mark underground facility locations and participate in the
Dig Safely New York facilities protection system.
State of New York Section 4.0. The discussion of Cumulative and Growth
4 47 Davis, Andrew
Department of Public Inducing Impacts should address the proposed Wolfe Island
3-20
003673
Table 3-1
Service Wind Project. Additional information, including the
Environmental Overview Report and additional details should
be reviewed and assessed in a cumulative impact
assessment, especially addressing visual resources and
potential for "visual saturation" of the regional coastal
landscape, and cumulative effects on significant habitats,
migratory wildlife and rare, threatened or endangered
species populations.
Cumulative assessment of the combined impacts of the St.
State of New York Lawrence Windpower and the BP Alternatives project should
4 48 Department of Public Davis, Andrew be addressed. Visual impacts, wildlife habitat effects,
Service construction impacts, traffic impacts, and historic resource
impacts should be addressed in a meaningful way.
The range of Coastal Zone resources should be carefully
considered in identifying cumulative project impacts.
State of New York
Coordinated planning for electrical output and
interconnecting facilities should be required to avoid multiple
Service
or duplicative facilities, and repeated construction impacts of
multiple transmission and substation facilities.
Section 7.0. The Alternatives analysis should be significantly
expanded to address project alternatives, including
State of New York
alternative electrical interconnection facilities, alternative
project arrangement and increased separation and setback
Service
from the broad range of significant resources within the study
area.
Section 7.0 The alternatives analysis should address routing
alternatives for the 115 kV transmission line, including facility
State of New York routes within or adjacent to the abandoned railroad ROW;
4 51 Department of Public Davis, Andrew and alternative designs including underground placement of
Service the 115 kV line especially near sensitive resources such as
Wildlife Management Areas, the Chaumont River, and
locations within view of the Seaway Trail Scenic Byway.
State of New York The Alternatives Analysis and the DEIS in general should
4 52 Davis, Andrew
Department of Public convey the essential nature of the project area as containing
3-21
003674
Table 3-1
Service a concentration of inter-related natural and cultural resources
which should be considered cumulatively, rather than
singularly by topic heading.
The Alternatives Analysis should be expanded to present
State of New York detailed assessments and mitigation opportunities resulting
4 53 Department of Public Davis, Andrew from a project design and layout, which increases setback
Service distances from the multiple sensitive resources in and
surrounding the project layout.
The developer should be required to give serious
consideration to a range of alternative facility arrangements
to enable the advancing of a project design that is
State of New York responsive to the many significant resources of State interest
4 54 Department of Public Davis, Andrew in the project area. This should address a reduced project
Service footprint; increased setbacks from shoreline areas, the
Seaway Trail, visual and cultural resources, Significant
Coastal Fish and Wildlife Habitats, WMA and Important Bird
Areas; and remove facilities from NRHP listed properties.
DEC recommends that mitigation measures be discussed,
including plans to provide for adequate control of stormwater
runoff near any identified karst features. The SDEIS should
describe procedures for conducting detailed subsurface
5 1 NYSDEC Nasca, Jack investigations at turbine site locations. The range of actions
to be taken if karst features are identified should be
specified, including further investigation, turbine re-location,
determination of the effects of blasting, or engineering
construction controls.
DEC recommends that a detailed construction plan be
developed to incorporate stringent containment of
5 2 NYSDEC Nasca, Jack construction-related runoff (e.g., installation of silt/stormwater
fencing to prevent surface runoff from entering uncontrolled
into karst inlets, etc...)
DEC recommends that the SDEIS discuss the role of an
5 3 NYSDEC Nasca, Jack environmental monitor, qualified to work in a karst
environment, related to pre-construction surveys and
3-22
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Table 3-1
construction activities that involve excavation to bedrock or
are located in proximity to an identified karst feature.
Figure 3 should be updated to include both the spring and
6 1 NYSDEC Gary, Brianna
fall radar sampling points
The dates on which no sampling occurred should be
included in the text, along with the reason.
Flight direction, movements, as well as distance of each bird
from the observer should be provided on a map and
table/graph for all birds, including those seen outside of an
800 meter radius from the observation point.
6 4 NYSDEC Gary, Brianna Headings for Table 1 seem to be missing or misaligned.
Information in Table 2 should be broken down by season
(spring 2006, 2007, and fall 2006). Combining the
6 5 NYSDEC Gary, Brianna percentages of birds flying within and below the rotor swept
area among all seasons could mask times of the year when
birds may be at greater risk.
The overall raptor passage rate at the St. Lawrence site is
generally lower than established hawk watches in New York,
particularly in the spring. However, when comparing this
proposed wind development site to others in the state, the
6 6 NYSDEC Gary, Brianna number of birds per observer hours reported is the highest of
15 spring reports and the second highest of 18 fall reports. It
should also be noted that despite these greater passage
rates, the raptor migration surveys at this project were
conducted with fewer hours of effort than at many other sites.
Based on a comparison of multiple reports from across the
state, the potential for raptor-turbine collisions at the
proposed St. Lawrence wind project may be higher than at
6 7 NYSDEC Gary, Brianna other proposed wind projects in New York. A post-
construction mortality monitoring plan will help determine
impacts to raptors and mitigation measures appropriate to
the level of impact.
No BBS points were located in the southern portion of the
project area where approximately 20 of the 96 turbines are
3-23
003676
Table 3-1
proposed.
Survey points also appear to be lacking in the northern
portion of the project area near some larger patches of
forest, and 13 proposed turbines. Conducting surveys in
these areas would provide a baseline estimate of what
forest-dependant species may be using the project area prior
to construction. A post-construction BBS would then provide
information on whether fragmentation has a negative effect
on breeding forest birds.
Surveys were conducted slightly later in the year than is
typical for BBS, and may have missed or had lower numbers
6 10 NYSDEC Gary, Brianna of some species that would have been more readily detected
during the peak of breeding season (e.g., Henslowe’s
sparrows, upland sandpipers, and short-eared owls)
The sponsor should keep in mind that the proposed project
area lies entirely within the FWS St. Lawrence Wetland
Management District Focus Area of the St. Lawrence Valley
Wetland and Grassland Management District. The NYS
6 11 NYSDEC Gary, Brianna Grassland Bird Landowner Incentive Program has also
received a number of applications from western Jefferson
County. The presence of these programs in the same area
as the project emphasizes the importance of grassland and
wetland habitat in the region.
The dates that each driving and static survey took place, the
times surveys were actually conducted, the weather
conditions during the surveys, and the number and species
of birds seen at each observation point and along driving
6 12 NYSDEC Gary, Brianna routes should be included in the report. Two state-
threatened bald eagles, 36 state-threatened northern
harriers, and 120 rough-legged hawks are reported, but it
cannot be determined from the tables provided when, where
or under what conditions these birds were seen.
Although no state-endangered short-eared owls were
observed by West, Inc. during the nine days of survey
3-24
003677
Table 3-1
between November 5, 2006 and March 1, 2007, this species
is known to winter in the area of the proposed project in fairly
large numbers. Surveys conducted on 57 days between July
13, 2006 and March 31, 2007 found 69 owls at 5 roost sites
on 9 survey days between November and March within and
around the project area. DEC staff has also captured and
radio tagged 2 individual owls during winter 2006-2007 and
tracked their movements around the Cape Vincent area.
For the Indiana bat habitat surveys, raptor migration surveys
focusing on golden eagles, and wintering raptor surveys
targeting short-eared owls, rough-legged hawks, northern
harriers, and eagles: a scope of each work plan should be
6 14 NYSDEC Gary, Brianna submitted for review, and consultation should be made with
DEC and USFWS prior to the start of these surveys, or as
soon as possible if fall studies have already commenced, to
determine appropriate methods, duration, and intensity of
survey effort for fall and winter 2007-2008.
A revised report containing the requested information that is
lacking in the current report should be submitted to the DEC
and USFWS as soon as possible. A work plan for monitoring
post-construction mortality and displacement should be
developed prior to the construction of any turbines, and will
be a condition of any permit issued by DEC.
Township of Cape Comments regarding the importance of setbacks and safety
7 1 Carr, Paul, Ph.D., P.E.
Vincent Engineer as it relates to ice throw
Concern over placement of the overhead transmission line.
What is the immediate vulnerability to the waterline and the
Township of Cape
7 2 Carr, Paul, Ph.D., P.E. impact on long-term maintenance if the OH was to be put in
Vincent Engineer
proximity to the Development Authority of the North Country
Right-of-Way for the waterline, the old RR bed?
If the transmission line is to follow the RR bed, what
Township of Cape
7 3 Carr, Paul, Ph.D., P.E. environmental issues arise as it passes through the Ashland
Vincent Engineer
Game Management area?
7 4 Township of Cape Carr, Paul, Ph.D., P.E. Have the Villages of Chaumont, Dexter, Brownville, and Glen
3-25
003678
Table 3-1
Vincent Engineer Park agreed to have a 115 KV or possibly a 345 KV
overhead power line straddling their single source for a vital
community service?
As the line approaches the Village of Chaumont, has there
Township of Cape been a proper notification of those effected residents?
Vincent Engineer Comment expresses concern about the opportunity for
residents to comment on OH route.
Photos in the Visual Impact Study are misleading and
Township of Cape
7 6 Carr, Paul, Ph.D., P.E. visually inaccurate representations of post-project conditions
Vincent Engineer
because of perspective.
Sound level analysis is inadequate and potentially
misleading. The ambient sound level in the community is not
45 dBA as used in the analysis, but closer to 30 as
Township of Cape measured by the commenter. If one were to use 45 dBA as
Vincent Engineer the ambient noise and allow a "non-interfering" increase of
5dBA from the Project, the noise increase would actually be
"objectionable" bordering on "intolerable" according to DEC
policy.
Concern for high visibility of the OH lines; disruption of the
Ashland Flats Wildlife Management Area; and devaluation of
8 1 Harris, Michael
land values for properties which will be visually impacted by
the project.
The Stone Building Appreciation Society supports the intent
in the Cape Vincent Zoning Law to protect historic properties
Stone Building
9 1 Uhlig, Robert and locations while allowing development and agrees with
Appreciation Society
the letter by D. Timothy J. Abel of the Jefferson County
Historical Society on this subject matter.
The nocturnal radar study was only available for public
10 1 Old Bird, Inc. Evans, William R. review 2 weeks before the public comment period on the
DEIS was over. The comment period should be extended.
The project turbines are proposed to be up to 425 feet high
but bird migration information is only provided for heights
10 2 Old Bird, Inc. Evans, William R.
under 410 ft above ground level. Bird/bat migration altitude
information should be provided at 25-m resolution up to 200
3-26
003679
Table 3-1
m above ground level.
Nightly data on passage rate below turbine height is not
presented. Providing a seasonal average for targets below
125 m is not helpful for assessing flying animal impact. Were
observations concentrated in certain months when the main
bat migration was occurring? Data should be presented in
tabular format with actual figures. West Inc. should follow
the format of Woodlot Alternatives in presenting their radar
data.
The Project would be located 800 m from the St. Lawrence
River and the radar study site was apparently only about 500
m from the shoreline, outside the wind project area. The
radar site would ideally be located 1500 m from the
shoreline, as previously stated by the consultant. Placement
of the radar unit 1 km closer leads to the fact that about one
third of the radar detection area was located over the St.
Lawrence River and less than half of their radar coverage
was over the proposed wind project site (based on West's
method of determining passage rate in the horizontal mode)
Comparing horizontal radar data from the West radar study
to those of other New York radar studies is problematic b/c
no radar studies in inland NYS includes such a large over-
water proportion in their sampling region. Based on his own
10 5 Old Bird, Inc. Evans, William R. research, there is a strong likelihood that more small
songbird migration in the fall occurs inland along the St.
Lawrence River than over the water. This would especially
be true on evenings when winds are below 10 mph or if
winds were from the east.
West's data suggests that the St. Lawrence plays a role in
channeling nocturnal migration but their analysis does not
10 6 Old Bird, Inc. Evans, William R. provide information on the details of this channeling. Is it
occurring across the whole St. Lawrence Valley? Only at low
altitudes?
10 7 Old Bird, Inc. Evans, William R. Radar data from over the St. Lawrence River, its shoreline,
3-27
003680
Table 3-1
and inland areas of coverage are summed together to
produce a single passage rate for the whole radar survey
area. Thus, the question of migration corridor along the
south shore of the St. Lawrence is not addressed as was
suggested it would be in the Study Plan.
It would be useful to a 500 m representation of flying target
density as one moves away from the St. Lawrence River up
to 2.0 km from the River. Also, how do these migration
density dynamics vary with weather?
Concurrent use of image intensifier methodology can be
10 9 Old Bird, Inc. Evans, William R. used to help understand the proportion of bats and birds in
the flying animal mix revealed by the radar.
11 1 LeTendre, Gerard Multiple concerns regarding birds
11 2 LeTendre, Gerard Multiple concerns regarding bats
11 3 LeTendre, Gerard Concern regarding the exact numbers and sizes of turbines
Threatened and endangered species such as Blanding's
11 4 LeTendre, Gerard
turtle should be identified, quantified, and protected.
Wetland studies have not been presented; wetlands should
be avoided during and after construction.
Towers and blades should be painted to not attract birds and
bats
Sellers should be compensated for declining property values
associated with the St. Lawrence Wind Farm
Multiple concerns regarding placement of turbines in
11 8 LeTendre, Gerard proximity to Cape Vincent and in proximity to non-
participating landowners
11 9 LeTendre, Gerard All transmission lines should be underground
11 9 LeTendre, Gerard Concern for sound levels
Request for mitigation measures in the event that
12 1 Falcon, Mary construction problems are encountered when blasting and
agricultural runoff enters local wells and streams.
Bird and bat studies are incomplete and should be extended
12 2 Falcon, Mary
for at least the same number of years as the wind studies.
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003681
Table 3-1
Clarification needed on what a bat fatality monitoring
12 3 Falcon, Mary
program will involve
Multiple concerns regarding comment periods for
12 4 Falcon, Mary
supplemental reports
It is believed that the old railway outside the Village of Cape
Vincent traverses an Indian burial ground. Has approval
12 5 Falcon, Mary
been sought from the Native American Tribes to dig in this
area?
12 6 Falcon, Mary All transmission lines should be underground
12 7 Falcon, Mary Will the Project augment local electricity supply?
Visual Impact photos should include photo simulations from
12 8 Falcon, Mary
the St. Lawrence River.
The Project will be visible from Wolfe Island as well as from
12 9 Falcon, Mary the Lake and River. Have residents of Wolfe Island been
contacted?
The alternatives analysis is misleading. All alternatives have
12 10 Falcon, Mary
not been explored.
12 11 Falcon, Mary Flicker supplemental is based on erroneous data
Concerns about the effects of noise on health. Further
13 1 Falcon, Spencer, MD studies on noise should be performed and short and long-
term health effect studies should be conducted
14 1 Chase, Hester Will forests be protected from being clear-cut?
USDA soil maps show Cape Vincent as very low construction
14 2 Chase, Hester
possibility. Why will turbine towers be different?
Question about compatibility of Project and Town's
14 3 Chase, Hester
Comprehensive Plan.
Does the DEC intend to change laws or guidelines to make it
14 4 Chase, Hester
possible for the towers to be built?
Question about impacts to bridges, buildings, roads, Indian
14 5 Chase, Hester
sites, rock walls, and historic places.
14 6 Chase, Hester Question about ice throw, setbacks, and Highway Dept. input
Questions regarding noise, noise studies and mitigation for
14 7 Chase, Hester
noise
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Table 3-1
14 8 Chase, Hester Concern regarding profits to participating wind companies
14 9 Chase, Hester Question regarding efficiency of turbines and alternatives
14 10 Chase, Hester Concerns about diligence of bird / bat studies
14 11 Chase, Hester Concern about the identification of Indiana Bats
14 12 Chase, Hester Source of concrete and gravel for roads
14 13 Chase, Hester Question regarding worker crew lodging
Concern about effect of Project on Important Bird Habitat on
14 14 Chase, Hester
Pleasant Valley Road.
Concern about landowner rights (Refers to BP Cape Vincent
14 15 Chase, Hester
Wind Power Project)
14 16 Chase, Hester Concern about shadow flicker on health
14 17 Chase, Hester Questions regarding decommissioning
Gaudette, Richard and Letter opposed to wind farm citing safety, visual impacts, and
15 1
Jan environmental impacts
Petras, Leigh and Request to move transmission lines through Chaumont
16 1
James several miles to the north to avoid visual impact
Concerns regarding shortcomings of DEIS and proposed
17 1 Dziekan, Andrew
mitigation measures
Copy of letter submitted to the NYS Historic Preservation
Office regarding potential effects of Project on historic
18 1 Bragdon, Brooks
preservation properties and the Historic District; copy of
response from the NYS Historic Preservation Office.
Save the River and
Caddick, Jennifer and A thorough review of the collective impacts of wind
19 1 1000 Islands Land
Aaron Vogel development projects in the region should be performed
Trust
Save the River and
Caddick, Jennifer and
19 2 1000 Islands Land Comment on importance of pre-construction studies
Aaron Vogel
Trust
Concern that the SEQR process has not been followed to its
Save the River and fullest extent. DEIS fails to show what the significant
19 3 1000 Islands Land adverse environmental impacts might be and does not
Aaron Vogel
Trust contain information necessary to evaluate project
alternatives
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003683
Table 3-1
Save the River and
Caddick, Jennifer and Comment on importance of agency involvement in decision
Aaron Vogel making processes.
Trust
Save the River and
19 5 1000 Islands Land The DEIS must include studies of at least 3 years in duration
Aaron Vogel
Trust
Save the River and
19 6 1000 Islands Land The DEIS does not address wetland impacts
Aaron Vogel
Trust
Save the River and Post-construction impacts of storm water run off from new
19 7 1000 Islands Land roads and other turbine maintenance facilities must be
Aaron Vogel
Trust examined.
Save the River and
19 8 1000 Islands Land A cost-benefit analysis of the project must be considered
Aaron Vogel
Trust
20 1 Merchant, Jerry Letter opposing wind farm
Avian and Bat Study Plan is only a protocol for undertaking a
Menter, Rudin and one year avian and bat impact study in the future; a 3-year
21 1 Fucillo, Thomas J.
Trivelpiece, P.C. preconstruction study should be conducted; other
comments/concerns
Menter, Rudin and Wetlands have not been delineated; impacts to wetlands
Trivelpiece, P.C. have not been assessed
Menter, Rudin and A geotechnical investigation and SWPPP should be part of
Trivelpiece, P.C. the DEIS
A transportation and traffic plan should be created as an
appendix of the DEIS to address the traffic-related impacts to
Menter, Rudin and
21 4 Fucillo, Thomas J. the Town of Cape Vincent resulting from the array of heavy
Trivelpiece, P.C.
vehicles that will deliver turbine components to the Project
site.
A sediment and erosion control plan and a Project
Menter, Rudin and Stormwater Pollution Prevention Plan should be developed
Trivelpiece, P.C. to ensure that impacts associated with construction area
properly mitigated.
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SLW should be directed by the Planning Board to utilize the
Menter, Rudin and Ranking Protocol (USFWS guidelines - enclosed) to
Trivelpiece, P.C. determine whether the proposed site is appropriate for
development of a wind energy facility.
Cumulative impacts of SLW and proposed wind projects in
Menter, Rudin and
21 7 Fucillo, Thomas J. close proximity should be addressed: community character,
Trivelpiece, P.C.
wildlife, connection to the existing power grid.
Menter, Rudin and
21 8 Fucillo, Thomas J. Comments/concerns about the Sound Level Report
Trivelpiece, P.C.
Menter, Rudin and
21 9 Fucillo, Thomas J. Comments/concerns about the Visual Resource Survey
Trivelpiece, P.C.
Menter, Rudin and The DEIS does not identify any mechanism to avoid or
Trivelpiece, P.C. mitigate for shadow flicker.
Menter, Rudin and The DEIS fails to properly assess the environmental impacts
Trivelpiece, P.C. of constructing the substation and power lines.
The DEIS should be modified to determine what portions of
Menter, Rudin and the electrical interconnection line will be aboveground, what
Trivelpiece, P.C. portions will be belowground, and assess the impacts of
such aboveground installation.
Financial assurances should be secured to fund the
Menter, Rudin and decommissioning of the Project in the event that the
Trivelpiece, P.C. Applicant is no longer financially viable or refuses to properly
remove the facilities.
Menter, Rudin and Enclosure: USFWS Service Interim Guidance on Avoiding
Trivelpiece, P.C. and Minimizing Wildlife Impacts from Wind Turbines
The DEIS does not adequately reference the Town's
Menter, Rudin and
22 1 Fucillo, Thomas J. Comprehensive Plan, or the fact that this Project appears to
Trivelpiece, P.C.
directly conflict it.
The DEIS should contain a meaningful discussion of
Menter, Rudin and
22 2 Fucillo, Thomas J. alternatives, not just the conclusory assertions that it
Trivelpiece, P.C.
presently contains.
23 1 Faulknham, R. Dennis The DEIS did not include a Shadow Impact Assessment
23 2 Faulknham, R. Dennis Large segment of the Project will be highly visible from many
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Table 3-1
parts of Cape Vincent. Request for one mile setbacks to
reduce visual impacts.
Given the scale of the Project, it is likely that visual impacts
23 3 Faulknham, R. Dennis
may extend far beyond the 5-mile APE
The DEIS does not discuss how long following completion of
site restoration the contractor will stay to evaluate areas
24 1 Faulknham, R. Dennis disturbed during construction and assure that agricultural
and wetland functions and values are restored and
maintained over the long term.
Public road improvement wetland study must be included in
the EIS
Wetlands analysis in DEIS should be refined to apply full
range of potential impact criteria to proposed construction
24 3 Faulknham, R. Dennis activity in determination of total area of permanent impact;
not just those areas proposed for permanent placement of
fill.
Ambient decibel levels used in the DEIS are higher than
25 1 Jury, Charles
observed
26 1 Vail, Alan Question about the "no action" alternative
Question about impact of Project on town and village
26 2 Vail, Alan
budgets
Comment on financial assurances for payment, performance
and maintenance bonding. If the project is not bonded,
26 3 Vail, Alan neither the towns nor the leaseholders have a guarantee that
promise will be kept, construction, completed, payments
made, maintenance done, and dismantling completed.
Most DEISs include results of a Job and Economic
Development Impact Model. None was referenced in DEIS
26 4 Vail, Alan
so it appears that the Socioeconomic Section was based on
Assumptions
Comment on direct financial benefit for town/village power
26 5 Vail, Alan
users
26 6 Vail, Alan The Decommissioning Plan needs to be completed
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Table 3-1
26 7 Vail, Alan Comment on the alternative of downsizing the Project
Concern for residents' needs and wants conflicting with
27 1 Gormel, Thomas
Project
Multiple concerns regarding existing and new roads and road
28 1 Gormel, Thomas
maintenance
29 1 Gormel, Thomas Multiple questions regarding bird and bat studies
30 1 Gormel, Thomas Concern regarding setbacks
Concerns regarding mitigation of views from historic
31 1 Gormel, Thomas
properties
Concerns about the overall cost of the Project and how that
32 1 Gormel, Thomas
will affect town and village budgets
Multiple questions regarding archeological studies and Indian
33 1 Gormel, Joyce
burial grounds.
Questions regarding impact of Project on herons and other
34 1 Gormel, Joyce
recreationally viewed avian species
Multiple concerns regarding effect of Project on community
35 1 Gormel, Joyce
tax base and income
Multiple questions regarding effect of Project on fishing and
revenues from fishing: recreational fishing important part of
the allure of the town and fisherman support local
businesses. Who compensates local businesses if wind farm
36 1 Gormel, Joyce development results in a loss of revenue? Construction
would occur during fishing season and could represent an
access conflict. How will change in revue be measured if
fisherman and recreation boaters go elsewhere after the
towers are constructed?
Questions regarding road maintenance and cost of road
37 1 Gormel, Joyce
maintenance
38 1 Zovistoski, Mary
maintenance
38 2 Zovistoski, Mary Concern for safety of children
Question regarding MOA developed if the Project design
affects NRHP-eligible sites
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Table 3-1
38 4 Zovistoski, Mary The assumptions used to complete the DEIS are not listed
Comments requesting more detail on layout of substation,
O&M facility, and construction staging area.
Comment regarding representation of the Project's area of
38 6 Zovistoski, Mary impact as an alternative to GIS maps, line of sight cross
sections, and photo simulations.
38 7 Zovistoski, Mary Multiple comments regarding alternatives
38 8 Zovistoski, Mary Comment regarding decommissioning
38 9 Zovistoski, Mary Mitigation strategies pertaining to visual impacts are limited
Concerns that the maximum power generation of the wind
farm will come close to the transmission line capacity, and
39 1 Hirschey, Urban C.
about the impact that this will have on future power
requirements for the area.
When will the estimate of the cost of decommissioning be
presented to the Town Board for approval?
The DEIS states that in agricultural areas, electrical cables
39 3 Hirschey, Urban C. will be buried at a possible depth of 48 inches; however, the
NYSDAM states a minimum burial depth of 48 inches.
What are the "other" subcomponents of the wind farm not
listed in the Executive Summary?
Concern for effect of Project on Fort Drum soldiers and
families. Projected increase in rental costs, based on a
surge in construction workers and the Fort Drum buildup will
place soldiers and their families at a financial disadvantage.
40 4 Hirschey, Urban C. Concern for safety of children
Comments regarding layout of substation, O&M facility, and
construction staging area
A real-time, 3-D computerized simulation of the project's area
of impact should be prepared to assess visual impacts
instead of GIS maps, line of sight cross sections, and photo
simulations.
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Table 3-1
40 7 Hirschey, Urban C. Multiple comments regarding alternatives
40 8 Hirschey, Urban C. Comment regarding decommissioning
40 9 Hirschey, Urban C. Mitigation strategies pertaining to visual impacts are limited
Comment regarding necessity of environmental monitor in
areas where karst features may occur
The DEIS needs to state that the maximum megawatt
capacity of this project is 136 megawatts, and that if turbines
larger than 1.5 megawatts are used, the number of turbines
will be reduced accordingly.
Photos in the Visual Impact Study are misleading because of
41 2 Hirschey, Urban C. turbine positioning and inaccurate representations of turbine
size
The viewshed analysis range should be enlarged to 10 miles
since land is relatively flat and there are many clear days
No field surveys regarding migratory birds, bats, and other
species were included in the DEIS. No information regarding
the location of flight corridors was depicted on the study
maps.
Section 3.4.3 should include an appropriate strategy for road
restoration
Section 3.5.1.2 and 3.5.1.5 should discuss the
43 3 Hirschey, Urban C. Comprehensive Plan adopted by the town and how the
project will fit into the goals set forth in the plan.
In evaluating if turbines prevent future development, Section
3.5.2.3 should discuss examples of future residential
development within 5 miles of turbines in comparison to
similar areas where they were not constructed.
Page 3-50 should include turbine accidents statistics along
43 5 Hirschey, Urban C. with the required emergency services used to respond.
Towns should be reimbursed for these services.
Page 3-62 should include performance of a balloon study on
a calm day
43 7 Hirschey, Urban C. Multiple comments regarding ambient noise and noise
3-36
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Table 3-1
increases due to turbines
Section 3.11.1.1 should discuss the effect of the project on
43 8 Hirschey, Urban C. property values in this area of high scenic value and tourism
potential.
Receptors of shadow flicker should be notified and
compensated
Section 6.0 should discuss the predicted effective capacity of
the project compared to the nameplate capacity.
Comments regarding declining property values as a result of
wind projects. Enclosure not attached.
Questions regarding medical issues, safety issues, and a fire
45 1 Boss, Mark
prevention and control plan
45 2 Boss, Mark Questions regarding road modifications and layout
45 3 Boss, Mark
45 4 Boss, Mark
Bracket, Mr. and Mrs. Letter expressing concern that EIS and other studies may be
46 1
Montgomery biased
Audubon New York requests that the DEIS perform
47 1 Audubon New York Liner, Jillian M. adequate pre-construction surveys to determine bird usage
and assess potential risk.
Comments regarding importance of historic properties and
suggestions for setbacks
48 2 Bragdon, Brooks Enclosure: Correspondence from NYS OPRHP
Enclosure: Letter to Editor from Brooks Bragdon regarding
49 1 Bragdon, Brooks turbine setbacks. Enclosure of SLW visual simulation not
attached.
Gregory, Maureen
50 1 Multiple comments regarding historic properties
Wiley
50 2 Gregory, Maureen Multiple questions regarding planting trees as mitigation for
3-37
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Table 3-1
Wiley visual impact
Gregory, Maureen
51 1 Multiple questions about archeological studies.
Wiley
Multiple questions about financial benefits and effect of
Project on Town and Village budgets (What is overall
estimated cost of project? What is estimated cost per
Gregory, Maureen
52 1 kilowatt/hour for first year, first five years, first ten years?
Wiley
How will residents other than lease-holders benefit? How will
the town’s budget be affected in one year, five years, ten
years?)
Gregory, Maureen Questions regarding impact of Project on herons and other
53 1
Wiley recreationally viewed avian species
Gregory, Maureen Multiple concerns regarding existing and new roads and road
54 1
Wiley maintenance
Gregory, Maureen Questions regarding road maintenance and cost of road
55 1
Wiley maintenance
Gregory, Maureen
56 1 Multiple questions regarding bird and bat studies
Wiley
Gregory, Maureen Multiple questions regarding effect of Project on fishing and
57 1
Wiley revenues from fishing
Gregory, Maureen Concern for residents' needs and wants conflicting with
58 1
Wiley Project
Gregory, Maureen Multiple concerns regarding effect of Project on community
59 1
Wiley tax base and income
Multiple comments and recommendations regarding
60 1 Doull, Melodee
representation and mitigation of viewshed
Comments and concerns about underlying geologic material
61 1 Macura, Daniel
and resulting impacts
Comments and concerns about effect of Project on
61 2 Macura, Daniel
groundwater
Moehs, Charles, MD, Concerns about "wind power syndrome" and
62 1
MPH recommendations on how to avoid this
63 1 Duehkind, Winnie Is it possible to set up some sort of screen to project birds
3-38
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Table 3-1
and bats?
64 1 Walker, Tom and Mabel Concern about adequacy of studies for wildlife
Comment on assessment of land as industrial as opposed to
64 2 Walker, Tom and Mabel
agricultural
The DEIS fails to evaluate impacts on Federal and State
65 1 Brown, Thomas listed threatened and endangered species, including the
Indiana Bat, the Short Eared Owl, and the Black Tern.
The DEIS should include an assessment to determine if
65 2 Brown, Thomas ozone levels would increase due to the collective effect of
the multiple proposed wind farms in this general area
Concern about declining property values and suggestion of
66 1 Hludzenski, Kathryn A.
property stabilization program
Section 3.13.1.2 on possibility of ice shed is misleading
because of selective quoting
Crossby, William and
68 1 Comment on the importance of performing thorough studies
Barbara
Jefferson County Comments on the importance of reviewing all historical
69 1 Historical Society, Abel, Timothy J., PhD resource inventory and assessment research prior to making
Watertown, NY a final decision on the Project.
70 1 LaPlante, J.O Urging of pre-construction bird and wildlife studies
Article: Watertown Enclosure: Article: "Study says wind power fatal to birds and
70 2
Daily Times bats" from the Watertown Daily Times 5/31/2007
Article: Los Angeles Enclosure: Article: "Wind power planning called for" from the
70 3
Times Los Angeles Times
Article: Watertown Daily Enclosure: Article: "Blades a draw for bats, birds" from the
70 4
Times Times Washington
Article: Source Enclosure: Article: "Wind farms, Study sees need for more
70 5
Unknown guidance"
Concern regarding public input and the addressing of
71 1 Hanson, Rollin V
comments
Multiple comments regarding historic sites, viewshed
analysis, and mitigation for visual impacts
72 1 Hludzenski, Kathryn A. Question regarding turbine stability in underlying geologic
3-39
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Table 3-1
substrate
73 1 Freislich, Michele L. Concerns about health effects from Project
Letter expressing concern about town relationships and
74 1 Simpson, Carol
asking Town Planning Board to slow down decision-making
Section 2.2 What is the third alternative procedural pathway
75 1 Gormel, Joyce
available to the Lead Agency?
Number of miles of gravel access roads is inconsistent
75 2 Gormel, Joyce
(Section 2.6.3 states 44 miles)
Section 3.12.1.1 and 3.13.1.1 are both titled "Microwave
75 3 Gormel, Joyce Analysis". Which section needs to address this topic and
what is missing from the other section?
75 4 Gormel, Joyce Section 3.13.2.4 Multiple questions regarding fire hazards
Section 1.6 and 2-9 contain the same table titled "Permits
75 5 Gormel, Joyce and Approvals for the St. Lawrence Wind Energy Project"
with different verbiage. Which is correct?
Request for more detailed information on PILOT payment
75 6 Gormel, Joyce
intentions
75 7 Gormel, Joyce Request for more detailed information on decommissioning
Request for more detailed information on bird and bat
75 8 Gormel, Joyce
studies
Multiple comments and recommendations regarding safety
76 1 Pundt, Art plans, emergency services training, and additional potential
hazards
The DEIS lacks detail on decommissioning and should be
77 1 Gormel, Thomas
modified to reflect a more formal plan
Concerns with DEIS claim that only a portion of the study
78 1 Levy, Ann E. area will have visibility of wind turbines within the five mile
radius
78 2 Levy, Ann E. Concerns with effectiveness of mitigation for visual impact
There is no mention of the Dodge Bay Cemetery in the
79 1 Boss, Sarah F. Historical Architecture Resource Investigation section of the
DEIS
79 2 Boss, Sarah F. As the zoning law does not permit structures more than 35
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Table 3-1
feet high, the wind towers do not qualify in the Township
79 3 Boss, Sarah F. The deadline for public input should be extended
Concern that wind power does not eliminate pollutants and
79 4 Boss, Sarah F.
greenhouse gases during the production of electricity
79 5 Boss, Sarah F. Transmission line locations have not been specified
79 6 Boss, Sarah F. Potential impacts to wetlands have not been provided
Potential impacts to karst topography have not been
79 7 Boss, Sarah F.
provided
Potential impacts to avian and bat species have not been
79 8 Boss, Sarah F.
provided
The model and megawatt of the windmills still need to be
79 9 Boss, Sarah F.
determined
79 10 Boss, Sarah F.
The DEIS needs to specify who will be responsible for road
79 11 Boss, Sarah F. improvements and reconstruction necessitated by
construction vehicles
79 12 Boss, Sarah F. Concern for turbine blades crossing property lines
Urging of an analysis of impacts to property values and the
region's economy
Concern that turbines are located too close to the Thousand
Islands Junior/Senior High School; concern for ice throw
Questions regarding how the Project will affect ducks and
80 1 Brown, Thomas
geese and how these impacts will be assessed
Inquiry as to when supplemental bird and bat studies will be
80 2 Brown, Thomas
available
Pressly & Associates,
81 1 Pressly, Nicholas Wetland impacts were not avoided to the extent practicable
Inc., Cherry Valley, NY
Pressly & Associates, Construction sites should be placed far enough away from
81 2 Pressly, Nicholas
Inc., Cherry Valley, NY potential receptors to reduce effects of storm water runoff
Pressly & Associates, A field survey of existing wetlands and associated biota
Inc., Cherry Valley, NY should be included in the DEIS
81 4 Pressly & Associates, Pressly, Nicholas Potential long-term impacts resulting from increased surface
3-41
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Table 3-1
Inc., Cherry Valley, NY flow due to road construction should be evaluated. This
should include impacts to wildlife resulting from increased
volume, turbidity, and chemicals used for road deicing or
dust suppression.
It is likely that groundwater will be impacted by direct
Pressly & Associates, infiltration of turbid water and dissolved concrete into the
Inc., Cherry Valley, NY bedrock aquifer. Potential impacts to groundwater should be
evaluated in the DEIS.
81 6 Curriculum Vitae Enclosure: CV of Nicholas Pressly
82 1 Cuda, Kenneth Request for removal of Turbine #22
Concerns expressed over proximity of Project to the Cape
Vincent Historic District
The Project does not accommodate the stated purposes of
the Cape Vincent Zoning Law
Cape Vincent Zoning
83 3 Enclosure: Page 1 of the Cape Vincent Zoning Law
Law
Bouchard, Gerry and Will the wind companies be held responsible for correcting
84 1
Michelle any interference with TV and radio reception?
85 1 Cuda, Kenneth Request for greater setbacks from the St. Lawrence River
Letter from Brooks Bragdon to the NY State Dept of Parks
addressing impacts to the St Lawrence River, Historic
District, and NR Listed properties; and requesting increased
setbacks and smaller turbines
Proposal for the formation of a review board to evaluate
Project
Article: Pylon cancer fears put £7bn blight on house prices
88 1 Article: Telegraph (UK)
(5/1/2006)(1st page only)
Article: Leukemia risk 70pc higher for children close to power
lines 6/8/2005)
Internet Article: Daily-
90 1 Article: An ill wind…wind farms as a blight on the landscape
John.com
91 1 Gormel, Joyce Multiple concerns about PILOT payments
92 1 Moehs, Charles, MD, Discussion of Wind Turbine Syndrome and request for
3-42
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Table 3-1
MPH increased setbacks from the Thousand Island Junior/Senior
High School
Concern that the number and placement of turbines will
93 1 Brown, Thomas transform the landscape into an industrial complex. Request
for fewer turbines and greater setbacks from the shore.
Letter to Editor: Letter to Editor: Noisy turbines disrupt sleep, devalue
94 1
Watertown Daily Times property
Multiple questions and comments regarding cumulative
95 1 Gormel, Thomas impacts of wind projects on wildlife, resources, migratory
birds, and transmission of electricity to the national grid.
A website has been created whereby all comments can be
96 1 Levy, Ann E.
aired objectively (www.stlawrencewind.org)
Comment on the term "appropriate" in the Executive
Summary when referring to buffers from property lines
97 1 Gormel, Thomas
nearby residences, roads, and other nearby visually sensitive
areas.
97 2 Gormel, Thomas Mitigation for visual impacts needs to be more specific
The DEIS is incomplete; the public hearing and comment
Wind Power Ethics period should be stayed until sufficient information has been
98 1 Drabicki, Judy, Esq.
Group developed to provide for a legitimate public review and
comment. Enclosure: not attached
99 1 Wiley, Karen Concerns about suffering summer tourism
Concern regarding the potential density of turbines in the
99 2 Wiley, Karen
region
99 3 Wiley, Karen Concern for declining property values
Concern that East End Park will not be as attractive with
99 4 Wiley, Karen
visible wind towers; effect on hunters and snowmobilers
99 5 Wiley, Karen Concern regarding objectivity of studies performed
Does St. Lawrence Wind Power have a good safety record
99 6 Wiley, Karen
regarding the construction and operation of towers.
Urging of town officials to do research regarding the impact
99 7 Wiley, Karen
of noise and light from the towers on residents and wildlife.
100 1 Graf, David General comments.
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Table 3-1
General questions about the size of the Project, visual
101 1 Callery, Judith Anne impacts, tax implications, impacts to avian species, ice
throws, TV reception interference, property values, and noise
Concern for tourism, visual impacts; call for zoning laws
102 1 Kemmis, Richard J. specific to wind turbines and increased setback from the St.
Lawrence River
103 1 Brown, Thomas Objection to the St. Lawrence Wind Farm DEIS
Brown, Thomas; R. Letter to the NYSDEC and USFWS expressing concerns
Dennis Faulknham, regarding the lack of bird and bat studies in the DEIS,
104 1
Gerard LeTendre, and impacts to migrating birds, and calling for 3-year long studies
Clifford Schneider for assessing impacts on bird and bat resources.
Haskins, Janet and
105 1 Concern for ill health effects from Project
James
The NYSDEC's Assessing and Mitigation Noise Impacts
(AMNI, 2001) should not be quoted as a standard; there is
106 1 Schneider, Clifford P.
no current statewide standard to govern and guide wind farm
development in New York State.
Article: Utica Observer Enclosure: Article: Wind Turbines could force family to leave
106 2
Dispatch Fairfield home (Utica Observer Dispatch - March 8, 2007)
Pre- and post-construction photographic simulations are
107 1 Brooks, Colin
deceptive due to perspective.
The only people who stand to benefit from the construction of
107 2 Brooks, Colin wind turbines are those who are leasing their land to the
company
There is a conflict of interest between members of the board
107 3 Brooks, Colin and St. Lawrence Windpower LLC; some individuals have a
financial/personal interest in the development of the Project
Objection to the size, shadow effect, flicker effect and noise
108 1 Bragdon, Brooks of the turbines; call for setbacks to protect the character of
the community. Listed enclosures not attached.
Multiple comments on inadequacy of specific avian studies.
109 1 Smith, Gerald
Please refer to comment letter.
110 1 Docteur, David H. Multiple questions on effect of Project on short and long term
3-44
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Table 3-1
human health
110 2 Docteur, David H. How do sweeping shadows affect fish?
Enclosure: e-mail concerning a press release about Vibro-
110 3 E-mail
Acoustic Disease,
To comply with Cape Vincent's wind turbine noise guideline,
a greater setback distance is needed. A setback of 3,457
feet would recognize the importance of night-time
background levels, include the 5 dBA above background
guideline, and use the same method as AES-Acciona uses
to calculate wind turbine noise spread loss. It would also
give non-participating landowners leverage in negotiating
with AES-Acciona.
Post-operational background noise surveys should be
performed to ensure that AES-Acciona conforms to their own
predictions and that their wind turbines comply with the
Planning Board's noise guideline.
AES-Acciona should be required to shut down wind turbines
111 3 Schneider, Clifford P. when winds at ground level diminish to turbine cut-in speeds
(e.g., 5 m/s)
The Planning and Town Boards should be more concerned
with individual property loss of non-participants than tower
removal costs. Bonding should provide these residents with
protection from property loss.
111 5 Schneider, Clifford P. Forty-one questions regarding sound level report
111 6 Schneider, Clifford P. Eleven questions regarding the flicker assessment
111 7 Schneider, Clifford P. Twenty-four questions regarding avian studies
111 8 Schneider, Clifford P. Twelve questions regarding the Visual Assessment Report
Enclosure: Response letter from Jack Nasca to Clifford
111 9 Letter: NYSDEC.
Schneider regarding comments dated 3/12/2007
The project definition should include an evaluation of the
Bernier, Carr, and
Cape Vincent Planning bedrock geology, as well as in the EIS. The level of detail
112 1 Associates (Dimmick,
Board needs to be commensurate with the stage of environmental
Kris)
review. This analysis should also identify potential impacts
3-45
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Table 3-1
and mitigating measures that will be implemented during the
site and foundation design. Remote sensing might also be
helpful.
The planning board requires that SLW redo the map showing
tower locations to conform to the following criteria: A. No
tower is to be closer than 1,000 feet to a non-participating
property line; B. No tower is to be closer than 1,250 feet to a
Cape Vincent Planning Planning Board
112 2 non-participating residence; C. No tower is to be closer than
Board Members
750 feet to a participating residence; D. No tower is to be
closer than 1,500 feet to the Village of Cape Vincent line.
The new map is to be submitted to the Planning Board and
to all of the locations where the DEIS is located.
SLW will respond to all comments submitted by the N.Y.
State DEC, USFWS, NY Public Service Commission, NY Ag
Cape Vincent Planning Planning Board and Markets, and NW State Historic Preservation Office that
112 3
Board Members have been submitted during the public comment period
ending 6/15/2007. SLW will submit a copy of this
correspondence to the Planning Board.
SLW is to indicate on their new map that location of the
transmission lines inside and outside of the project area.
The map will need to show whether the lines are above
ground or below ground. If below ground, the depths of the
lines will need to be indicated. The map will need to show
line capacity, size of lines, height of lines, material of lines,
and any other pertinent specifics. The map will also have to
Cape Vincent Planning Planning Board show the specifics of any towers and the tower placement.
112 4
Board Members This new map will also have to be submitted to the Planning
Board and to all of the locations where the DEIS is located.
There is to be only one transmission line leaving the wind
turbine project from the Town of Cape Vincent. Therefore,
SLW is to communicate with BP to the effect that both
companies must work together on the transmission line.
SLW is to send this correspondence to BP via certified return
receipt mail. A copy of the SLW letter, certified receipt, and
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Table 3-1
any response by BP are to be submitted to the Planning
Board.
A revised visual impact study will need to be done based on
the new project map. This revised visual impact study is to
include at least 2 locations from the waters of Lake Ontario
inland and 3 locations from the waters of the St. Lawrence
112 5 river inland. There is to be an additional location taken from
Board Members
the water in the vicinity of the Tibbets Point Lighthouse
focusing downriver. Another such location is to be taken
from the Cedar Point State Park area while on the water
looking back toward the Tibbets Point Lighthouse.
Cape Vincent Planning Planning Board Further explanation of the visual study methodology will need
112 6
Board Members to be submitted to substantiate the study.
Background ambient sound levels will need to be done to
accurately measure the entire project and the Village of
Cape Vincent. The background ambient sound
measurements submitted need to be located so as to include
112 7 commercial and pleasure watercraft on the river as well.
Board Members
These background ambient sound levels are to include
measurements taken both during daytime and nighttime
hours. Study methodology will need to be submitted to
substantiate the study.
Cape Vincent Planning Planning Board A revised shadow flicker study map is toe be prepared using
112 8
Board Members the new project map and submitted accordingly.
Cape Vincent Planning Planning Board Wetland delineation studies need to be done and wetland
112 9
Board Members locations shown on the project map.
SLW will need to meet with the Cape Vincent Fire Dept. and
112 10 work out an emergency fire and ambulance response plan.
Board Members
This will need to be submitted accordingly.
Cape Vincent Planning Planning Board A traffic/transportation plan will need to be created and
112 11
Board Members submitted accordingly.
A stormwater pollution prevention plan and soil erosion
112 12 control plan will need to be prepared for the appropriate
Board Members
agency approval as part of the site plan review approval
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Table 3-1
process. All necessary permits will need to be in place prior
to any construction.
Enough distance to avoid shadow flicker affecting people
113 1 Boss, Sally
with migraines.
113 2a Byrne, John Requesting that the night-time lighting be mitigated
Requesting the avoidance of excessive trees and shrubbery
113 2b Byrne, John
removal.
113 3 Docteur, David Minimize shadow flicker, 3,000 setback for noise.
Wind Power Ethics Public comment period after environmental studies are
Group complete?
113 5 Falcon, Mary Contingency plans for water run-off problems from project.
What are the cumulative impacts of all of these projects on
the residents of our community? How will all proposed wind
projects in the area impact migratory birds? How SLW does
113 6 Gormel, Thomas
proposes to mitigate the cumulative impact of all of these
projects on the transmission of electricity to the National
Grid.
113 7 Hambrose, Harold Inaccurate visual analysis of the area.
Questions: is the removal of turbines only to be paid at the
end of their useful life, clear definition of "useful life", who
113 8 Hambrose, Johanna
determines “useful life", removal of underground collection
system, damage to visual beauty of area.
113 9 Hanson, Rollin V Setbacks needed to protect character, history of area.
113 10 Henchy, Harold Do not overlook quality of life.
Concerns about changing recreational area to industrial
113 11 Hirschey, Sally
zone.
113 12a Hirschey, Urban C.
zone, outdated, suggests 5 mile setback from lake and river.
113 12b Hirschey, Urban C. Accuracy of the project efficiency needed.
Who provides compensation for loss of property value,
113 13 Hludzenski, Ed damage to water table? Who is liable for property, personal
damage from ice throw, study on infrasound needed.
113 14 Hludzenski, Ed Leukemia possible near power lines.
3-48
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Table 3-1
Decommissioning of turbines at no cost to town, absolutely
113 15a Metzger, Don
no advertising.
113 15b Metzger, Don Requesting that the night-time lighting be minimized.
Restoring damage from installation process, and repairs at
113 16a Reinhart, Marianna
no cost to town
Where will the O&M building be placed in relation to town
113 16b Reinhart, Marianna
and turbines?
Three year Avian / Bat study, unknown credentials of visual
113 17a Schneider, Clifford P. analyst, use accurate noise instruments for measuring
sound.
Night-time noise studies needed, more description of
113 17b Schneider, Clifford P.
character of noise needed
113 18 Simpson, Carol Relocate turbines to accommodate the wildlife in the area.
Siting of turbines must be done in an environmentally
113 19 Nasca, Jack
sensitive fashion.
1
Source 113 represents oral comments received during March 24, 2007 Public Hearing.
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Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
The USFWS has reviewed the SDEIS and may provide further comments
1 1 USFWS Stilwell, David pursuant to the MBTA, BGEPA, CWA, or the Fish and Wildlife Coordination
Act, as applicable. Further consultation pursuant to the ESA is warranted
and is ongoing.
The additional data gathered by the project sponsor has answered some of
1 2 USFWS Stilwell, David our questions and concerns. However, we believe that insufficient
information still exists to predict potential impacts to wildlife.
Our previous comments on the project's ability to reduce greenhouse gases
1 3 USFWS Stilwell, David were not adequately addressed. We requested data which shows that the
project will offset emissions produced at fossil fuel burning plants, but none
was provided.
According to the SDEIS, there will be five meteorological towers eventually
located in the project area and all will by guyed for support. As stated
1 4 USFWS Stilwell, David before, we recommend that no guy wires should be used on the towers as
they have been known to be flight hazards for wildlife. Instead, monopole or
self-supporting towers should be installed.
Transmission line overhead crossing of the Chaumont River should be
accomplished using directional drilling under the river to limit impacts to
wildlife using the river corridor. Also, we commend the project sponsor for
1 5 USFWS Stilwell, David minimizing habitat impacts by choosing a route that primarily follows an
abandoned railroad and water line right-of-way. We recommend that tree
clearing along the ROW to reduce risk of damage to OH lines be kept to a
minimum amount necessary.
Based on wetland delineation report, it appears Turbine 3 is in wetland W-
1 6 USFWS Stilwell, David 22; however, the permanent impact associated with this area is listed as a
road impact on Table 3-6. Determine if this is an error. We recommend that
no turbines be placed in wetlands.
We recommend project design should be reviewed to eliminate clearing of
1 7 USFWS Stilwell, David 0.34 acres of forested wetland, if feasible. While compensatory mitigation
plans have not been finalized, project sponsor is not proposing mitigation
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for clearing of forested wetlands. We consider that this impact is
permanent, and accordingly, mitigation should be provided.
The SDEIS, p3-47, indicates that breeding bats are not highly susceptible
to mortality from wind turbines. We caution that insufficient data has been
collected at wind energy projects in the eastern US to draw conclusions
1 8 USFWS Stilwell, David about the effects of turbines on local populations. However, it is true that
most bat fatalities have been found during the fall migratory period,
primarily because that is when turbine areas have been searched for
carcasses.
The SDEIS mentions White Nose Syndrome (WNS) as an affliction killing
bats but does not include a discussion of the cumulative effects of WNS
and other sources of mortality on bats, such as wind turbines. While the text
acknowledges that little brown bats have been most affected by WNS, it
1 9 USFWS Stilwell, David does not mention that this species was also among the most killed at
nearby Maple Ridge wind project last year. Since little brown bats are the
most numerous species of bat found in the project area, the text should
provide an analysis of what the long term implications of the project are for
this species.
Adaptive management should be listed as a method for monitoring and
mitigating impacts to bats (and birds). Specifically, the project sponsor
should commit to adjusting project operations, such as adjusting turbine
1 10 USFWS Stilwell, David cut-in speeds during low wind periods to reduce bat fatalities. This is the
period when most bats are killed as documented by recent research (Arnett
2005). A study at the Meyersdale wind project in PA recently determined
that bat mortality can be reduced by more than half if the cut-in speeds are
adjusted (Arnett 2009).
The project area, as noted in the DEIS on p3-22, is within a concentrated
migratory pathway, has attractive stopover habitat, and has unusually high
1 11 USFWS Stilwell, David concentrations of birds and, therefore risk for collision may be higher than
at other projects. The proximity to wetlands, Lake Ontario, and St.
Lawrence River attract waterfowl, waterbirds, and shorebirds to the area
during the breeding and migratory periods (Northern Ecological Associates,
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1994). We find that insufficient data were collected at the project site to
determine the spatial and temporal use of the project airspace by flying
animals and to adequately conduct a risk assessment and predict wildlife
mortality for this project. One year of surveys is not enough and we
recommend another year of study data to adequately determine avian use
in project area and the associated risk from project operation.
The SDEIS has documented the presence of bald eagles and golden
eagles in the project area. The bald eagle was removed from the Federal
endangered list and is no longer protected under the ESA; bald eagles
1 12 USFWS Stilwell, David remain on the NYS list as a threatened species and are also protected by
the federal MBTA and BGEPA. The USFWS is currently finalizing
regulations related to eagle take. We suggest the project sponsors review
that information when available. We may make additional recommendations
regarding these species.
The USFWS is currently coordinating with project team and USACE
regarding effects of the project on the federally-listed Indiana bat. The
project sponsor is preparing a Biological Assessment and we reserve the
1 13 USFWS Stilwell, David right to provide additional comments on the Federally-listed species until
the receipt of a complete BA. We will follow the consultation process (CFR
Part 402) for next steps (Biological Opinion, determination of effects,
recommendations and necessary conservation measures, etc).
In summary, we find that the SDEIS provides some of the information we
requested previously, but other data are missing. We maintain our view that
the report does not contain adequate information regarding potential
impacts of the project on wildlife, and additional environmental review is
necessary. Significant data is lacking for migrating, breeding, and wintering
1 14 USFWS Stilwell, David birds, as well as bats. Importantly, more information is needed on State-
and Federally-listed species use of the project area and how the
construction and operation of the project will affect these species. The
USFWS typically recommends that these studies be conducted over 3
years of project operation and be conducted at all times of the year and
under varied weather conditions.
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Our previous recommendation to mitigate potential impacts to bats was not
included in the SDEIS. Again, we recommend turbines should not have a
cut-in speed of less than 6 meters per second, and operation should be
curtailed between July 15 and September 15 for 5 hours after sunset. Also,
1 15 USFWS Stilwell, David the project approval should be conditioned upon an adaptive management
plan to address wildlife mortality as a result of turbine operations. A
construction environmental monitoring program should be implemented for
this project. We suggest that the program include a training component for
workers on how to identify and handle injured or dead wildlife.
The SDEIS Section 2.4, page 2-4, states that the project is seeking an
easement from DEC to cross approximately 1.6 miles of the Ashland WMA
with the 115 kV transmission line. Use of the WMA for this purpose requires
authorization by the New York State Legislature and requires DEC
approval. The DEC is not aware of any pending legislative proposals to
2 1 NYSDEC Tomasik, Stephen provide this authorization. Because the timeframe for receipt of
authorization by the state legislature is not able to be determined, an
alternate route may be necessary for the project to move forward in a timely
manner, which may necessitate revision of SDEIS Section 7, Alternatives
Analysis. If the transmission line exceeds 10 miles, DPS approval would be
required.
Define the procedures proposed to cross the Chaumont River with the
overhead transmission line. The Chaumont River is a Navigable Body of
Water, as defined by 6 NYCRR Part 608. Workers/contractors in the river
2 2 NYSDEC Tomasik, Stephen could create a health and safety issue for the workers and the recreational
public. Appropriate measures to ensure the health and safety of the
workers/contractors and recreational public while crossing a navigable body
need to be addressed.
SDEIS Section 4 does not include discussion of the potential for use of the
proposed transmission line by the BP Cape Vincent Wind Power Project,
2 3 NYSDEC Tomasik, Stephen which would be located adjacent to the SLWF and would need to deliver
power to the same substation in the Town of Lyme. This analysis should be
provided.
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SDEIS Section 2.6.5, page 2-16, states that although not currently
anticipated, portions of the interconnect could be installed above-ground
when burial would not be economically feasible or could result in significant
2 4 NYSDEC Tomasik, Stephen environmental impacts. More clearly define what situations would meet
these criteria to provide rationale for change. This section includes typical
specifications for installation of underground collection lines. Provide specs
for OH lines also in order that potential impacts, particularly visual, can be
analyzed.
Section 3.1.3.3 includes an outline of proposed karst and geotechnical
investigations, and the role of the environmental monitor is included in
2 5 NYSDEC Tomasik, Stephen Section 3.1.3.4. While this largely conforms to the DEC's previous
recommendations in the June 15, 2007 letter, it is important that results be
made available to assess the adequacy of proposed mitigation measures
identified in Section 3.2.1.3.
A draft SWPPP should have been included in the SDEIS that provides
specifications for best management practices to control contaminants
based on results of the karst and geotechnical investigations. Specifically
lacking is any mention of controlled concrete washout areas at turbine
2 6 NYSDEC Tomasik, Stephen foundation sites, which is imported for preventing concrete slurry from
contaminating groundwater through karst features or surface waters and
wetlands. DEC may require that the SWPPP prepared for the SPDES
permit be reviewed by DEC staff prior to implementation to ensure that
plans for site characterization, project construction, and construction
monitoring have been included and adequately address these concerns.
DEC is concerned that the short-eared owl was not sampled in any of the
bird surveys conducted. In contrast to SDEIS Section 3.3.6.2, DEC has
documented a wild, although cyclic, distribution of the species within the
2 7 NYSDEC Tomasik, Stephen general project area during winter months (see attached maps). Additional
surveys of short-eared owl are recommended both pre-construction and
post-construction to be sure this species' distribution and abundance is
accurately documented. SDEIS should also include 1) short-eared own in
its list of bird species know to inhabit the area 2) short-eared owl in its
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wintering bird discussion and 3) short-eared owl listed in Table 1-1.
In reference to Appendix E, page 3, the site visit with the DEC staff
2 8 NYSDEC Tomasik, Stephen mentioned is not valid part of survey/study effort and was not only to
identify roosting locations. DEC requests that this characterization in the
report be corrected.
Based on the information in the SDEIS, it is difficult to predict that raptors
would not have a high risk for collision due to either low recorded numbers
or flight height outside of the rotor swept zone because 1) the numbers
recorded at the Project Area were higher than most other proposed wind
energy projects and 2) there is not enough information collected at the
2 9 NYSDEC Tomasik, Stephen Project Site regarding use by wintering or migrating raptors, especially
during fall migration to make such a conclusion. It is known that the Project
Area lies within one of the most important raptor wintering grounds in New
York State. A more thorough analysis of raptor migration within the Project
Area is needed to support the conclusions made in the SDEIS.
Mortality rates at other wind farms, such as Maple Ridge, should not be
2 10 NYSDEC Tomasik, Stephen used to predict SLWF numbers because avian use of the SLWF Project
Area is higher than all other sites.
SDEIS Section 2.4 states that the total of built project facilities will occupy a
land area of approximately 60 acres. The SDEIS also quantifies impact to
habitat loss by providing the acreage of grassland (41 acres) and second
growth forest (17 acres) that will be affected. However, calculating the total
of temporary and permanent impacts, 14.4 miles of access road
development at 39 feet mean width, 53 tower work spaces at 1.6 acres
2 11 NYSDEC Tomasik, Stephen each, the result is approximately 150 acres of disturbed land area, much of
which may represent existing wildlife habitat. Further discussion is needed
regarding plans for restoration of temporarily affect areas, including the
length of time for restoration (e.g. replaced forest canopy will require much
longer to replace than grassland). Also, any areas that will need to remain
as buffers (e.g., mowed areas along permanent roads) should be calculated
as permanent impacts if these activities represent restoration of viable
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wildlife habitat.
2 12 NYSDEC Tomasik, Stephen Revise Table 1-1 of the SDEIS to include consultation with the DEC
regarding T&E species, in addition to consultation with USFWS.
While it is recognized that project development and operation will result in
the perpetuation of some grassland habitat (that might otherwise be lost to
succession if farm were to cease) the direct loss of 150 acres of habitat, at
least on a temporary basis, combined with associated habitat loss due to
avoidance or displacement, at least relative to listed species, will need to be
2 13 NYSDEC Tomasik, Stephen minimized and perhaps mitigated. Pending further clarification and
consultation with DEC with regard to direct and indirect habitat loss due to
construction of this project, the presence of both state endangered and
threatened species utilizing the Project Area may require the issuance of an
Article 11 permit from DEC. The principal condition of this permit would be
to ensure that habitat take impacts, if not avoided, will be mitigated in such
a way as to achieve a "net conservation benefit."
The breeding bird survey conducted for the project according to USGS BBS
protocol are not sufficient; the BBS protocol is designed to estimate trend
data over the long-term, not to fully characterize bird species' occupancy of
2 14 NYSDEC Tomasik, Stephen an area. Due to the presence of significant grassland, endangered, and
threatened species know to be in the area, an additional breeding bird
survey should be conducted according to DEC's Guidelines for Conducting
Bird and Bat Studies at Commercial Wind Energy Facilities.
More complete data need to be obtained in order to support the conclusion
that construction and operation of the proposed Project will likely result in
2 15 NYSDEC Tomasik, Stephen minor, temporary impacts to breeding birds. The Project could contribute to
an increase in the fragmentation of habitat that may result in birds being
displaced from their nesting areas.
Conclusion: The SDEIS and its related additional information with regards
to pre-construction bird and bat studies substantially adds to what was
2 16 NYSDEC Tomasik, Stephen offered in the DEIS. However, several of the related studies, including the
Raptor Migration and Breeding Bird Surveys are still lacking in scope in
comparison to the most recent DEC guidelines for bird and bat pre-
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construction studies.
Conclusion: Another concern is that the SDEIS continually cites other
studies of wind projects or data from surveys that are not ecologically
2 17 NYSDEC Tomasik, Stephen similar or even related to the Project Area. The SLWF is located in a region
that has significant grassland bird, raptor, and waterfowl concentration
areas and should not be compared to other potential wind energy projects
that do not support the same natural resources.
DEC agrees that post-construction studies are very important and should
be included as part of the project's required mitigation measures. The
2 18 NYSDEC Tomasik, Stephen SDEIS should further state that based on the results of these studies,
adjustments to the Project's operational configuration and or time-table may
be necessary to affect avoidance or minimization of the take of birds or
bats, with listed species receiving the highest consideration.
In order to adequately assess the potential impacts to the Project Area's
threatened and endangered species, the Project needs to fully characterize
2 19 NYSDEC Tomasik, Stephen seasonal use of the area by these species. As submitted, the SDEIS is
inadequate to allow a thorough evaluation of the potential impacts to these
species.
Subsection 3.1.1.4, p3-13, states that a majority of the area is level and the
drainage pattern is generally in the direction of small streams and creeks
(e.g. Kent's Creek, Fox Creek, Shower Creek, Super Creek, Three Mile
Creek), which discharge directly into the St. Lawrence River. There are a
number of inaccuracies in this description: (1) Kent's Creek (aka Mud
Creek) flows directly into Mud Bay, which is an embayment of Lake Ontario
2 20 NYSDEC Tomasik, Stephen that is approximately 4 miles from the beginning of the St. Lawrence River;
(2) Fox Creek flows directly into Lake Ontario approximately 5.5 miles away
from the beginning of the St. Lawrence River; (3) Shower Creek and Super
Creek do not exist within the Project Area. Shaver Creek, Soper Creek, and
Three Mile Creek flow into Three Mile Bay which flows into Chaumont Bay
and then directly into Lake Ontario approximately 12.2 miles from the
beginning of the St. Lawrence River.
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Subsection 3.2.2, p3-23, stats that 36 mapped surface water bodies occur
within the Project layout. These include Scotch Brook, Chaumont River,
Kent's Creek, Shaver Creek, Three Mile Creek, Soper Creek and 30
unnamed tributaries. These surface waters are perennial and located within
the Saint Lawrence River Basin. There are a number of inaccuracies in this
description: (1) Scotch Brook is the only one from the listed streams on
page 3-23 that actually flows directly into the St. Lawrence River; (2) Kent's
Creek (aka Mud Creek) flows directly into Mud Bay, which is an embayment
of Lake Ontario that is approximately 4 miles from the beginning of the St.
Lawrence River; (3) Shaver Creek, Soper Creek, and Three Mile Creek flow
into Three Mile Bay which flows into Chaumont Bay and then directly into
Lake Ontario approximately 12.2 miles away from the beginning of the St.
Lawrence River.
It is difficult to assess this SDEIS with a highly inaccurate description of the

surface water geography as it relates to the Project Area.
Subsection 3.1.2 states that the proposed project, once built, could
potentially cause a minor alteration to existing drainage patterns (pages 3-
13 to 3-14). A detailed investigation designed to evaluation the potential for
2 21 NYSDEC Tomasik, Stephen long-term alterations to existing drainage patterns should be prepared,
noting that any alterations to the existing drainage patterns, even perceived
minor ones, could have serious effects on current land use patterns,
homes, and the environment.
The methods noted in the SDEIS to avoid impacts to Blanding's turtles
(Subsection 3.3.7) are insufficient to adequately protect Blanding's turtles,
particularly from loss of nesting habitat by turbines and mortality caused by
2 22 NYSDEC Tomasik, Stephen vehicles on roads constructed in nesting areas. Nesting areas are typically
found outside of wetlands. In addition, minimization of impacts to nesting
Blanding's turtles may need to include the restriction of construction
activities to outside of the nesting season.
2 23 NYSDEC Tomasik, Stephen SDEIS Section 2.6.10. DEC recommends that the environmental monitor
be empowered to order correction of acts that violate environmental
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regulations and permit requirements, and order the cessation of
construction activities until such corrective action has occurred. The monitor
should also provide regular reports to appropriate involved and interested
agencies, including DEC staff responsible for permitting and technical
review of agency permits. A staff of monitors should be available to provide
coverage at all times the construction activities occur; one monitor may not
be enough to cover extended hours. These provisions will be requirements
on any DEC permits that may be necessary for project construction.
As currently proposed, the project is not substantially located within the
boundaries of the New York State coastal zone. However, its proximate
location and the nature of the proposed activity suggest that coastal effects
3 1 NYSDOS Zappieri, Jeff may be likely. Should further authorization from other federal regulatory
agencies be required or should the USACE decide that the proposed
project would not meet the criteria for a permit issued under the NWP
program, DOS should be notified to determine if a consistency review is
necessary.
The proposed project incorporates transmission lines that traverse portions
of New York's Coastal Zone. Transmission line right-of-way maintenance
activities should not adversely affect any coastal resources. In part, this
3 2 NYSDOS Zappieri, Jeff may be accomplished through a reduced reliance on herbicides, the
establishment of buffer areas adjacent to the Chaumont River, and careful
use of best management practices designed to lessen stormwater impacts
both pre- and post-construction.
Section 2.8.1.4 states that at decommissioning, the transmission line poles
will be sawn flush with the ground unless the "appropriate governing
3 3 NYSDOS Zappieri, Jeff authority" determines that the environmental damage will outweigh the
benefits of removal. This "appropriate governing agency" should be
identified along with suspected environmental damage that would negate
the benefits of removal.
In the Section 2.8.3 discussion of decommissioning, it may be useful to
3 4 NYSDOS Zappieri, Jeff require a performance bond or dedicated fund to be established to ensure
the complete decommissioning of the project.
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Section 3.2.3.3 should include that all wetland mitigation should be located
within the same sub-watershed as the original disturbed wetland.
Additionally, specific parameters should be established that define what
3 5 NYSDOS Zappieri, Jeff would constitute a successfully established wetland and at what point
guaranteed remedial action would occur, should success parameters not be
met. It may be advantageous to guarantee proper wetland establishment
through bonding or other financial security mechanisms.
Curtailment between July and September should be considered to reduce
impacts to birds and bats. A recent study at the Casselman Wind Power
Project in Pennsylvania indicated that these impacts may be reduced by
3 6 NYSDOS Zappieri, Jeff raising the minimum "cut-in" wind speed necessary to begin turning the
wind turbine. An investigation into the viability of such a procedural shift
may indicate that the benefits derived warrant its implementation. Similarly,
this procedure may be useful to curtail potential effects on the proximate
Significant Coastal Fish and Wildlife Habitats.
Avian use may be affected at the seven Significant Coastal Fish and
Wildlife Habitats (SCFWH) located within 10 miles of the SLWF. Specific
pre-construction characterization of avian uses of the SCFWHs should be
3 7 NYSDOS Zappieri, Jeff required along with sufficient post construction monitoring to quantify any
potential effects. Appropriate provisions for operating procedure adaptation
should be included in the SDEIS if impacts at the SCFWHs become
evident. These and all other wildlife monitoring data should be presented to
all regulatory agencies and made available for public inspection.
Statements within the last paragraph of Section 3.3.7.2 appear to contradict
each other by stating that the project may cause abandonment of an
3 8 NYSDOS Zappieri, Jeff Indiana Bat maternal colony, effects will not be large enough to affect the
maternal colony, and that direct impacts may lead to the loss of the
maternal colony. This language should be clarified to indicate the
paragraph's true intent.
Section 3.4 states that several road closures may be necessary to enable
3 9 NYSDOS Zappieri, Jeff delivery of construction equipment and materials to the project site and that
some routes may necessitate road improvements. These routes should be
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planned to ensure that the public's access to the coast is not hindered.
Additionally, the potential may exist to improve the public's access to the
coast by ensuring that necessary road upgrades are constructed in a way
that would relieve traffic congestion or otherwise improve the public's travel
to and from the coast.
Section 3.4.3 discusses mitigation measures to repair highway
infrastructure that may be damaged during construction of the proposed
3 10 NYSDOS Zappieri, Jeff project. It may be advantageous to ensure that proper financial assurance
measures are in place to provide for adequate repair. Roads likely
susceptible to damage also likely provide the public access to the coast and
as such should be maintained in an appropriate fashion.
Section 3.5.1.3 discusses potentially applicable New York State coastal
policies. However, the analysis appears to consider only a small part of the
project's transmission line. Given the project's proximity to the coastal zone,
3 11 NYSDOS Zappieri, Jeff a full analysis of coastal policy should be included in the SDEIS that
considers the potential effects of the entire project on New York Coastal
Resources. Such an analysis should consider all applicable New York State
coastal policies and any applicable policies of the Village of Cape Vincent
Local Water Revitalization Plan.
3 12 NYSDOS Zappieri, Jeff Include the DOS on the distribution list for all future monitoring reports
regarding this proposed project.
The facilities proposed for the SLWF do not trigger Public Service
4 1 NYSDPS Davis, Andrew Commission jurisdiction (nameplate capacity above 80MW, 115 kV line
over 10 miles, or 125 kV over 1 mile).
The PSC encourages wind energy developers to adopt procedures and
practices to minimize conflicts and interruptions of utility services during
wind project construction and operations. The developer should coordinate
4 2 NYSDPS Davis, Andrew with local utility service providers to avoid construction interference of
electric, gas, cable, water, and telecommunications services providers. The
developer is encouraged to join Dig Safely New York UFPO program during
project development to identify proposed locations of underground facilities
in relation to other underground infrastructure and avoid inadvertent
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interruptions during excavation. Section 3.6.2.1 does not address
underground utility structures and equipment which may be affected by
road widening or access road construction. Widening roads at intersections
for temporary construction access by oversize vehicles has the potential to
affect buried infrastructure. Project planning and coordination with utilities
should address any underground facilities which may be encountered for
these improvements. Alternative design or access layout adjustments may
be necessary to avoid conflicts with infrastructure.
Discussion of transmission line construction at Section 3.6.2.1 is cursory.
Construction will involve repeated access for clearing, grading, and access
4 3 NYSDPS Davis, Andrew improvement, excavation, pole placement, installation of hardware and
conductors and conductor tensioning. Maintenance of transmission facilities
and vegetation along the right-of-way will require permanent and ongoing
periodic access to the length of the line.
Above-ground poles should be marked with owner identification information
and numbering of poles, pursuant to PSC regulations. DEIS Section 3.6.3
does not address pole marking requirements. Pole marking is important for
4 4 NYSDPS Davis, Andrew notification of the facility operators in event of damages to or emergency
responses involving downed or damaged service lines. Without appropriate
facility marking information, the likely perception in the community will be to
contact the local electric company if a pole is damaged in events such as
automobile accidents, or construction accidents or line encounters.
DPS staff notes that the use of the former railroad corridor for siting a 115
kV transmission line will require access for construction and facility O&M.
The old rail right-of-way includes washed out bridge and culvert crossings
at waterways, which preclude through-access, and which may make
4 5 NYSDPS Davis, Andrew construction access problematic. Access routes should be identified, and
constraints accounted for in project planning and permitting. In addition, the
co-location of electric transmission lines along the corridor of the existing
water lines may have the potential to result in induced voltages on the
water pipeline. Step and touch voltage levels should be estimated, and any
grounding necessary to avoid induced voltages which could induce an
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electric shock in someone touching an above-ground water line facility
(such as a hydrant) should be implemented.
Discussion of facility security at Section 3.13.3.2.7 should indicate that clear
4 6 NYSDPS Davis, Andrew zone around the project substation may need to be enlarged beyond the 10
feet cited, to preclude danger tree contact with station infrastructure and
perimeter fencing.
Attached are standard questions and information requests which DPS
poses to major wind project developers. Some of these items are
4 7 NYSDPS Davis, Andrew addressed in the discussion of impacts and mitigation as described in the
SDEIS; however there are additional details which may be relevant for
consideration of the SLWF.
Visual impacts discussion does not address the Seaway Trail-Cape Vincent
Bicycle Look trail (map attached), much of which is open land through
portions of the Project Area. An analysis of visual impacts to the trail,
including photo simulations, should be provided. Some consideration of
4 8 NYSDPS Davis, Andrew cumulative effects of wind energy on state parks and recreation facilities in
the Jefferson County area is warranted. The number of wind turbines which
will be visible from park locations should be noted for the Wolfe Island, St.
Lawrence, Cape Vincent, and Hounsfield Wind projects is like to be
significant. DPS notes that the Wolfe Island wind turbines are visible across
the low-relief areas of the region at distances exceeding 12 miles.
1. Provide a list of engineering codes, standards, guidelines, and practices
that the company intends to conform with when planning, designing,
4 9 NYSDPS Davis, Andrew constructing, operating and maintaining the wind turbines, electrical
collection system, substation, transmission line, interconnection, and
associated buildings and structures.
2. a) Provide a list of the permits, approvals, and permissions the company
will have to obtain to construct, operate, maintain, and retire the wind
4 10 NYSDPS Davis, Andrew turbines, electric collection system, substation, transmission line,
interconnection, and associated buildings and structures. b) Provide an
estimated schedule for the application and receipt of items in item "a"
4 11 NYSDPS Davis, Andrew 3. Provide a Quality Assurance and Control plan, including staffing
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positions and qualifications necessary, demonstrating how applicant will
monitor and assure conformance of facility installation with all applicable
design, engineering and installation standards and criteria as indicated in
question 1 above [Comment 4-9].
4. Provide a statement from a responsible company official that: a)
company and its contractors will conform to the requirements for protection
4 12 NYSDPS Davis, Andrew of underground facilities contained in Public Service Law §119-b, as
implemented by 16 NYCRR Part 753; b) company will comply with pole
numbering and marking requirements, as implemented by 16 NYCRR Part
217.
5. Provide plans and descriptions indicating design, location, and
construction controls to avoid interference with existing utility transmission
4 13 NYSDPS Davis, Andrew and distribution systems. Indicate detailed locations and specify design
separations of proposed facilities from existing electric, gas, and
communications infrastructure. Indicate measures to minimize interferences
where avoidances cannot be reasonably achieved.
6. Provide description and indicate details of plans to limit public access
4 14 NYSDPS Davis, Andrew and assure security at substations, collection points, wind energy facilities,
and aboveground components of electrical collection system.
7. Explain how the design and operation of the facility will avoid interference
4 15 NYSDPS Davis, Andrew with radio communications, including cell phones, AM/FM/SW radio,
television, radar, GPS and LORAN, and microwave transmissions.
8. Provide transmission facility design and construction plans, indicating
vegetation clearing and disposal specifications, structure locations, access
4 16 NYSDPS Davis, Andrew requirements, grading and access improvements, and environmental
control measures including storm water and erosion and control practices
and facilities.
9. Provide facility maintenance and management plans, procedures, and
criteria. Specifically, address the following topic:
4 17 NYSDPS Davis, Andrew a) turbine maintenance, safety inspections, and tower integrity;
b) electric transmission, gathering and interconnect line inspections,
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maintenance and repairs;
(i) vegetation clearance requirements;
(ii) vegetation management plans and procedures;
(iii) inspection and maintenance schedules;
(iv) notification and public relations for work in public right-of-way;
(v) minimization of interference with electric and communications
distribution plans.
c) vegetation management practices for switchyard and substation yards,
and for danger trees around stations; specifications for clearances;
inspection and treatment schedules; and environmental controls to avoid
off-site effects.
10. If the company will entertain proposals for sharing above ground
4 18 NYSDPS Davis, Andrew facilities with other utilities (communications, cable, phone, cell phone
relays, etc) provide criteria and procedures for review of proposals.
11. Provide emergency response plans, notification and coordination
procedures. Specify plans and procedures for addressing electric line
4 19 NYSDPS Davis, Andrew outages, specification of 24-hours per day storm and emergency response
situations. Include measures for communication and coordination with
operators of existing utility facilities, and residents of adjoining or affected
locations.
4 20 NYSDPS Davis, Andrew 12. Specify commitments for addressing public complaints, and procedures
for dispute resolution during facility construction and operation.
13. Specify commitments for end-of-life facility retirement and
4 21 NYSDPS Davis, Andrew decommissioning, with specific references to electrical gathering and
transmission system, interconnection and substation facilities.
14. Provide switchyard and substation design drawings and site plans,
indicating:
a) property lines and setbacks; access road location, width, and gradient;
4 22 NYSDPS Davis, Andrew site grading, cut and fill, drainage and environment controls; all proposed
improvements and equipment; fencing and gates; permanent erosion
control measures;
b) indicate any station lighting needs, and appropriate design criteria
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c) provide a statement indicating that any future lighting will be designed to
avoid off-site lighting effects (i.e., avoid up-light direction except for as-
necessary maintenance task-lighting; avoid drop-down optics to minimize
light trespass);
d) listing of all electrical equipment and specifications for substation and
switchyard facilities;
e) interconnection facility design plan and profile information.
4 23 NYSDPS Davis, Andrew 15. Provide a status report on equipment availability and expected delivery
dates for towers, turbines, transformers, and related major equipment.
16. a) Specify turbine design setback requirements for the following
structures: occupied structures (residences, businesses, and schools);
barns and unoccupied structures; electric transmission lines.
4 24 NYSDPS Davis, Andrew b) Explain the rationale for the setback distances for each type of structure
or facility.
c) Provide a detailed explanation as to why local setback provision from
transmission lines cannot be accommodated in facility layout.
17. Provide an analysis of the electrostatic and electromagnetic fields for
the proposed 115 kV electric transmission line. Include a cross-section
diagram and chart showing the results of the field strength analysis at
4 25 NYSDPS Davis, Andrew average annual and annual maximum conductor current flow (maximum
conductor rating). The cross-section diagram should demonstrate the
electrostatic and electromagnetic field strengths extending horizontally from
facility centerline to a distance of 300 feet.
We have received a request to evaluate properties for potential
historic/cultural significance. The initial request for resource evaluation was
received on October 9, 2007 and consisted of a single-volume report titled
Historic Architectural Survey (1-2 Mile APE) for the St. Lawrence Wind
5 1 NYSOPRHP Bonafide, John Project (October 2007, TRC). This document was supplemented by a
revised and expanded survey document that was received on January 23,
2008 titled Historic Architectural Survey for the St. Lawrence Wind Project
(January 2008 TRC). Our full assessment is attached to this letter as
Appendix A.
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Within the survey area, this agency has identified several key loci where
visual impacts should be carefully assessed. There areas encompass the
Cape Vincent village area, especially the National Register Listed individual
properties and historic district. Many of these resources may have a direct
visual connection to more than two-thirds of the proposed towers. In
addition, several of the individual rural agrarian properties will be in the view
5 2 NYSOPRHP Bonafide, John shed of a significant number of the proposed towers. Given the
unremarkable topography of this area the potential view shed/setting
impacts associated with these resources should be carefully assessed. All
resources where this office believes additional visual assessments should
be undertaken have been identified in Appendix A with an asterisk (*). We
would recommend that your agency seek to have appropriate visual
simulations generated to better understand the full extent of the potential
visual impacts associated with this project.
Although the full extent of potential impacts from the proposed undertaking
cannot be assessed absent simulations as part of a comprehensive visual
analysis, OPRHP believes that sufficient information does exist to
determine that under Section 14.09 1(c) of New York State Parks and
Recreation Law, the undertaking will have an Adverse Impact on cultural
5 3 NYSOPRHP Bonafide, John resources. The introduction of the sleek, ultra modern, approximately 425-
foot tall kinetic wind turbines (up to 96 proposed) throughout this scenic
landscape forever alters and changes the rural setting, which itself is a
significant element in much of the survey area and serves as the backdrop
for the architectural, cultural, and scenic tourism heritage of these
communities.
We would recommend that the applicant utilize the visual analysis as a tool
to aid in the exploration of feasible and prudent alternatives that avoid the
adverse impact(s). The assessment of potential impact avoidance options
5 4 NYSOPRHP Bonafide, John may include a reduction in turbine numbers and/or height, relocation of
turbine units, and various screening options. We would recommend that
only after an assessment of avoidance options has been established should
potential migration options be discussed. All consultation regarding
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avoidance options and potential later mitigation options should involve
those state/federal agencies directly associated with the permitting/approval
process for this project.
At this point in time we have concluded our evaluation of eligible resources
5 5 NYSOPRHP Bonafide, John and the potential impacts to those resources associated with this project.
Please be aware that we will be asking the project sponsor for GPS data
gathered as part of the survey.
Project design has been changed from 97 turbines to 53 and, consequently,
from 136 MW to 79.5 MW. As a result of the redesign, the project may no
longer require the Section 14.09 review of the NYS Public Service
6 1 NYSOPRHP Bonafide, John Commission. However, at this time, we do not know if other state and/or
federal agencies may be involved in this undertaking. Also, please note, our
comments related only to historic/cultural resources. Comments regarding
New York State parkland were submitted separately.
It is our understanding that the remaining 53 turbines are located on sites
previously identified in the original project information. As such, no
6 2 NYSOPRHP Bonafide, John additional topographic assessment or architectural survey was requested
by this office. The Alternatives Analysis and Visual Analysis provided in the
SDEIS would indicate that a number of the previously identified resources
would remain affected even with the turbine field selection.
As noted in the SDEIS, the reduction in the total number of turbines from 97
to 53 is a significant component in minimizing the impacts to historic
properties and is discussed in the sponsor's Alternatives Analysis. While
recognizing the significance of this redesign on the overall impact to the
6 3 NYSOPRHP Bonafide, John region's historic resources that surviving turbine field, nevertheless will
continue to have an adverse effect on historic properties. At this point in
time we encourage the Lead Agency, the project sponsor, and involved
state and/or federal lead agencies to continue to seek opportunities to
explore feasible and prudent alternatives that avoid, minimize, or to mitigate
the adverse impacts.
7 1 NYSOPRHP Lyons, Thomas I am writing on behalf of the State Parks office of the NYSOPRHP.
Comments on the cultural/historic impacts are provided separately by John
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Bonafide.
The visual impact analysis indicates the project will be visible from three
state parks: Cedar Point, Burnham Point, and Long Point. These three
facilities constitute an important component of the public recreational
amenities in the region and it is quite apparent that this project will have an
7 2 NYSOPRHP Lyons, Thomas adverse impact on these facilities. It is not possible to tell the location where
the line-of-sight confirmations were conducted. We request information on
the specific location, preferable GPS coordinates, for further review. Once
we receive this information, we may request additional photo simulations to
assist in determining potential impacts.
There seems to be an inconsistency in the SDEIS between the photo
simulation in Figure A14b and Table 3-27 which indicates that the "Actual
7 3 NYSOPRHP Lyons, Thomas View" from Cedar Point State Park will be "substantially screened by local
structures or vegetation." It would seem that this should be listed as
"Visibility indicated." Please clarify or provide further information.
7 4 NYSOPRHP Lyons, Thomas We also request further information on the impacts to park patrons of the
required FAA lighting to the nighttime horizon.
Based on the fall raptor migration rates exceeding those of Franklin
Mountain Hawk Watch and given the location of the project along the
northeastern edge of Lake Ontario, large numbers of birds may funnel
7 5 NYSOPRHP Lyons, Thomas through the Project Area during fall migration. State Parks recommends
that post-construction mortality surveys focus particularly on mortality
during migration. If significant mortality is observed, consideration should
be given to reducing operations during peak periods of migration.
State Parks endorses the SDEIS proposal to implement "the minimum FAA
safety lighting requirements." Also with regard to lighting, this agency
requests that the findings within the following two scientific documents be
7 6 NYSOPRHP Lyons, Thomas considered during the preparation of the FEIS: 1) USFWS 2003 Interim
Guidelines to Avoid and Minimize Wildlife Impacts from Wind Turbines.
Wind Turbine Siting Group, and 2) Longcore, Travis, Catherine Rich and
Sidney A. Gauthreaux Jr., 2008.
7 7 NYSOPRHP Lyons, Thomas The DEIS states that there will be shadow flicker less than 10 hrs/year at
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Burnham Point State Park. Please provide additional information on
impacts associated with shadow flicker including the basis for this estimate
as well as a focus on impacts to recreationists at the State Park.
Table 1-1 of the DEIS states, "The proposed project would generate noise
7 8 NYSOPRHP Lyons, Thomas during construction." State Parks seeks assurances that the project
applicant will confer with us on ways to minimize disruptions to park patrons
during construction.
In closing, State Parks acknowledges the importance of alternative and
7 9 NYSOPRHP Lyons, Thomas renewable energy sources for sustainability but we also recognize the
importance of this agency's mission to protect public resources that are so
important to the quality of the experience for our patrons.
WWNY's experience is that windmill farms can disrupt television signals
and municipalities should have a solid plan to make sure that free over-the-
air TV remains a valuable resource to all citizens now and in the future for
local news, weather, emergency broadcasts, as well as entertaining
programming.
WWNY has reviewed the sections which covered television reception within
the DEIS and SDEIS. We know St. Lawrence Wind Farm contracted
Comsearch for an analysis of the impact on off-air television reception, but
Corbin, James, could not find a date when this study was conducted. Some data is
FOX Program Director incorrect or dated (stations in operation, channel numbers, stations
10 1
Broadcasting and Director of FOX operating digitally, etc) and there are a few statements which we would
Broadcasting challenge based on our engineering knowledge and experience.
As of February 17, 2009 WWNY no longer broadcasts an analog signal. On
that date we also switched our digital broadcasts from UHF channel 35 to
VHF channel 7. It has been our experience that VHF frequencies are more
affected by turbines than UHF frequencies, and contrary to the conclusion
Comsearch makes, digital signals can be affected by intervening structures.
We suspect it relates the physical size of the radio wave-length of a
structure reflects or signal. Reflected signals produce a phenomenon called
multi-path which with may DTV sets or converter boxes makes the signal
appear weak or missing.
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We were pleased to read that if project operations impact existing television
coverage SLWF would address and resolve each individual problem. This
is encouraged since all viewers are important to us. It notes further that
mitigation actions could include adjusting existing antennae, upgrading
Corbin, James antenna, or providing cable or satellite systems to affected households. It
FOX Program Director needs to be noted that cable is not a viable action for many residents in our
10 2
Broadcasting and Director of FOX rural area and the Direct Broadcast Satellite services do not carry local
Broadcasting stations. Signal interference from windmills would not make a viewer
eligible for a distant-market Network feed from satellite and distant-market
feeds do not serve the viewer with local news or emergency broadcasts.
Distant Network feeds negatively affect WWNY's ability to serve and
contribute to the North Country.
Menter, Rudin, The SDEIS is not adequate and still fails to address the deficiencies
11 1 & Trivelpiece, Fucillo, Thomas discussed in my letters of June 13, 2007, June 14, 2007 and February 20,
P.C. 2008.
The SLWF is incompatible with the Village and Town of Cape Vincent Joint
Comprehensive Plan of 2004. The plan provides that "Area 8" where the
majority of the Project and much of the unrelated BP wind project will be
Menter, Rudin, sited, consists "mainly of rural residential and agriculture, with scattered
11 2 & Trivelpiece, Fucillo, Thomas commercial and a public school." The plan provides that "development that
P.C. has minimum impact on important resources such as scenic natural vistas,
working landscapes, and tourism assets" should be encouraged, and the
"location of towers...or utility facilities...[which] would have a negative
impact on scenic vistas and tourism assets" should be discouraged. Page
32.
Menter, Rudin, The visual impact analysis is not adequate. The 140 towers from the
11 3 & Trivelpiece, Fucillo, Thomas pending Cape Vincent are not included. The density of wind turbines in the
P.C. town will have a large impact that is not adequately addressed.
Menter, Rudin, The Applicant states that design alternatives for the portion of the
11 4 & Trivelpiece, Fucillo, Thomas transmission substation in the resort district will be evaluated to avoid or
P.C. minimize placement of this facility within this district. The evaluation of
design alternatives must take place as part of the impact statement
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process.
Menter, Rudin, The bird and bat studies in the SDEIS are not adequate. Further study is
11 5 & Trivelpiece, Fucillo, Thomas necessary in accordance with NYSDEC Guidelines (expanded study) and
P.C. USFWS 2003 Interim Guidelines.
Menter, Rudin, The raptor surveys are inadequate. The SDEIS downplays the presence of
11 6 & Trivelpiece, Fucillo, Thomas these species. At a minimum, additional seasons of data regarding the
P.C. presence and height of these species is needed before such presence can
be dismissed as "minimal" or outside the "zone of danger."
Menter, Rudin, The presence of the protected species of breeding birds (northern harrier,
11 7 & Trivelpiece, Fucillo, Thomas horned lark, grasshopper sparrow, and vesper sparrow) merits additional
P.C. seasons of study during the SEQR review of this Project.
The Indiana bat analysis in the SDEIS is inadequate. Further study is
required to determine the extent in which this site is used by the Indiana
Bats (as opposed to the two brief sampling events conducted by the
Menter, Rudin, Applicant) and to corroborate the Applicant's theory that the Glen Park
11 8 & Trivelpiece, Fucillo, Thomas cave-based ecology is dying off. Such analysis should not be part of a
P.C. vague future "collaborate process" but must be assessed in an
environmental impact statement. Such consultation and the development of
effective mitigation must occur during the SEQR process to render SEQR
meaningful.
Based upon the presence of multiple threatened and endangered species
of birds and bats and in the immediate vicinity of the site, much more study
is required to adequately assess the impact of the proposed facility on
those species. Such study must be performed prior to construction, as part
Menter, Rudin, of the environmental impact statement for this Project.
11 9 & Trivelpiece, Fucillo, Thomas
P.C. Such impacts must be assessed and mitigated during the SEQR process,
not after it has concluded. These are potential impacts that will likely require
a "taking" permit under both state and federal law, and therefore this is not
some theoretical or fanciful concern. There are many different species of
birds and bats which are lawfully protected and significantly more study is
required in an environmental impact statement to determine whether or not
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this site is feasible for this large industrial wind facility.
Menter, Rudin, SDEIS should adequately justify the need for overhead rather than buried
11 10 & Trivelpiece, Fucillo, Thomas power lines and discuss whether overhead lines will actually create more
P.C. impacts to birds than will be avoided in the wetlands.
Menter, Rudin, Coastal consistency - nowhere in the DEIS or SDEIS is there any
11 11 & Trivelpiece, Fucillo, Thomas demonstration that this facility (or any part of it) must be constructed in a
P.C. shorefront location.
Menter, Rudin, The SDEIS states that the Applicant will develop a wetland mitigation plan.
11 12 & Trivelpiece, Fucillo, Thomas Mitigation of impacts to resources such as wetlands is an important part of
P.C. the SEQR process and should be discussed within the SDEIS, not
developed after SEQR is completed.
Group of local citizens hired a noise consultant to evaluate Hessler's noise
analysis of the BP facility (attached to comment letter). Because the same
consultant conducted the analysis for SLWP, we assume the same flaws in
methodology.
(1) Test sites at the noisiest locations resulting in higher ambient noise
level. And the typical residence in Hessler's report is not a typical residence
but a construction trailer on a main road with a storage yard for trucks and
other heavy equipment
(2) Hessler significantly overstated background noise conditions during the
Menter, Rudin, summer by conducting a noise survey during a narrow time period when
11 13 & Trivelpiece, Fucillo, Thomas insect noise would have been at its peak
P.C. (3) Insect noise does not "mask" noise from wind turbines as contended by
Hessler because it is of a substantially higher frequency than wind turbine
sounds.
Schomer showed how a much more accurate ambient level for comparison
is 30 dB, which is much more typical of a rural community like Cape
Vincent.
Based upon the critical ramifications of establishing an erroneous ambient
sound level, it is incumbent upon the Town to more accurately determine
the background sound levels in this community. SLWF's elevated ambient
level of 37 db(A) is neither reasonable nor adequate to protect the citizens
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of Cape Vincent from objectionable noise. At a minimum, the Town should
have its own consultant assess background noise levels in Cape Vincent,
the results of which will be important to both pending projects.
Anticipated noise level of the operating facility is also suspect. The
Applicant's study relied upon modeling results obtained utilizing the
manufacturer's (the Applicant's) own sound data rather than actual sound
Menter, Rudin, level data obtained from operating wind farms. The Applicant should
11 14 & Trivelpiece, Fucillo, Thomas compare actual operational noise data from operating facilities with
P.C. manufacturer's data to determine if model results compare with actual
conditions at such facilities, and determine if whether the Applicant's
modeling assesses the frequency and duration of weather-generated
variation from "normal" expected sound levels at such facilities.
Menter, Rudin, The visual impact analysis of impacts to cultural/historic resources is
11 15 & Trivelpiece, Fucillo, Thomas inadequate because it does not consider the total impact of the additional
P.C. 140 proposed turbines for the adjacent Cape Vincent Wind Energy Project.
The SEQR process is meant to be an important tool for analyzing impacts
and mitigation, not a mere procedural impediment or bother. As with the
Menter, Rudin, DEIS, the Applicant relies too much on post-construction studies or future
11 16 & Trivelpiece, Fucillo, Thomas collaborative efforts with state and federal agencies to determine impacts or
P.C. develop necessary mitigation. As Lead Agency, the Planning Board must
ensure that such efforts are part of the SEQR process or that process has
no value whatsoever.
Since my comment letter dated May 22, 2007, I have received copies of the
following documents which are part of the Planning Board's record of this
action:
Menter, Rudin, 1. Memo to "File" from Kris Dimmick, the Town of Cape Vincent's consulting
12 1 & Trivelpiece, Fucillo, Thomas engineer dated 2/11/09 re Comments on January 2009 SDEIS (copy
P.C. attached).
2. 2/12/09 Letter from Todd Mathes, Town of Cape Vincent attorney, to
Richard Cogen, attorney for SLWF regarding the SDEIS completeness
review.
3. Email from Todd Mathes to various representatives of the Applicant
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dated 3/20/09 subject "Comments on St. Lawrence SDEIS" and
4. Letter of 3/23/09 from Todd Mathes to Richard Edsall regarding
completeness review of the SDEIS.
These documents support the conclusion that the SDEIS is inadequate, in

particularly regarding the sound analysis. It confirms that the Town's sound
consultant takes issue with portions of the sound analysis. Our FOIL
request to obtain a copy of these comments was denied and we reserve the
right to challenge that denial as a violation of New York's Freedom of
Information Law.
We request that you make the Tocci materials part of the SEQR record in
this action, require the Applicant to modify the SDEIS to make substantive
changes required by Mr. Dimmick (and apparently Mr. Tocci) and require
further analysis of noise impacts after appropriate background levels are
determined. There is no need to rush this important review to accommodate
the Applicant's construction schedule.
The WEST Inc study is likely flawed and did not adhere to the study work
plan. The SLWF is located proximal to one of the largest rivers in North
America and at the base of a large peninsula yet the studies provide little
evidence documenting the large concentrations of birds that would be
expected in this area. Flaws include:
- The study does not characterize avian/bat passage rates proximal to the
shoreline nor over inland areas, as planned in the study plan. Only a
13 1 Old Bird Inc. Evans, William passage rate summing up the whole radar-swept area is provided, most of
which is outside the wind project and another determination of passage rate
from a thin slice of atmosphere from the vertical mode of radar operation,
which was also collected outside the wind project area.
- West located radar equipment 0.5 km (instead of the prescribed 1.5 km
from the river edge. As such, the study provides horizontal passage rate
data where a third of the radar sweep area is over the St. Lawrence River.
The bird activity in this airspace is totally impertinent [sic] for avian impacts
of this wind project and it likely severely biases the results. For example,
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lower density (low-altitude) migration over water wouldn't have been
included in the overall passage rate figure whereas higher density overland
migration would have. Why doesn't the SDEIS come out and say that the
radar was only located 0.5 km from the St Lawrence River instead of the
prescribed 1.5 km? Why does this SDEIS incorrectly state that the USFWS
and NYSDEC recommended that the radar be less than 1.5 km away from
the shore when, in fact, these agencies requested that it be "approximately
1.5 km away?
- The passage rate determined from the vertical radar analysis is just a
single small slice of atmosphere adjacent to the project area and doesn't tell
us anything about channeling dynamics or the migration density across the
larger project area.
The West study does provide directional data of targets, which has the
potential to indicate channeling dynamics if carried out properly. But the
directional data they use in their analysis is from targets detected across all
altitudes surveyed. West's inclusion of high-altitude targets in this analysis
13 2 Old Bird Inc. Evans, William will tend to mask any channeling along the shoreline region because such
channeling activity would be primarily at low-altitudes.
The West study does not provide quantification of the relative rates of
passage below turbine height over the water, over the coastal zone, or over
the inland regions -- data that would help substantiate whether channeling
along the lakeshore was occurring.
For various reasons, the preconstruction radar study for this wind project
was not as productive as it could have been. What this means is there is a
lot less certainty in any forecast for impact to night migrating songbirds,
13 3 Old Bird Inc. Evans, William which so far appear to compose more than 80% of fatalities in eastern
North American wind projects. I think the SDEIS and the West radar study's
predictions of inconsequential collision impacts to birds are without solid
basis. The avian collision impact is potentially much higher than is
suggested by the SDEIS and West.
13 4 Old Bird Inc. Evans, William I have conducted nocturnal migration research in the region of the St.
Lawrence wind project using acoustic monitoring of avian flight calls. While
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my data suggest channeling dynamics in the region and unusual avian
concentration dynamics due to the peninsular location of this wind project, it
is clear that more research needs to and could be conducted to understand
these complex nocturnal migration dynamics with regard to reducing the
avian impact of wind projects in the region. What is needed is a study with
multiple nocturnal monitoring methodologies that can monitor the
atmospheric stratum below turbine height of multiple sites. Such a study
would help site turbines in areas that would have less nocturnal migration
traffic below turbine height, and theoretically less collision risk. Such a
study is worth consideration by all parties as wind turbine development in
this region is a long-term prospect.
While the West radar study has serious flaws and could have been carried
out more productively, the NYSDEC bears some responsibility for making
sure than the preconstruction studies are on track to be productive. The
preconstruction studies for the SLWF wind project were designed and
13 5 Old Bird Inc. Evans, William carried out before the NYSDEC guidance on wind power development were
finalized and fully thought out. It should be noted that avian impact at wind
projects is a learning process for all involved. The wind industry is the
primary proponent (and receiver of significant public $ stimuli). As such, it
has to bear a major burden for compliance with the full spectrum of public
service surrounding wind projects, including environmental impact.
I have conducted an acoustic monitoring avian night migration study
approximately 1 km west of the intersection of Rosiere Rd and Millens Bay
Road, approximately 1 km south of the SLWF, rough the same distance as
the West radar equipment was from the wind project area. The breeding
bird survey should also consider the following five species based on my
13 6 Old Bird Inc. Evans, William study, which recorded multiple flight calls of these species in the first week
of June 2007: Black-crowned night heron, least bittern (NYS Threatened),
Virginia rail, whip-poor-will (NYS Special Concern), and grasshopper
sparrow (NYS Special Concern). The site where these species were
recorded was simply an open field area. For most of these species, this
suggests they were flying about at night in regions outside of their preferred
feeding and nesting habitat. The fact that three of these species are
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associated with wetlands suggests that they are breeding within (or in the
near vicinity) of the SLWF. I am happy to provide this data to SLWF and the
agencies.
The SDEIS does not contain enough data to support the conclusions made
in the SDEIS. For example, the Second Atlas of Breeding Birds in New
York State identifies Cape Vincent as having significant concentrations of
Onondaga bird species that are Threatened and Special Concern in New York State.
14 1 Riley, Thomas
Audubon The atlas is a culmination of five years of fieldwork by thousands of
volunteers across the state. The SDEIS does not report the same avian
concentrations. We believe this is because the fieldwork for the SDEIS was
not adequate in duration and expertise.
We are very concerned that the project will adversely impact breeding,
migrating, and wintering patterns and behavior on the project site and
Onondaga surrounding area for the following Threatened and Species of Special
14 2 Riley, Thomas Concern that occur in the project area: northern harrier, short-eared owl,
Audubon
rough-legged hawk, whip-poor-will, and grasshopper sparrow (contrary to
the SDEIS conclusion, there is no evidence that this species would benefit
from the project).
The environmental impact statement attempts to discount those concerns
with the citing of minimal studies. Considering the variety of weather and
Onondaga other natural cycles there was not enough study of the bird populations to
14 3 Riley, Thomas
Audubon be confident of the recommendations. We would request that at least two
additional years of avian studies be conducted before another
environmental impact statement is considered for review.
For all the assurances in the SDEIS, the operator does not know what
damage will be done to the bird species on this site. The impact of this
Onondaga project on the welfare of birds in the region and the state is so critical that
14 4 Riley, Thomas we should insist that all comments in the study be based on scientifically
Audubon
acquired data. Referencing other studies and the proposed wind projects
that do not have a historical basis for their data should be discounted and
removed from the report.
14 5 Onondaga Riley, Thomas Any wind power project that gets approved and built should include post-
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Audubon construction studies. For this unique site it is critical that the science be
done now, not after the facilities are built and the damage to the avian
resources is done.
Onondaga In conclusion we ask you to recommend that this site not be approved for
14 6 Riley, Thomas
Audubon wind power projects.
We have talked with DEC employees watching for short-eared owls by our
Bell, Dolores and house over the past few years. They've seen as many as seven owls at one
15 1 time. If those doing the SDEIS failed to find any of these owls they must be
Michael
either incomplete or negligent and it should call into question their credibility
on other aspects of the SDEIS.
Two years ago, Clif Schneider did a sound level study at our home. Sound
levels he recorded were much lower than background levels assumed in
the SDEIS. The ambient sound test for the SDEIS is not a correct
representation of typical non-participating residents because the testing
Bell, Dolores and positions were located in noisy areas (near a construction site, near the
15 2
Michael largest dairy in town, near working farms, near busy highway, one near a
farm and a road). We are a farming and a resident community. To achieve
a limit of no more than 5 dBA above ambient sound at our home we think
setbacks need to be at least 3500 feet. Assurances that non-participating
residents will be protected need to be made before development proceeds.
In reference to low frequency noise, independent studies show it adversely
affects young children and the elderly. There needs to be further studies
into that. We did not find reference to this problem in the SDEIS. Please
reference World Health Organization (WHO) Lares final report Noise effect
Bell, Dolores and Morbidity by Dr. Niemann and Dr. Maschke
15 3
Michael (http://www.who.int.docstore/peh/noise/guidelines2.html) on page 8 refers
to the nervous and cognitive systems and on page 14 it refers to noise and
sleep disturbances, let alone other health problems. Science suggests that
Fiber acoustic disease may be attributed to windmills, so further research
needs to be done here too.
Bell, Dolores and The SDEIS report claims shadow flicker will affect up to 2,700 feet. There
15 4
Michael are 10 proposed turbine sites within this distance of our house. We have
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bedroom windows facing east without shades, frequently watch the sunset
out the western windows, and spend a lot of time outdoors. We will be
subjected to shadow flicker thought the day.
Bell, Dolores and Under the complaint resolution it is very vague and no true resolutions are
15 5 listed. Fill out the paperwork and wait. It doesn't give any time constraints
Michael
for true resolution.
A concern to be included in the complaint resolution in the complaint
resolution would be for the wind farm, it's developer and participating
Bell, Dolores and landowners to put up a bond to purchase properties from non-participating
15 6
Michael owners of adjacent windmill property owners if adjacent windmill property to
remediate any problems, if adversely affected by the "effects" of the
windmills and unable to sell on the open market.
There are no mitigation measures for shadow flicker or sound levels in the
Bell, Dolores and report. In fact, the use of buffer zones is the primary protection for ice shed
15 7
Michael and blade failure. We think buffer zones should be at least 3,500 feet to
avoid problems with shadow flicker and sound levels.
Also, under the mediation measure it needs to state that if within 18 months
Bell, Dolores and a non-participating resident deems that the developer denies them health,
15 8
Michael safety, or well-being, the wind farm, its developers, and participating
landowners would purchase property at pre-development market value.
It's not the responsibility of this board to assess the wind power industry's
Bell, Dolores and affect on global warming based on questionable science or the financial
15 9 viability of the industry without government subsidies. It is this board's
Michael
responsibility to regulate development based on its effect on the health,
safety, and general welfare of the public of this community.
Bell, Dolores and We think the SDEIS should be rejected due to its obvious lack of credibility
15 10 and apparent attempt to deceive and a moratorium be placed on
Michael
development until these concerns can be more adequately addressed.
Bell, Dolores and We started building our home over 5 years ago. If we know then what we
15 11 knew now we wouldn't have built our home here. The public officials did us
Michael
a disservice by not letting us know of the proposed windmills.
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The poles used for the overhead 34.5 kV and 115 kV transmission lines can
cause interference with agriculture operations when located on farmland.
16 1 Boss, Mark As a result, the Department [NYS Ag & Mkts] recommends that the 34.5 kV
lines be buried in agricultural fields. Why are you not burying the lines in
farmland?
In paragraph 2.6.2 St. Lawrence Wind states that in active agricultural
areas, agricultural protection measures in accordance with the guidelines of
16 2 Boss, Mark the NYS Ag & Mkts will be followed and the cable will be placed at a
minimum depth of 48 inches or 6 inches beyond the depth of bedrock. NYS
Ag & Mkts says that at now time [sic] will the depth be less than 24 inches
below the soil surface. Is it 24 inches or 6 inches?
Concerns regarding impacts of bedrock excavation on water resources.
There is no indication that any fieldwork has been done to establish major
springs and their use or flow prior to construction, thus no baseline to
16 3 Boss, Mark measure the impact of construction. Nor is there any information on wells
and springs within 500 feet of where blasting will occur. Will this information
be included in the FEIS? Also, what is St. Lawrence Wind's plan to provide
citizens with potable water if well problems occur?
St. Lawrence Wind does not say if the concrete will be mixed on site or
hauled in from off site. In either case will the FEIS include a description of
16 4 Boss, Mark specific processes that will be implemented to ensure the concrete is
handled properly during construction to limit the impacts to surface waters,
wetlands, and underground waters, given the existence of karst topography
in the project area?
St. Lawrence Wind states that the final overhead transmission line right-of-
16 5 Boss, Mark way will be identified post-construction on as-built drawings which will be
filed with the Towns of Cape Vincent and Lyme. Why not be identified pre-
construction?
Why doesn't the decommissioning plan include the long distance
16 6 Boss, Mark transmission lines? What is the plan to ensure that there are sufficient
funds available to execute the plan? If it includes bonding, which I favor,
how will that bonding follow to successive owners?
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What are the migratory patterns of the herons and how do they fly when
17 1 Boss, Sarah they are migrating? How long do they stay in Cape Vincent? When do they
arrive and when do they depart? Why isn't this addressed in the DEIS?
17 2 Boss, Sarah Impacts of shadow effect on wildlife should be part of the DEIS.
17 3 Boss, Sarah Individuals, guides, and town must be compensated if towers result in loss
of fishing revenues.
17 4 Boss, Sarah SLWF needs to establish who the environmental monitor works for and how
he/she sends reports to.
The development of a long-term environmental management plan should
be considered to incorporate plans for restoration of environmental impacts
17 5 Boss, Sarah during the following construction [sic], environmental considerations to be
included in the ongoing maintenance facility, a contingency plan to assess
and minimize environmental impacts during major repairs, and assessment
and mitigation of environmental impacts during decommissioning process.
17 6 Boss, Sarah It is important to know the impacts of shadow effect on the fish in the water.
How can the impact on wells and springs be evaluated if there is now
baseline for the springs or wells? Fieldwork should be done to establish
17 7 Boss, Sarah major springs and their use or flow prior to construction. I would like to see
identification of all wells and springs within 500 feet of where blasting will
occur. Also address the steps to be made to provide citizens with potable
water if problems occur.
17 8 Boss, Sarah The project may require an Article 24 Freshwater Wetland Permit and
Section 401 Water Quality Certification.
Since issues regarding potential medical problems related to wind turbines
17 9 Boss, Sarah come up with proposals around the state, it would seem appropriate to
include a section on medical issues in the DEIS.
Critical information is needed to evaluate potential impacts resulting from
17 10 Boss, Sarah the project not performed as part of the DEIS. The DEIS should be updated
to include: geotechnical field data, groundwater studies, wetland field
survey, and hydrogeological balance study based upon long-term runoff. By
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omission of this information during the design and review stage with a
disclaimer that it will be obtained "prior to construction" the developer
avoids all accountability from the Lead Agency, involved agency, and public
comment.
At best the studies to date may be considered pilot efforts requiring 3-5
17 11 Boss, Sarah years of intense further studies of many groups before any consultation of
value may be drawn.
Are you and the Audubon Society aware of the IBA (Important Bird Habitat)
17 12 Boss, Sarah on Pleasant Valley Road? How will it be affected? What does Audubon
say?
17 13 Boss, Sarah The lease with SLWF takes away landowners' constitutional rights to sue
for punitive damages and the right to jury trial. Why is this acceptable?
Section 2.6.4 of the SDEIS needs to include a description of specific
processes that will be implemented to ensure the concrete is handled
17 14 Boss, Sarah properly during construction to limit the impacts to surface waters,
in the project area.
The report should specifically state that the habitat type located at
17 15 Boss, Sarah Chaumont Barrens and Three Mile Creek will not be impacted by the
project.
Section 3.2 shows that no biotic or water quality data is provided but this
17 16 Boss, Sarah information should be included in the report along with a discussion of
potential impacts from project construction.
Section 3.3 of the DEIS does not identify if the wind project will impact to
17 17 Boss, Sarah establish [sic] the St. Lawrence Wetland and Grassland Management
District (SLWGMD). Nor does it mention if it is compatible with the
SLWGMD.
Section 3.3.6 NYS Fish and Wildlife strongly recommend that the Smith
17 18 Boss, Sarah (2007) be considered by the project sponsor in siting the project features
[sic].
17 19 Boss, Sarah Section 3.3.6 NYS Fish and Wildlife found insufficient data exists to
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adequately conduct a risk assessment and predict wildlife mortality for this
project.
The DEIS falls short of providing the necessary information in a
17 20 Boss, Sarah comprehensive manner. The DEIS states that additional data on wildlife
use and potential impacts is forthcoming. NYS Fish and Wildlife will review
this information prior to making a final determination.
The SDEIS states that SLWF will meet the setbacks required by the
Planning Board of Cape Vincent. These setbacks are 1,500 feet from the
18 1 Boss, Sarah Village of Cape Vincent boundary line, 1,000 feet to a non-participating
property line, 1,250 feet to a non-participating residence, and 750 feet to a
participating residence. These are inadequate for the safety of our
residents. I request that you require changes to these setbacks.
Commentary regarding the impact on health and safety from the wind
18 2 Boss, Sarah turbines. It is bordering on a crime to even consider that some residents will
be forced out of their homes due to inability to live with conditions caused
by the location of their turbines to their homes.
The monies the town acquires from the PILOT will be eaten up by the loss
18 3 Boss, Sarah of revenue from property taxes. Properties will decrease in value due to the
turbine industry. Commentary regarding negative impacts to the community
from the wind project.
The SDEIS is incomplete and not adequate for public comment and should
not have been accepted by the Town of Cape Vincent Planning Board.
Dramatic adverse impacts are proposed in the SDEIS without adequately
19 1 Bragdon, Brooks describing these impacts. There is no discussion to avoid adverse impacts;
there is no mention of alternate sites for the turbines, and no opportunity for
interested parties such as myself to communication concerns and
suggestions about the adverse impacts.
A letter dated May 28, 2008 from John A Bonafide of the NYS Historic
Preservation Office to Andrew C Davis of the NYSDPS advises that the
19 2 Bragdon, Brooks project shall result in adverse impacts, that "visual analysis be used to
explore alternatives to avoid the adverse impacts, suggests discussion of
relocation of the turbine units as well as a reduction in height and the
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number of turbines. Only after potential avoidance options have been
established should mitigation measures be discussed and this
communication should involve supervision state and federal agencies.
There is no such communication in the SDEIS.
Objections to the location of turbines near the two roads leading into Cape
Vincent, NYS Route 12 from Chaumont and from Clayton. These turbines
should be moved back considerably in order to preserve the basic assets of
the community. The project will jeopardize the historic preservation
19 3 Bragdon, Brooks designation of my home and my real estate development company. The
project will adversely affect the historic and cultural significance of the
community. Setbacks from the main roads leading into the community,
away from the St. Lawrence River, and from the village and historic
properties are essential to preserve the culture of the community.
A large percentage of the property tax assessment base is made up of
19 4 Bragdon, Brooks waterfront and water view properties and would be adversely affected by
the imposition of the economic will of a minority of the tax assessment
base.
20 1 Bragdon, Brooks Who negotiates PILOT payments for our town is not addressed.
20 2 Bragdon, Brooks What is the estimated cost per kilowatt hour produced for the first year of
the project, first five years, and the first 10 years?
There is no mention of Payment, Performance, and Maintenance Bonding
for this project. If the project is not bonded, neither the towns nor
20 3 Bragdon, Brooks leaseholders have any guarantee that promises will be kept, construction
completed, payments made, maintenance done, and dismantling
completed.
Most DEISs I have reviewed for wind power projects include the results of a
20 4 Bragdon, Brooks Job and Economic Development model. None was referenced in this DEIS
so it appears that the Socioeconomics section was based upon
assumptions.
20 5 Bragdon, Brooks There is insufficient documentation to back up the claim that downsizing the
project is not considered an economically viable solution.
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Since turbines are considered a utility then shouldn't the land on which they
20 6 Bragdon, Brooks are placed by assessed as industrial use and taxed accordingly and not
taxes as agriculture?
I am concerned that the DEIS does not adequately address who will
20 7 Bragdon, Brooks compensate businesses and individuals if the proposed wind project results
in loss of fishing revenues.
20 8 Bragdon, Brooks How will historic designated properties near towers be compensated?
20 9 Bragdon, Brooks How does SLWF plan to compensate Indigenous Americans if Indian burial
grounds are discovered?
20 10 Bragdon, Brooks Why no mention of Dodge Bay in the historical Architecture Resource
Investigation section of the DEIS/Supplemental?
20 11 Bragdon, Brooks describing these impacts. There is no discussion to avoid adverse impacts,
project shall result in adverse impacts, that "visual analysis be used to
20 12 Bragdon, Brooks relocation of the turbine units as well as a reduction in height and the
20 13 Bragdon, Brooks Vincent, NYS Route 12 from Chaumont and from Clayton. These turbines
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designation of my home and my real estate development company. The
The SDEIS is grossly incomplete. It should be returned to the developer to
be redone. The rights of interested parties in the community must be
respected. In my view, turbines may be allowed but in an area away from
20 14 Bragdon, Brooks unique community assets. Should I personally suffer economic loss as a
result of having my rights under the SEQR review process suppressed I
shall be obliged to defend myself legally in order to reverse any economic
losses I should suffer.
I am writing to clarify my comments on the SDEIS in regard to setbacks
[Comments 19.3 and 20.13]. The setbacks I proposed are intended to be
consistent with the Introductory Provisions of the Cape Vincent Zoning Law
which calls for the following: protecting existing development while
protecting the existing assets of the community, conserving property
values, minimizing negative environmental impacts of development,
protecting visually and environmentally sensitive areas such as viewsheds
along the lake and river, protecting scenic views and agricultural lands,
protecting historically significant land and buildings, allowing landowners to
20 15 Bragdon, Brooks make beneficial economic use of their land provided that such uses are not
harmful to neighboring properties.
I maintain that no turbines should be allowed on the lake side of or near
Route 12 from Cape Vincent to Chaumont and also not near Route 12 from
Cape Vincent to Clayton. Rather the turbines should be setback sufficiently
to protect the basic scenic sense and spirit of the community. This setback
may be variable depending on the landscape, but a starting point for
discussion would be 4000 ft inland from Route 12. The development should
fit in with the community, not vice versa. Interested parties in the community
must be allowed the right to have input into the SEQR review process and
any analysis of adverse effects and proposals to mitigate.
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The SDEIS is a dishonest document which avoids moving the turbines to
reasonable locations. If the project is allowed as proposed it would harm
20 16 Bragdon, Brooks the majority tax assessment comprised of waterfront and waterview
properties in favor of the minority interests of the relatively modest number
of landowners who have contracts for turbines.
Any turbines allowed should be setback so as to not change this unique
and lovely community. Views should be protected. The spirit of the
21 1 Brown, Mary Jane community should not be ruined. The SEQR process is not being carried
out fully and there has been no opportunity for input into the approval
process.
The proposal has too many turbines dominating the landscape. This would
22 1 Burpee, Edith destroy the community particularly together with the other proposed project.
Any turbines allowed should be setback so as not to damage the loveliness
of the community setting along the St. Lawrence River.
Commentary objecting to misinformation about the adverse impacts from
wind projects that have been suggested in other comments. My opinion is
that there are people in our community that just do not want wind power in
23 1 Burton, Darrell the area. I have observed the members of our planning board in action
since this project started. I believe you all have been very open minded and
conducted business properly. I think the results of the SDEIS are an
adequate report.
Commentary supporting the wind energy project and the benefits of wind
energy as opposed to other forms of energy production. Commentary
24 1 Burton, Marlene objecting to misinformation about the adverse impacts from wind projects
that have been suggested in other comments. I truly believe Tom Rienbeck,
Rich Edsall, and the Board Members are doing an honest, legally,
thankless job and should be applauded for the work they have done.
25 1 Byrne, Tatyana As a result, the Department [NYS Ag & Mkts] recommends that the 34.5 kV
farmland?
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25 2 Byrne, Tatyana the NYS Ag & Mkts will be followed and the cable will be placed at a
25 3 Byrne, Tatyana measure the impact of construction. Nor is there any information on wells
25 4 Byrne, Tatyana specific processes that will be implemented to ensure the concrete is
25 5 Byrne, Tatyana way will be identified post-construction on as-built drawings which will be
construction?
25 6 Byrne, Tatyana transmission lines? What is the plan to ensure that there are sufficient
25 7 Byrne, Tatyana Will the geotechnical investigation, necessary for project construction and
design, be included in the FEIS?
25 8 Byrne, Tatyana 3.1.3.3 In this paragraph, SLWF does not mention the use of an
environmental monitor. In order to provide proper oversight of these
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activities it is important that an environmental monitor be onsite for all pre-
construction survey and any construction activities that involve excavation
to bedrock or are located in proximity to known karst features. Will an
environmental monitor be present?
25 9 Byrne, Tatyana 3.2.3.3 The discussion on soil is too general. Each turbine site, access
road, electric line pole, and substation needs a soil map.
25 10 Byrne, Tatyana 3.4.2 Will the comprehensive transportation study, delivery routes, and
crane assembly areas be part of the FEIS?
3.9.1 There is no discussion of the impact of the turbines on the ozone level
25 11 Byrne, Tatyana which is already out of compliance with EPA guidelines. What is the impact
and if so, how will you mitigate?
3.11.3 To mitigate impacts to local roads during construction, any
construction-related damage or improvements to roads would be the
25 12 Byrne, Tatyana responsibility of the Applicant and would be undertaken at no expense to
the municipalities. How long after project completion is this going to
continue.
3.13.1.2 The study used in the discussion if ice shedding (Morgan,
25 13 Byrne, Tatyana Bossanyi, and Siefert, 1998) is an 11-year old study. Why aren't you using
a more recent one?
4.1.3.2 This section indicates that white nose syndrome will have a greater
25 14 Byrne, Tatyana cumulative effect on Indiana bats than the wind energy development. What
is the cumulative impact of both white nose syndrome and wind turbines on
Indiana bats?
25 15 Byrne, Tatyana 4.1.11.2 Since the housing market has changed so dramatically since 2007
why haven't you done a more recent "housing value study."
7.2 This section states that the Project will meet all of the following
setbacks required by the Planning Board of Cape Vincent. Are these
25 16 Byrne, Tatyana current?
- 1500 feet from Village of Cape Vincent boundary line
- 1000 feet to a non-participating property line
- 1250 feet to a non-participating residence
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- 750 feet to a participating residence
25 17 Byrne, Tatyana 7.6 Table 7-1. What compensation are the three non-participating
homeowners with over 48 db going to get?
25 18 Byrne, Tatyana Appendix E. The avian and bat study was conducted in one year. Why
didn't you do a multi-year study?
25 19 Byrne, Tatyana Appendix E1. The bat studies were done with radar. Why not also sonar?
Appendix E1. In this Appendix SLWF says that there is no statistical
evidence that Indiana Bats are in the project area, but Appendix E3 Section
3.0 July Aug 2007 states that four were captured and tracked. Appendix E6
25 20 Byrne, Tatyana July Aug 2007 1.0 states that six captures Indiana bats were radio tracked
and roost sites were identified in the project area [sic]. Appendix E4 June
2008 states that no Indiana bats were captured during that study. Appendix
F3 says they are present. Are there Indiana bats in the project area or not
and if there are, what mitigation actions will you take?
25 21 Byrne, Tatyana Appendix E3 is labeled Blanding Turtle but reports on bats.
25 22 Byrne, Tatyana Appendix E7. Which of the Blanding Turtle mitigation recommendations will
be adopted and which will not and why not?
25 23 Byrne, Tatyana Appendix J. What will you do to mitigate shadow flicker if your analysis is
wrong?
25 24 Byrne, Tatyana Appendix L. The data in Table 2.2.1 does not match the data from our paid
consultant (elaborate).
25 25 Byrne, Tatyana Appendix L.3.6 The negative impacts of low frequency sound are dismissed
as corrected by design change. Where is the medical data?
25 26 Byrne, Tatyana Appendix N2. Who pays to mitigate the loss of TV signals in the project
area?
25 27 Byrne, Tatyana they are migrating? How long do they stay in Cape Vincent? When do they
25 28 Byrne, Tatyana Impacts of shadow effect on wildlife should be part of the DEIS.
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25 29 Byrne, Tatyana Individuals, guides, and town must be compensated if towers result in loss
25 30 Byrne, Tatyana SLWF needs to establish who the environmental monitor works for and how
25 31 Byrne, Tatyana during the following construction [sic], environmental considerations to be
25 32 Byrne, Tatyana It is important to know the impacts of shadow effect on the fish in the water.
25 33 Byrne, Tatyana major springs and their use or flow prior to construction. I would like to see
25 34 Byrne, Tatyana The project may require an Article 24 Freshwater Wetland Permit and
25 35 Byrne, Tatyana come up with proposals around the state, it would seem appropriate to
the project not performed as part of the DEIS. The DEIS should be updated
25 36 Byrne, Tatyana survey, and hydrogeological balance study based upon long-term runoff. By
comment.
25 37 Byrne, Tatyana At best the studies to date may be considered pilot efforts requiring 3-5
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years of intense further studies of many groups before any consultation of
value may be drawn.
25 38 Byrne, Tatyana on Pleasant Valley Road? How will it be affected? What does Audubon
say?
25 39 Byrne, Tatyana The lease with SLWF takes away landowners' constitutional rights to sue
25 40 Byrne, Tatyana properly during construction to limit the impacts to surface waters,
25 41 Byrne, Tatyana Chaumont Barrens and Three Mile Creek will not be impacted by the
project.
25 42 Byrne, Tatyana information should be included in the report along with a discussion of
25 43 Byrne, Tatyana establish [sic] the St. Lawrence Wetland and Grassland Management
SLWGMD.
25 44 Byrne, Tatyana (2007) be considered by the project sponsor in siting the project features
[sic].
Section 3.3.6 NYS Fish and Wildlife found insufficient data exists to
25 45 Byrne, Tatyana adequately conduct a risk assessment and predict wildlife mortality for this
project.
25 46 Byrne, Tatyana comprehensive manner. The DEIS states that additional data on wildlife
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25 47 Byrne, Tatyana Who negotiates PILOT payments for our town is not addressed.
25 48 Byrne, Tatyana What is the estimated cost per kilowatt hour produced for the first year of
25 49 Byrne, Tatyana leaseholders have any guarantee that promises will be kept, construction
completed.
25 50 Byrne, Tatyana Job and Economic Development model. None was referenced in this DEIS
assumptions.
25 51 Byrne, Tatyana There is insufficient documentation to back up the claim that downsizing the
25 52 Byrne, Tatyana are placed by assessed as industrial use and taxed accordingly and not
25 53 Byrne, Tatyana compensate businesses and individuals if the proposed wind project results
25 54 Byrne, Tatyana How will historic designated properties near towers be compensated?
25 55 Byrne, Tatyana How does SLWF plan to compensate Indigenous Americans if Indian burial
25 56 Byrne, Tatyana Why no mention of Dodge Bay in the historical Architecture Resource
Since the coal/gas generators just go on standby while the wind generator
25 57 Byrne, Tatyana is generating please explain how wind power eliminates pollutants and
greenhouse gases during the production of electricity, thus benefiting
ecological water resources, as well as human health.
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Please explain who maintains service roads to individual towers and
25 58 Byrne, Tatyana takeaway lines and what level of maintenance priority will these roads have
vs. residential roads.
25 59 Byrne, Tatyana I am concerned that there are no safety measures to ensure children don't
get near the wind mills.
25 60 Byrne, Tatyana The assumptions used to complete the DEIS/Supplemental are not listed.
The DEIS should include the Planning Board's Energy Facilities Ordinance
25 61 Byrne, Tatyana that governs the application and decision-making process for the special
permits associated with the wind farm project.
The substation/collection station and operations and maintenance facility
should be represented with a plan and profile figures indicating proposed
25 62 Byrne, Tatyana layout, elevation drawings indicating all major equipment, architectural
features, fencing, exterior lighting, and access road in relation to the NMPC
transmission facilities.
A real-time 3D computerized simulation of the project's area of impact with
selected resources digitized would give the Lead Agency, Involved
25 63 Byrne, Tatyana Agencies, and the public a better understanding of the project's impacts.
Due to the scale of the project, it is virtually impossible to assess the
project's impacts through GIS maps, line of sight cross sections, and photo
simulations alone.
The decommissioning process is inadequate. Watertight policies must be
put into contract form which ensures that sufficient funds are available to
dismantle and remove the complete project and to restore the land to its
25 64 Byrne, Tatyana original condition before the FEIS is accepted. Additionally, triggers need to
be set to clearly provide parameters under which a decommissioning
process must occur. The citizens of the town must then be given sufficient
time and opportunity to review and comment on the revised process before
the FEIS is signed.
I urge the Lead Agency to insist upon nothing short of full bonding for
25 65 Byrne, Tatyana performance, payment, public improvements, and decommissioning. You
will need to figure out how that bonding follows to successive owners,
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because the IRS tax structure for wind turbines is a huge incentive to sell
the project every two years.
I am concerned that the maximum power generation of the wind farm will
25 66 Byrne, Tatyana come close to the transmission capacity and the impact that will have on
future power requirements for the area.
SLWF has concluded that the transmission line on which the project would
25 67 Byrne, Tatyana interconnect has limited capacity, which limits a larger project. In that case,
they are blocking other power generators (bio/solar) from generating power
unless they pay to increase the capacity of the transmission line.
25 68 Byrne, Tatyana The DEIS states that the project will augment local electricity supply. Is this
a true statement?
Neither the DEIS or the Supplemental discuss the Comprehensive Plan
25 69 Byrne, Tatyana adopted by the Town and how the project will fit into the goals set forth in
the plan. The discussion should include potential impacts to the scenic
byway and tourism in the area.
The Planning Board in their 11 July 2007 letter to SLWF in paragraph 6
25 70 Byrne, Tatyana asked that SLWF work with BP on the transmission line and asked that any
response by BP be provided to the Planning Board. That response belongs
in the Supplement but is not provided. Why not?
25 71 Byrne, Tatyana asked that SLWF produce a revised visual impact study based upon the
new project map. They asked that seven specific locations be included.
That response belongs in the Supplement but is not provided. Why not?
25 72 Byrne, Tatyana asked that SLWF include measures of commercial and pleasure watercraft
in the background ambient sound measurement. There are no such
measures in Supplemental Appendix L1 and L2. Why not?
25 73 Byrne, Tatyana asked that SLWF meet with Cape Vincent Fire Department and work out an
emergency fire and ambulance response plan. Why isn't it included in
Appendix B Emergency Response Plan?
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There are many variables that could impact the number of turbines you can
25 74 Byrne, Tatyana site in the Project Area. What is the number that keeps the project
commercially viable?
26 1 Cullen, Geoffrey I wish to express my profound concern regarding the proposed SLWF. I
have reviewed the SDEIS and feel it is inadequate.
26 2 Cullen, Geoffrey One only has to look across the river to Wolfe Island to see how radically
and permanently the landscape will be changed.
Property values will inevitable suffer if this project moves forward. What
26 3 Cullen, Geoffrey compensation is planned for those of us who will not have turbines but will
see a drop in our home and property values?
While I firmly believe in renewable energy, I also feel there are other more
26 4 Cullen, Geoffrey compelling issues to consider. The SDEIS is not adequate. The setbacks
are too low. I request that you reject the SDEIS.
I frequently drive through the town of Cape Vincent. I feel Cape Vincent is
not the right community for wind turbines. The roads and fields are lovely
27 1 Daub, Patricia and are to be protected as rural landscapes with historic preservation stone
farmhouses and old barns under the New York State preservation laws.
Input under the SEQR process has been inadequate.
28 1 Docteur, David asked that SLWF work with BP on the transmission line and asked that any
28 2 Docteur, David asked that SLWF produce a revised visual impact study based upon the
28 3 Docteur, David asked that SLWF include measures of commercial and pleasure watercraft
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28 4 Docteur, David asked that SLWF meet with Cape Vincent Fire Department and work out an
28 5 Docteur, David site in the Project Area. What is the number that keeps the project
Docteur, Dennis and Comments expressing support for the project and the Town Board's
29 1
Donald decisions. Comments requesting approval of the project not be delayed.
Comments supporting the project and objecting to information presented by
30 1 Docteur, Lee a vocal minority that has been opposed to the project. Comments
expressing the positive net benefits of wind power. Please do your civic
duty to uphold the rights of the majority.
31 1 Docteur, Mary cumulative effect on Indiana bats than the wind energy development. What
Indiana bats?
31 2 Docteur, Mary 4.1.11.2 Since the housing market has changed so dramatically since 2007
current?
31 3 Docteur, Mary - 1500 feet from Village of Cape Vincent boundary line
31 4 Docteur, Mary 7.6 Table 7-1. What compensation are the three non-participating
31 5 Docteur, Mary Appendix E. The avian and bat study was conducted in one year. Why
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31 6 Docteur, Mary Appendix E1. The bat studies were done with radar. Why not also sonar?
31 7 Docteur, Mary July Aug 2007 1.0 states that six captures Indiana bats were radio tracked
31 8 Docteur, Mary Appendix E3 is labeled Blanding Turtle but reports on bats.
31 9 Docteur, Mary Appendix E7. Which of the Blanding Turtle mitigation recommendations will
be adopted and which will not and why note?
31 10 Docteur, Mary Appendix J. What will you do to mitigate shadow flicker if your analysis is
wrong?
31 11 Docteur, Mary Appendix L. The data in Table 2.2.1 does not match the data from our paid
31 12 Docteur, Mary Appendix L.3.6 The negative impacts of low frequency sound are dismissed
31 13 Docteur, Mary Appendix N2. Who pays to mitigate the loss of TV signals in the project
area?
The SDEIS should not be accepted as written. There are too many issues
32 1 Docteur, Paul pertaining to the health, safety, and welfare of all residents of the
community. Over the past couple of years, many of us have learned a great
deal about the effects of noise and its effects on our health.
Shadow flicker also can have a very detrimental effect on our health as well
32 2 Docteur, Paul as safety issues. My wife is plagued with benign positional vertigo. It is
impossible for her to drive through the turbines on Route 177, making
setbacks a very important issue.
32 3 Docteur, Paul The other issue of importance is the Conflict Resolution Board. This cannot
be controlled by the wind company.
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Mr. Reinbeck, as our Supervisor, you are in charge. Put an end to this
hostile sell out of this most beautiful and historical part of the world.
32 4 Docteur, Paul Implement a two year moratorium immediately. Put together a legitimate
steering committee, which will document a zoning law for turbines, to clarify
it if can occur with our already accepted comprehensive plan.
The Blanding Turtle study conducted by SLWF is flawed. Results show only
one turtle found in 2005 and one in 2007. We gave permission to the
NYSDEC to study Blanding Turtles on our property during 2007 and 2008.
Numerous Blanding turtles have been found on our property in the
wetlands, farm pond and resting in hayfields. We have seen many crossing
Estelle, Douglas and the street from our property to the wetlands which continue on the opposite
33 1 side of the street. In addition, numerous Blanding turtles have been found
Michelle
on our neighbor's property, Francis & Brenda Aubertine, on Pelo Road.
The study was conducted when there wouldn't be much movement by

turtles, in mid-November. They even state that the active time for Blanding
turtles is in June, so why did they do it in winter? This is why it is so
important for the Town to do their own studies.
Freislich, John and Comments expressing concern regarding affects of the project, shadow
34 1 flicker and noise in particular, on existing health problems, fibromyalgia and
Michelle
Graves Disease.
The potential sleep disruption from turbine noise has me generally
concerned. The noise study is flawed. First, why should there be no sound
meters along the river from Burnham Pt to Sand Bay? The bulk of the
dwellings are located along the river on both sides of 12E as you well know.
Freislich, John and Why would the only location be at Wood's Farm? They are a participant so I
34 2 fail to see how this would be representative of the effect on the bulk of the
Michelle
populace. Why did the Planning Board not challenge the lack of additional
data affecting the populated areas? Secondly, the length of time spent
studying the ambient noise is laughable if it wasn't so serious a factor.
Seventeen days? One of the most critical issues and that was the total
winter test duration?
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Why was no measuring device placed at the school? Why no devices near
Beadles Pt, Millen's Bay, or further west near the trailer parks? Why did the
Town of Cape Vincent not hire an independent firm to conduct this critical
research?
Freislich, John and This SDEIS does nothing to guarantee that there will be no impact on my
34 3
Michelle quality of life.
35 1 Doull, Melodee is generating please explain how wind power eliminates pollutants and
35 2 Doull, Melodee takeaway lines and what level of maintenance priority will these roads have
35 3 Doull, Melodee I am concerned that there are no safety measures to ensure children don't
35 4 Doull, Melodee The assumptions used to complete the DEIS/Supplemental are not listed.
35 5 Doull, Melodee that governs the application and decision-making process for the special
35 6 Doull, Melodee layout, elevation drawings indicating all major equipment, architectural
35 7 Doull, Melodee Agencies, and the public a better understanding of the project's impacts.
simulations alone.
35 8 Doull, Melodee The decommissioning process is inadequate. Watertight policies must be
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original condition before the FEIS is accepted. Additionally, triggers need to
the FEIS is signed.
performance, payment, public improvements, and decommissioning. You
35 9 Doull, Melodee will need to figure out how that bonding follows to successive owners,
35 10 Doull, Melodee come close to the transmission capacity and the impact that will have on
35 11 Doull, Melodee interconnect has limited capacity, which limits a larger project. In that case,
35 12 Doull, Melodee The DEIS states that the project will augment local electricity supply. Is this
a true statement?
35 13 Doull, Melodee adopted by the Town and how the project will fit into the goals set forth in
Concerns regarding impacts to aquifer providing water to spring off of
Mason Road as a result of possible blasting for wind turbine footings in the
36 1 Henchy, Harold general vicinity of the spring. What is the plan of the Town to provide water
to my home in a timely manner, within 24 hours, if the aquifer is
compromised?
37 1 Hetzler, Eileen Concerns regarding the impact of the project on property values and
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existing tourism from visual impacts.
Concerns regarding the impact of the project on property values from visual
38 1 Hetzler, Stephen impacts. Also concerns that the escrow for the warranty of the wind turbine
generators would more than likely be used up before the warranty period is
over.
Concerns that there has not been sufficient time for public review of the
39 1 Hirschey, Urban SDEIS. The SDEIS was submitted over 2 years after the DEIS and is twice
as long yet public was given only half the time to review and make
comments.
Concerns regarding the cumulative impacts from the BP Cape Vincent
project, as well as the proposed, dormant PB application for a project in
Lyme which would also share the same transmission line. Also, the
39 2 Hirschey, Urban Alternatives Section Table 7-1, states that the 53-turbine project will
encompass 7849 acres. This amounts to 148 acres per turbine and if you
include the 140 turbines of BP that would total over 28,000 acres which
amounts to 88% of the mainland area of the Town of Cape Vincent.
Concerns regarding the adequacy of the ice shedding discussion in the
SDEIS, specifically the lack of an ice shedding study and relevance of the
existing research referenced in the discussion.
The Morgan, Bossani, and Siefert 1988 study calls for ice studies to be
completed in three stages. An estimate should be made of the time
(number of days per year) during which icing conditions occur at the turbine
40 1 Hludzenski, Kathryn site:
- "heavy icing" more than 5 days, less than 25 days icing per year
- "moderate icing" more than 1 day, less than 5 days icing per year
- "light icing" less than 1 day icing per year
- "no icing" no appropriate icing conditions occur
Also, the report is now old. Since it was written, many cases of injury from
turbine ice shed have been documented. For example,
http://www.caithnesswindfarms.co.uk/fullaccidents.pdf.
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Concerns that the Cape Vincent Indiana bat studies are insufficient.
The length of time may not be sufficient to determine bat presences

because weather conditions changes from year to year and this could affect
bat activity. The Cape Vincent test was done in July/August 2007 but is not
clear on how many days were spent in the field and under what conditions.
41 1 Hludzenski, Kathryn Sampling was done in July and August but the report for the Horse Creek
Wind Farm in neighboring Clayton, New York trapped their first bat on June
2 and after July 31st capture rates significantly decreased. Depending on
when the Cape Vincent studies were done, this may have had an effect on
the results also.
The study did not do thermal imaging or use acoustical radar. The Indiana
brown bat is difficult to distinguish from the little brown bat therefore
additional mist net surveys are needed during spring and fall migration.
Concerns regarding cumulative impacts from the several wind projects in
the area: operational Wolfe Island project (86 turbines), Horse Creek in
41 2 Hludzenski, Kathryn Clayton (62 turbines), Galoo Island (77 turbines), BP's Cape Vincent wind
project (140 turbines), and the SLWF (53 turbines). All for a total of 418
turbines within a 25 mile radius of the Indiana bat hibernacula in Glen Park,
New York.
Concerns regarding mortality to Indiana bats from the wind project, from
fragmenting its habitat and destroying its foraging ground and pressure
changes that spinning blades have on the lungs of bats. A more extensive
41 3 Hludzenski, Kathryn study is necessary to know how many Indiana bats are actually in the area
and the impact the project would have. Not only do I think that the bat
studies are inadequate, but I think that due to the plight of the Indiana bat
and the sensitive nature of the area, the project should not be in Cape
Vincent.
41 4 Hludzenski, Kathryn Were the transmission line routes also included as part of the area being
tested?
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42 1 Hubbard, Sandy they are migrating? How long do they stay in Cape Vincent? When do they
42 2 Hubbard, Sandy Impacts of shadow effect on wildlife should be part of the DEIS.
42 3 Hubbard, Sandy Individuals, guides, and town must be compensated if towers result in loss
42 4 Hubbard, Sandy SLWF needs to establish who the environmental monitor works for and how
42 5 Hubbard, Sandy during the following construction [sic], environmental considerations to be
42 6 Hubbard, Sandy It is important to know the impacts of shadow effect on the fish in the water.
42 7 Hubbard, Sandy major springs and their use or flow prior to construction. I would like to see
42 8 Hubbard, Sandy The project may require an Article 24 Freshwater Wetland Permit and
42 9 Hubbard, Sandy come up with proposals around the state, it would seem appropriate to
42 10 Hubbard, Sandy the project not performed as part of the DEIS. The DEIS should be updated
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comment.
42 11 Hubbard, Sandy years of intense further studies of many groups before any consultation of
value may be drawn.
42 12 Hubbard, Sandy on Pleasant Valley Road? How will it be affected? What does Audubon
say?
42 13 Hubbard, Sandy The lease with SLWF takes away landowners' constitutional rights to sue
42 14 Hubbard, Sandy properly during construction to limit the impacts to surface waters,
42 15 Hubbard, Sandy Chaumont Barrens and Three Mile Creek will not be impacted by the
project.
42 16 Hubbard, Sandy information should be included in the report along with a discussion of
42 17 Hubbard, Sandy establish [sic] the St. Lawrence Wetland and Grassland Management
SLWGMD.
42 18 Hubbard, Sandy (2007) be considered by the project sponsor in siting the project features
[sic].
42 19 Hubbard, Sandy Section 3.3.6 NYS Fish and Wildlife found insufficient data exists to
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project.
42 20 Hubbard, Sandy comprehensive manner. The DEIS states that additional data on wildlife
The Complaint Appeal Procedure states that the Complaint Resolution
Board shall consist of three members: an SLWF designee, a Town Officer
or Employee appointed to the position annually, and an independent third
party expert."
Since the appeal procedure follows the original complaint which "SLWF will
make every reasonable effort to resolve" it does not make any sense that
SLWF would also be included in an appeal board. If they had resolved the
43 1 Jury, Charles complaint in the first place the appeal would not be necessary.
The appendix also states "in making such decision, the Complaint
Resolution Board shall take into account the terms and conditions of the
special use permit and approved site plans, and shall not require any
resolution that is inconsistent with such terms." This seems to say that as
long as the permit and site plans are approved there is no way any
complaint will be heard. This statement should be eliminated from the
SDEIS.
Regarding the TV analysis and the statement that TV programming by
alternative means can be offered to mitigate the issue of loss of coverage,
who will determine whether there is a problem and who will pay for the
44 1 Jury, Ellen alternative method? It should also be noted that cable TV is not available to
all areas of Cape Vincent and that DBS does not offer all local channels.
These local channels are necessary for local news, emergency information,
weather alerts, school closings, security alerts, etc.
45 1 LaMora, David Concerns regarding conflict of interest of the Planning Board members in
reviewing the SLWF. A majority of the Planning Board, which I believe
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illegally voted itself Lead Agency for this process, have prohibitive conflicts
of interest, which you refuse to acknowledge or seek an authoritative
decision on in the best interest of this community.
Further information is necessary to substantiate the conclusion that the
wind project will have a positive benefit to air quality. In many cases, the
45 2 LaMora, David existing plants that provide electricity at a much higher efficiency level do
not shut down when wind-generated power is being substituted; they
merely redirect their energy source so it is available to ramp up with the
wind stops blowing.
The visual impacts from the project are enough to prevent acceptance of
45 3 LaMora, David the SLWF on the basis of the zoning law, which specifies that if any
deleterious effect cannot be mitigated then the subsequent site plan review
must be disapproved.
The SLWF is not compliant will all town zoning and land use regulations
because the project does not comply with the Comprehensive Plan, which
guides all land use laws in Cape Vincent. The Plan states that one of its
45 4 LaMora, David goals is to encourage development that minimizes any negative impact on
the natural vistas and scenic landscapes. This is in complete contradiction
to the claim SLWF makes that this project complies with all land use
regulations by its own admission that it cannot mitigate the visual impact of
these turbines.
In Section 3.5.1.3 this report states that turbine locations and other project
components will conform to setbacks and standards required by the Town
Planning Board in response to public comments on the SLWF DEIS. These
setbacks and standards are not legitimate validated criteria for site plan
45 5 LaMora, David review. According to the Cape Vincent Zoning Law all zoning criteria must
be legislated by the Town Board. Stipulating that these standards must be
conformed to is an illegal attempt to circumvent the proscribed legislative
process and cannot be allowed to guide the SEQR process. The planning
board must not allow this, since these criteria would not hold up to a
challenge by either the developer or a dissenting landowner.
45 6 LaMora, David The noise analysis has flaws. Why were 5 to 6 testing locations chosen
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only at participating properties? They should have tested at non-
participating properties, because impacts to non-participating residents
should be evaluated. Also, the equipment used to collect the data was not
suitable for sever winter weather and didn't provide a statistically adequate
percentage of raw data.
My final comment concerns the complaint resolution process. It is obvious
that even though they go to great lengths to detail every impact and
describe what they consider a suitable mitigation for each impact, they are
certain that the criteria suggested to site this project are inadequate to the
extent that it will require a sophisticated and complex complaint resolution
process to deal with noncompliance. I believe it is inherent in the biased
45 7 LaMora, David unwillingness of the Town Board and Planning Board to significantly restrict
this development that will lead to this compliance nightmare. The final insult
to the residents of Cape Vincent is the proposed makeup of SLWF's
resolution board. If it is true that we require resolution beyond what the
Zoning Board of Appeals can provide then the process should not be
determined by the developer and certainly not controlled by them to the
extent they propose. A resolution board should be designed and controlled
by members of the community just as any zoning regulations should be.
If this Supplemental Study is approved by this Planning Board, it will do
nothing but illuminate the severity of the bias produced by the conflicts of
45 8 LaMora, David interest prevalent in this government. I sincerely hope you will consider the
ramifications of approving this document and instead will either ask for
another Supplemental Review of halt the process until this community can
resolve some of these issues for ourselves.
The wind turbine setbacks are in violation of several paragraphs under
46 1 Leschord, Paul Article I, Section 115 of the Cape Vincent Planning and Zoning Introductory
Provisions. Setbacks should be examined in miles, not feet. Anything else
creates visual impacts.
Concerns regarding the cumulative impacts from both Cape Vincent and
47 1 LeTendre, Gerard the other proposed project on wildlife. The SDEIS does not adequately
address this and does not have adequate studies of impacts to wildlife.
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We had deep rooted problems in attempting to resolve the wind tower issue
in this town. The Town Board is conflicted as is the Zoning Board (including
47 2 LeTendre, Gerard the Chairman). These people that have little or no biological training are
making decisions favoring the developer that will affect the town drastically
in the future. Favorable decisions are often rendered no matter how poor or
wrong the information is that is provided.
The bird and turtle studies are inadequate and never even develop an
accurate portrayal of the various populations as they exist today. The
47 3 LeTendre, Gerard developer fills many pages with information about other wind farms that
don't apply to Cape Vincent and then neglects local information such as the
data generated in the 1980 and 1984 NYS Breeding Bird Atlas.
Blanding Turtles: The developer and paid consultants have been unable to
determine where the turtles exist in town so they have no idea of population
size. Yet, they want us to believe that once the wind towers are in place the
47 4 LeTendre, Gerard turtles will survive. Additional effort is required to locate this species. Once
location and numbers are known they can move forward and determine
possible adverse effects and develop a wind turbine placement plan that
will avoid the turtle habitat or mitigate the problem.
Bats: Studies have been completed. Several Indiana Bats were captured in
2006, but in the SDEIS there is no report of follow-up studies on the Indiana
Bat. The studies done are too narrow in scope and avoid review of such
problems as white nose syndrome and how that relates to expected
47 5 LeTendre, Gerard mortality rates caused by wind tower blades. Much more and better
information is necessary in order to mitigate turbine mortality of bats. Cape
Vincent is near the Glen Park, NY hibernaculum and at least 3 years of
sound pre-construction bat studies should be required to learn how the
wind towers will effect the various populations of bat species.
Hawks: The studies done to date are minimal. A case in point is the
Northern Harrier that is NYS threatened and not adequately studied. These
47 6 LeTendre, Gerard birds nest in our town and will require protection. Acciona consultants are
not providing population status and no mitigation to protect species can be
applied at this time. Other hawks such as rough-legged, sharp-shinned,
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coopers and American kestrel depend on areas such as Cape Vincent for
their survival. Rough-legs require over-wintering habitat while the other
three species successfully nest here. The fact that all local hawks are
stressed means more and better studies are required.
Owls: Cape Vincent habitat is of particular importance to short-eared owl
survival. It is inconceivable that people hired to study birds in the Acciona
wind tower area never even located one! The developer either hired
unqualified people to collect bird data or they simply don't care. I have
47 7 LeTendre, Gerard personally shown short-eared owls to many bird watchers and nature lovers
that visited the area in recent years. Yes, they are here and require
protection from wind towers. The developer has not located the species and
therefore is unable to determine the number of short-eared owls present.
Once they know where the owls are and how many they can begin the
process of mitigating potential damage. Several years will be required.
Migrating Birds: The studies of migrating birds are especially poor. The
counters are not able to identify ducks and geese in flight and this is
compounded by short study times and too few counts. Information is
required on all bird migration and what can be done to avoid collisions.
Wind tower siting should not be anticipated until this is completed.
Note: In 2005, I spent one May morning watching birds on Gosier Road in
Cape Vincent. This site is the Acciona footprint. Large numbers of ducks
47 8 LeTendre, Gerard and geese were migrating north and I decided to make an impromptu
count. Over 20,000 ducks and geese were counted that morning. Of these,
over 1,000 were Snow Geese, a few hundred were Mallard Ducks and
approximately 19,000 Canada Geese were tallied. This was in a one mile
wide area that I selected because they were outside the count area. I
believe that more birds migrated through the area that morning than were
represented in all studies conducted and reported in the DEIS and the
SDEIS.
Breeding Birds: This study should start from scratch. A good place to start
47 9 LeTendre, Gerard is the 2000 to 2004 New York State Breeding Bird Atlas. Major problem
identified in bird studies: Adequate bird studies can't be completed unless
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you have competent bird counters that can identify birds by site and sound.
Counts of hawks, owls, ducks, geese, gulls, and songbirds were all poorly
done and should be expanded and repeated.
Invasive Plants: The disturbed earth created by wind farm construction will
compromise the ongoing swallow-wort control effort in the entire Town of
Cape Vincent. This invasive species is being controlled with funding by
47 10 LeTendre, Gerard NYS at the present time. There is no specific mention in the SDEIS of this
control effort which is funded for two more years. Stopping the possible
spread of swallow-wort and other invasive species should be given high
priority. Methodology for implementing this stoppage must be developed
prior to wind tower approval.
Noise: The noise issue is the most interesting and confounding issue of the
Cape Vincent wind tower sites. The developer hired a consultant (Hessler)
that appears to know exactly what decibel levels are required for maximum
placement of wind towers. Amazingly, the data provided by this consultant
came out at just the proper level for maximum wind tower placement.
This information on decibel background levels and the methodology
Hessler used is being challenged by several noise experts. I believe the
47 11 LeTendre, Gerard consultant hired by the Town of Cape Vincent (Cavanaugh Tossi
Associates Inc) came up with lower decibel background levels. It is
imperative that the Town Board and Zoning Board members get this right
because all the residents will be affected by the noise levels.
In addition to the consultant Cape Vincent hired, another consultant was
hired (Shomer and Associates) and neither of these (Shomer or
Cavanaugh) agreed with the results produced by Hessler. Paul Carr, a local
noise expert, also does not agree with Hessler.
Request for a moratorium of at least 12 months to investigate and
determine if this project is safe for the town. The issues of accurate
LeTendre, Jerry and measurement of ambient noise levels, nighttime noise levels affecting
48 1
Judith sleep, project effect on our water supplies, shadow flicker effects, migratory
bird impact, and the dominant visual impact of 390 foot tall turbines on our
landscape need to be resolved.
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49 1 Macura, David Will the geotechnical investigation, necessary for project construction and
3.1.3.3 In this paragraph, SLWF does not mention the use of an
49 2 Macura, David activities it is important that an environmental monitor be onsite for all pre-
49 3 Macura, David 3.2.3.3 The discussion on soil is too general. Each turbine site, access
49 4 Macura, David 3.4.2 Will the comprehensive transportation study, delivery routes, and
49 5 Macura, David which is already out of compliance with EPA guidelines. What is the impact
49 6 Macura, David responsibility of the Applicant and would be undertaken at no expense to
continue.
49 7 Macura, David Bossanyi, and Siefert, 1998) is an 11-year old study. Why aren't you using
a more recent one?
50 1 Macura, Joan Why not bury the overhead lines in the farmland?
50 2 Macura, Joan Will the cable depth be 24" or 6" below the soil surface?
50 3 Macura, Joan Will nearby well/spring info be included in the FEIS? Are there any plans to
provide potable water to citizens if well problems occur?
50 4 Macura, Joan How will concrete be handled during construction?
50 5 Macura, Joan Why not identify final overhead transmission line right-of-way pre-
construction?
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50 6 Macura, Joan Why doesn't it include long-distance transmission lines? What is the plan to
ensure sufficient funds? How will bonding follow to successive owners?
51 1 Mahrer, Carolyn Request for 12 month moratorium to investigate project safety.
Mahrer, Michael and Request for more time to review impacts and 1 year moratorium.
52 1
Susan
Mason, Elaine and Expressed support of the project.
53 1
Paul
54 1 Metzger, Donald Request for 30 days of public comment period
54 2 Metzger, Donald What is the second of the two alternative pathways? If second pathway is
taken, what are the steps involved?
54 3 Metzger, Donald Discuss decommissioning overhead collection lines. Confusion and
skepticism over decommissioning process.
54 4 Metzger, Donald Confusion regarding decommissioning concrete foundations.
54 5 Metzger, Donald Overhead transmission line shares same right-of-way with water line -
potential issue?
54 6 Metzger, Donald Request for testing of stray voltage every 6 months.
54 7 Metzger, Donald Who appoints the Complaint Resolution Board Town Officer member?
What town is represented?
54 8 Metzger, Donald Request for pre- and post-construction tests for signal quality.
54 9 Metzger, Donald Request for Saratoga Associates to apologize for calling community "late
risers."
54 10 Metzger, Donald Request for testing of all wells within 500' radius of turbines.
54 11 Metzger, Donald Expressed concern over cumulative effects of overall project.
55 1 Metzger, Donald Same as comment letter #54
56 1 Moehs, Charles Request public health/medical impact research
56 2 Moehs, Charles Request for mitigation of impacts through setbacks if impacts exist
57 1 Radley, Jerry Will people want to come to the area if they see turbines everywhere?
57 2 Radley, Jerry How will turbines affect child and adult health?
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57 3 Radley, Jerry Request for more research on wildlife.
57 4 Radley, Jerry Will turbines decrease property values? Will industrialization affect
seasonal residents?
58 1 Radley, Pattie Marie Expressed support of the project.
Reed, Alfred and Turbine #38 will decrease property value.
59 1
Maria
Reed, Alfred and Noise from turbines #38 and #39 will affect their way of life.
59 2
Maria
60 1 Ross, Pat Request for 12 month moratorium to investigate project safety.
61 1 Ryon, Doug Expressed concern over visual effects of overall project.
62 1 Schneider, Clifford Maps showing non-resident receptors are inadequate.
62 2 Schneider, Clifford Request for new survey that represents background noise for non-
participating residents.
62 3 Schneider, Clifford References to LEQ noise metrics in SEQR should be struck.
62 4 Schneider, Clifford Request to conduct another background survey using more representative
monitoring sites and incorporate recommendations from Town's consultant.
62 5 Schneider, Clifford Request to conduct project layout and impact analysis that assumes 26
dBA background sound along with the NYSDEC noise impact allowance.
62 6 Schneider, Clifford Provide details on source levels presented in Table 3-30.
62 7 Schneider, Clifford Request to recast analysis using 31 dBA as critical operational design level.
62 8 Schneider, Clifford Request to correct the ground absorption coefficient.
62 9 Schneider, Clifford Request to adjust model analysis (including setbacks) that will reduce
predicted noise levels by 5 dBA.
62 10 Schneider, Clifford Request to adjust siting plan to ensure non-participating residences will not
have noise impacts that exceed state guidelines.
62 11 Schneider, Clifford Provide siting plan and design level based on 31 dBA impact contour for
Project only noise addition.
62 12 Schneider, Clifford Remove comments and opinions that diminish importance of State
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guidelines.
62 13 Schneider, Clifford Increase the setback from the nearest offending turbines to reduce noise
impacts.
62 14 Schneider, Clifford Complaint Resolution Board Town Officer membership appointment issues.
62 15 Schneider, Clifford SLW Noise Impact Assessment - Provide measures of background noise
based on more conventional standards.
62 16 Schneider, Clifford SLW Noise Impact Assessment - Issues with background sounds -
misrepresentation of summertime noise levels.
62 17 Schneider, Clifford SLW Noise Impact Assessment - Van Der Berg references impacts would
be 15-18 dBA higher than expected.
62 18 Schneider, Clifford Noise Modeling Methodology - Request to re-do noise modeling
62 19 Schneider, Clifford Model Results - Redesign the layout plan accounting for background levels
at least 10 dBA lower than provided.
63 1 Schoeberlein, Donna Expressed concern over human and environmental health effects of project.
Requested more time to determine health effects.
63 2 Schoeberlein, Donna Who will purchase more expensive form of energy? What will this project
do to tourism revenue?
64 1 Simpson, Carol What is cumulative impact of both White Nose Syndrome and continued
human encroachment?
64 2 Simpson, Carol A more recent housing value impact study should be done due to the recent
changes in the housing market.
64 3 Simpson, Carol Are the listed setbacks correct?
64 4 Simpson, Carol Compensation for non-participating residents with noise over 40 dBA?
64 5 Simpson, Carol Why not multi-year study?
64 6 Simpson, Carol Are there Indiana Bats within the project area? If so, mitigation?
64 7 Simpson, Carol Appendix E3 is labeled "Blanding Turtles" but is about bats.
64 8 Simpson, Carol Appendix E7 - Which of the mitigation efforts for Blanding Turtles will be
adopted, which not?
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64 9 Simpson, Carol Appendix J - if analysis is wrong, what will be done to mitigate?
64 10 Simpson, Carol Appendix L - The negative impacts of low frequency noise are dismissed.
Where is the medical data?
64 11 Simpson, Carol Appendix N2 - who pays to mitigate loss of TV signals?
65 1 Simpson, Carol The SDEIS should provide specific impacts to specific
threatened/endangered.
What is the potential impact to Northern Harrier? How many breeding pairs
could be affected? Is this a significant portion of the breeding population in
65 2 Simpson, Carol the area? How will the impact be mitigated? What is the range of
reasonable alternatives considered to avoid this species pursuant to
617.9(b)(5)(iv)?
65 3 Simpson, Carol Cumulative Impacts on bird species with regard to Wolf Island
66 1 Steinhouse, Barbara Request for 12 month moratorium to investigate project safety.
Thomas, Carol and Who negotiates PILOT payments for the town?
67 1
Dan
Thomas, Carol and What is the estimated cost per kilowatt hour produced for the first year of
67 2
Dan the project, first 5 years and the first 10 years?
Thomas, Carol and No mention of payment, performance and maintenance bonding. If project
67 3
Dan is not bonded, how will promises be kept?
Thomas, Carol and No Economic Development Impact Model, so it appears the
67 4
Dan socioeconomics section was based on assumptions.
Thomas, Carol and Insufficient documentation to backup project downsizing claim.
67 5
Dan
Thomas, Carol and Since the turbines are a utility, then shouldn't the land be zoned as
67 6
Dan industrial and taxed accordingly.
Thomas, Carol and SDEIS does not address who will compensate business and individuals if
67 7
Dan proposed project results in loss of fishing revenues.
68 1 Uhlig, Bob and Ruth Who is responsible for the safety, repairs, maintenance, and removal of
turbines?
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Organization
What evidence do we have to keep swallow wort from spreading? Will
68 2 Uhlig, Bob and Ruth equipment be power washed when moved from site to site? Will turbines
spread seeds? Will farmers discontinue to plow fields which allows swallow
wort to spread?
68 3 Uhlig, Bob and Ruth Visible damage at Wolfe Island. Will this happen to Cape Vincent?
69 1 Vooder, Linda Request for 12 month moratorium to investigate project safety.
Wiley, Karen and Request for 12 month moratorium to investigate project safety.
70 1
Richard
71 1 Williams, Sharon Request for 12 month moratorium to investigate project safety.
72 1 Williams, Tina Request to set turbines back from roads, views of the St. Lawrence River,
and village.
72 2 Williams, Tina The SEQR process should allow for input from interested parties.
72 3 Williams, Tina Feels the SDEIS is incomplete.
73 1 Grant, Cindy General concerns over health and safety of residents within 2 mile radius of
project.
73 2 Grant, Cindy Believes residents will be harmed by low frequency noise, or infrasound.
Noise should be measured using dBC in addition to dBA.
73 3 Grant, Cindy Project area is highly populated. Other wind farms are in less populated
areas, far enough away so people are not harmed.
Typically industrial wind turbines cause the most disturbance at night, when
73 4 Grant, Cindy the winds at ground level are still but the wind up at the hub height are still
blowing, and the noise from the turbine will be very noticeable in the home.
Noise studies done at an industrial wind project sites after they have been
73 5 Grant, Cindy up and running often show that they are making much more noise than the
developers said they would, but by then it's too late.
73 6 Grant, Cindy Also believes that the residents will be harmed by the shadow flicker effect,
especially people who already suffer from migraines, epilepsy and vertigo.
73 7 Grant, Cindy Believes that large oil companies are not good to do business with, and
residents may never see compensation citing Exxon Valdez as an example.
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Organization
Believes there is also no way that the town of Cape Vincent residents will
ever be able force developer to make right any violations against the
73 8 Grant, Cindy residents that live near this project unless proper regulations are put into
effect now. Before this project is allowed, requests more safeguards in
place now.
Expressed concern over raptor area. States that issues are barely
73 9 Smith, Gerry addressed, and they are not addressed significantly, especially on the part
of the field teams that were out looking at these birds and bats, specifically
short-eared owl. Also, disagrees with breeding bird summary.
73 10 Metzger, Don The SDEIS doesn't state anything about alternative two. What is alternative
two?
The public only gets ten days in which to consider the final Environmental
73 11 Metzger, Don Impact Statement. Believes that ten days to consider a project of this size is
insufficient for the community.
Do the foundations go, the collection cables, the 37 miles of underground
73 12 Metzger, Don collection cables? At one point a depth of 44 inches is used. Believes that's
a misprint.
Concerns about the safety and integrity of the Development Authority of the
North Country's western Jefferson County regional water line, the 12-inch
interior diameter water line that goes for 25 miles from Cape Vincent to
73 13 Metzger, Don Glen Park, serving four towns, five villages, the General Brown School, and
many, many water hydrants. That is a potential -- with the poles there being
set 15 feet into the ground, there is a physical integrity, physical security
problem.
73 14 White, Beth In favor of accepting SDEIS and supports the proposed wind farm.
73 15 Doull, Melodee States that the project is not in compliance with the local zoning ordinance
and land use regulations.
73 16 Doull, Melodee Claims setbacks have not been legally adopted.
73 17 Doull, Melodee Claims downsizing is not enough to mitigate visual impacts.
73 18 Doull, Melodee There is no mention of the transmission lines; there is no mention of secure
3-119
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Agency/
Organization
funds to implement the plan. Will there be bonding? What happens when
the wind farm is sold to another company?
What happens when the wind farm is sold to another company? Will the
73 19 Doull, Melodee new company adhere to the decommissioning plan as described in the
SDEIS?
73 20 Doull, Melodee A mitigation solution would be to increase turbine setbacks in order to
lessen the effects of flicker, noise, and vibration concerns.
73 21 Hirschey, Urban Feels 5 months are necessary for SDEIS comment period.
73 22 Hirschey, Urban Disagrees with separating two (BP and Acciona) Cape Vincent projects.
73 23 Hirschey, Urban Concerned that Lyme project was not considered in projects within 13 miles
of site.
73 24 Ciocci, Theresa Concerns over overall impacts to human health.
73 25 Byrne, John Expressed concern over 5 dB increase in background noise.
73 26 Docteur, David Why is this area even considered when there can be visual and health
impacts? Specifically, disease from vibrations.
Claims a 1,250-foot setback from a nonparticipating residence results in
putting the generating plant practically on top of them and will cause
73 27 Docteur, David intolerable conditions with the shadows, flicker, and noise. Says it is
recommended that there be a one-and-a-half-mile setback, not two-tenths
of a mile.
73 28 Docteur, David Land will become undevelopable. Why does St. Lawrence want to do this?
73 29 White, Kenneth In favor of accepting SDEIS and supports the proposed wind farm.
73 30 King, Gary In favor of accepting SDEIS and supports the proposed wind farm.
73 31 Chapman, Tom Does not feel that wind energy is green energy and does not create jobs.
73 32 Lawrence, Rick Supports the proposed wind farm.
73 33 Johnson, Warren Expresses concern over overhead lines and requests burying lines
underground.
73 33 LeTendre, Jerry Disagrees with SDEIS findings on impacts to birds.
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Agency/
Organization
73 34 Sirianni, Paul Supports the proposed wind farm.
73 35 Clark, John Supports the proposed wind farm.
73 36 Gauthier, Bob Supports the proposed wind farm.
73 37 Mason, Paul Supports the proposed wind farm.
73 38 Kenney, Gail Resident of Wolfe Island warns of negative impacts.
73 39 Brown, Tom Wants to know why other potentially less visually intrusive sites were not
considered.
73 40 Brown, Tom Disagrees with exempting alternative sites.
Disagrees that during operation approximately 48 residences would have a
73 41 Ebbing, Chuck nominal project sound level slightly above the project impact threshold of
60B over the estimated 42 dBA.
Challenges Table 1-1 when it talks about impacts, potential impacts and
73 42 Ebbing, Chuck what they're going to do. Disagrees that the project will not have significant
noise impacts during operation.
73 43 Ebbing, Chuck Challenges overall noise study, claims it is biased.
73 44 Schneider, Clif Challenges overall noise study, says estimate of ambient at 37 dB is about
10 dB high.
73 45 Haskins, Janet Concern over living adjacent to turbines.
Insists that the town and the developer fully give rights under the SEQR
73 46 Bragdon, Brooke law, the National Federal Historic Preservation laws, and other -- the local
zoning law.
73 47 Cullen, Cyril How is decommissioning going to be funded, bonding, no bonding,
deposits, etc.?
73 48 Cullen, Cyril Requests for a moratorium and zoning law.
73 49 Kobylarz, Virginia Climate may not be adequate for wind power.
73 50 Kobylarz, Virginia Concern over migrating birds.
73 51 Kobylarz, Virginia Who is responsible for repair, decommissioning, and restoration?
73 52 Radley, Jarvis Supports SDEIS findings and the proposed wind farm.
3-121
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Agency/
Organization
Requests identification of liability in the case of damages caused by the
73 53 Jolliff, Tom wind farm to persons or property and how they would be handled, such as
by insurance.
73 54 McTaggert, Pat Requests further health studies.
73 55 Boss, Sally Projects turbines will take-up 88% of land mass and requests a moratorium.
73 56 White, Harvey Supports SDEIS findings and the proposed wind farm.
73 57 Chase, Hester Requests clarification on sound/distance relationship.
73 58 Chase, Hester Proposes development of alternatives.
73 59 Falcon, Mary Concerns over red light at night.
73 60 Falcon, Mary Concerns over protecting water during construction.
73 61 Falcon, Mary Concerns over subsidies - feels that citizens will be paying for putting it up
and taking it down.
73 62 Bourquin, Don Supports the Planning Board.
73 63 Bowers, Bert Does not believe 79.5 megawatts of power will be produced.
Production of this clean, renewable energy will not create air or water
73 64 Bowers, Bert pollution or add to greenhouse gases in the atmosphere. This statement
again is totally false as it pretends that industrial wind power can be an
independent stand-alone source of power.
73 65 Bowers, Bert Concern over 10 to 15-decibel sound level increase.
73 66 Falcon, Spencer Concern over psychiatric impact.
73 67 DeLong, Sam Concern over the effect on his vertigo and migraine health conditions.
73 68 Edgar, Chris Supports the SDEIS and proposed wind farm.
73 69 Moehs, Charles Concerns over low frequency noise, cardiac issues, children, elderly, and
learning disabilities, and sees no way of mitigating these issues.
73 70 Metzger, Don Concerns over decommissioning, with regard to long-distance transmission
line that would run to Lyme.
73 71 Metzger, Don Concern over proposed 485 turbines all within 17 miles of the building they
are in.
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Agency/
Organization
Claims there will be a degradation of signal with the cell phone, with the AM
73 72 Metzger, Don radio, with the FM radio, with wireless communication, wireless internet,
issues with the VHF and UHF communication for police, fire, emergency
responders.
73 73 Ciocci, Theresa General health concerns.
73 74 Ciocci, Theresa Asks for liability of damages for both short- and long-term outcomes of
health risks.
73 75 Ciocci, Theresa Concerns regarding sleep deprivation.
Shadow flicker concerns, citing Maine Medical Association results of
73 76 Ciocci, Theresa shadow flicker and noise emissions from turbines on humans living within
3500 feet of industrial turbines
73 77 Schneider, Clif Finds SDEIS exceedances of acceptable noise levels.
73 78 Ebbing, Chuck Concern over night-time noise conditions. Overall concern with noise
study.
Requests ambient noise is measured in the area directly beside each
proposed turbine locations so that you have an accurate noise baseline to
73 79 Grant, Cindy start with and is performed by an independent acoustic engineer that is
chosen by the Town Board but paid for by the developer. Stresses
importance of measuring low frequency noise.
73 80 Grant, Cindy Requests testing of drinking water.
73 81 Grant, Cindy Suggests a buyout clause.
There is no further communication after this letter from Acciona to the
73 82 Bragdon, Brooke State, no follow-up whatsoever in terms of delineating what the adverse
impacts are, and no discussion whatsoever about relocating turbines or
coming up with greater setbacks.
73 83 Byrne, John Questions background noise levels. Feels that noise study is flawed.
What if a well goes dry while blasting for a turbine foundation is done
74 1 various landowners nearby? According to the SDEIS, pre-construction and post-construction
hydrological studies will be conducted to determine if project construction is
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Agency/
Organization
responsible for any wells going dry. But what about the time between the
blasting and the post-construction studies? Will the landowner have to find
an alternative water supply and pay for it out of his own pocket, while
waiting for the post-construction study to be completed?
1
Source 73 represents oral comments received during May 16, 2009 Public Hearing.
3-124
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Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
Alternatives Stilwell, David and Tim Sullivan USFWS 2.44
Alternatives Davis, Andrew NYSDPS 4.50
Alternatives Falcon, Mary 12.10
Alternatives Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 22.2
Alternatives Vail, Alan 26.1
Alternatives Zovistoski, Mary 38.7
Alternatives Hirschey, Urban C. 40.7
Construction Tomasik, Steven for Jack Nasca NYSDEC 1.7
Construction Stilwell, David and Tim Sullivan USFWS 2.3
Cultural Resources Tomasik, Steven for Jack Nasca NYSDEC 1.17
Cultural Resources Davis, Andrew NYSDPS 4.8
Cultural Resources Uhlig, Robert Stone Building Appreciation Society 9.1
Cultural Resources Falcon, Mary 12.5
Cultural Resources Chase, Hester 14.5
Cultural Resources Bragdon, Brooks 18.1
Cultural Resources Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.9
Cultural Resources Gormel, Thomas 31.1
Cultural Resources Gormel, Joyce 33.1
4-2
003778
Table 4-1
Comment
ID 1
Cultural Resources Zovistoski, Mary 38.3
Cultural Resources Hirschey, Urban C. 40.3
Cultural Resources Gregory, Maureen Wiley 50.1
Jefferson County Historical Society,
Cultural Resources Abel, Timothy J., PhD 69.1
Watertown, NY
Cultural Resources Hanson, Rollin V 71.2
Cultural Resources Boss, Sarah F. 79.1
Cumulative Impacts Tomasik, Steven for Jack Nasca NYSDEC 1.2
Cumulative Impacts Stilwell, David and Tim Sullivan USFWS 2.43
Cumulative Impacts Davis, Andrew NYSDPS 4.47
Save the River and 1000 Islands
Cumulative Impacts Caddick, Jennifer and Aaron Vogel 19.1
Land Trust
Cumulative Impacts Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.7
Cumulative Impacts Brown, Thomas 65.2
Cumulative Impacts Gormel, Thomas 95.1
Cumulative Impacts Docteur, David 113.3
Cumulative Impacts Hambrose, Johanna 113.8
Cumulative Impacts Hanson, Rollin V 113.9
Cumulative Impacts Henchy, Harold 113.10
Cumulative Impacts Hludzenski, Ed 113.13
Cumulative Impacts Metzger, Don 113.15a
Cumulative Impacts Schneider, Clifford P. 113.17a
Ecological Resources Tomasik, Steven for Jack Nasca NYSDEC 1.1
4-3
003779
Table 4-1
Comment
ID 1
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.4
Ecological Resources Davis, Andrew NYSDPS 4.16
Ecological Resources Gary, Brianna NYSDEC 6.1
4-4
003780
Table 4-1
Comment
ID 1
Ecological Resources Evans, William R. Old Bird, Inc. 10.1
Ecological Resources LeTendre, Gerard 11.1
Ecological Resources Falcon, Mary 12.2
Ecological Resources Chase, Hester 14.1
4-5
003781
Table 4-1
Comment
ID 1
Ecological Resources Caddick, Jennifer and Aaron Vogel 19.2
Land Trust
Land Trust
Ecological Resources Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.1
Ecological Resources Faulknham, R. Dennis 24.2
Ecological Resources Gormel, Thomas 29.1
Ecological Resources Gormel, Joyce 34.1
Ecological Resources Hirschey, Urban C. 43.1
Ecological Resources Liner, Jillian M. Audubon New York 47.1
Ecological Resources Gregory, Maureen Wiley 53.1
Ecological Resources Duehkind, Winnie 63.1
Ecological Resources Walker, Tom and Mabel 64.1
Ecological Resources Brown, Thomas 65.1
Ecological Resources Crossby, William and Barbara 68.1
Ecological Resources LaPlante, J.O. 70.1
Ecological Resources Article: Los Angeles Times 70.4
Ecological Resources Boss, Sarah F. 79.6
Brown, Thomas; R. Dennis
Ecological Resources Faulknham, Gerard LeTendre, and 104.1
Clifford Schneider
Ecological Resources Smith, Gerald 109.1
Ecological Resources Docteur, David H. 110.2
Ecological Resources Schneider, Clifford P. 111.7
4-6
003782
Table 4-1
Comment
ID 1
Ecological Resources/Water
Davis, Andrew NYSDPS 4.13
Resources
Resources
Ecological Resources - Threatened &
Tomasik, Steven for Jack Nasca NYSDEC 1.11
Endangered Species
Stilwell, David and Tim Sullivan USFWS 2.38
Endangered Species
Endangered Species
Endangered Species
Endangered Species
Endangered Species
Endangered Species
Facility Layout and Design Stilwell, David and Tim Sullivan USFWS 2.5
Facility Layout and Design Davis, Andrew NYSDPS 4.1
4-7
003783
Table 4-1
Comment
ID 1
Facility Layout and Design Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 7.1
Facility Layout and Design LeTendre, Gerard 11.3
Facility Layout and Design Falcon, Mary 12.6
Facility Layout and Design Chase, Hester 14.12
Facility Layout and Design Petras, Leigh and James 16.1
Facility Layout and Design Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.11
Facility Layout and Design Vail, Alan 26.6
Facility Layout and Design Gormel, Thomas 30.1
Facility Layout and Design Gormel, Joyce 37.1
Facility Layout and Design Zovistoski, Mary 38.5
Facility Layout and Design Hirschey, Urban C. 39.2
Facility Layout and Design Boss, Mark 45.4
4-8
003784
Table 4-1
Comment
ID 1
Facility Layout and Design Boss, Sarah F. 79.5
Facility Layout and Design Cuda, Kenneth 82.1
Facility Layout and Design Brown, Thomas 93.1
Facility Layout and Design Wiley, Karen 99.2
Facility Layout and Design Schneider, Clifford P. 111.1
Facility Layout and Design Byrne, John 113.2a
Facility Layout and Design Metzger, Don 113.15b
Facility Layout and Design Reinhart, Marianna 113.16a
Facility Layout and Design Reinhart, Marianna 113.16b
Facility Layout and Design Simpson, Carol 113.18
General/Miscellaneous Davis, Andrew NYSDPS 4.23
General/Miscellaneous Chase, Hester 14.15
General/Miscellaneous Gaudette, Richard and Jan 15.1
General/Miscellaneous Dziekan, Andrew 17.1
General/Miscellaneous Merchant, Jerry 20.1
General/Miscellaneous Zovistoski, Mary 38.4
General/Miscellaneous Bracket, Mr. and Mrs. Montgomery 46.1
General/Miscellaneous Article: Source Unknown 70.5
General/Miscellaneous Gormel, Joyce 75.3
General/Miscellaneous Pressly, Nicholas 81.6
General/Miscellaneous Bouchard, Gerry and Michelle 84.1
General/Miscellaneous Internet Article: Daily-John.com 90.1
General/Miscellaneous Gormel, Thomas 97.1
General/Miscellaneous Wiley, Karen 99.5
General/Miscellaneous Graf, David 100.1
General/Miscellaneous Callery, Judith Anne 101.1
4-9
003785
Table 4-1
Comment
ID 1
General/Miscellaneous Kemmis, Richard J. 102.1
General/Miscellaneous Brown, Thomas 103.1
General/Miscellaneous Brooks, Colin 107.3
General/Miscellaneous Bragdon, Brooks 108.1
Land Use and Zoning Davis, Andrew NYSDPS 4.30
Land Use and Zoning Chase, Hester 14.3
Land Use and Zoning Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.6
Land Use and Zoning Hirschey, Urban C. 39.3
Land Use and Zoning Walker, Tom and Mabel 64.2
Land Use and Zoning Article: Watertown Daily Times 70.3
Land Use and Zoning Boss, Sarah F. 79.2
Land Use and Zoning Bragdon, Brooks 83.2
Land Use and Zoning Cape Vincent Zoning Law 83.3
Land Use and Zoning - Agriculture Brower, Matthew NYSDA&M 3.1
Land Use and Zoning - Agriculture Davis, Andrew NYSDPS 4.6
Noise Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 7.7
Noise LeTendre, Gerard 11.9
Noise Chase, Hester 14.7
Noise Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.8
Noise Jury, Charles 25.1
Noise Hirschey, Urban C. 43.7
Letter to Editor: Watertown Daily
Noise 94.1
Times
Noise Schneider, Clifford P. 106.1
Noise Article: Utica Observer Dispatch 106.2
4-10
003786
Table 4-1
Comment
ID 1
Noise Letter: NYSDEC 111.9
Noise Schneider, Clifford P. 113.17b
Operations and Maintenance/
Decommissioning
Decommissioning
Physiography, Geology and Soils Macura, Daniel 61.1
Physiography, Geology, and Soils Tomasik, Steven for Jack Nasca NYSDEC 1.12
Physiography, Geology, and Soils Nasca, Jack NYSDEC 5.1
Physiography, Geology, and Soils Hirschey, Urban C. 40.10
Physiography, Geology, and Soils Boss, Sarah F. 79.7
Physiography, Geology, and Soils/
Chase, Hester 14.2
Construction
Construction/Agriculture
Dimmick, Kris Bernier, Carr, and Associates 112.1
Physiography, Geology, and
Soils/Wildlife
Project Purpose, Public Need and
Falcon, Mary 12.7
Benefits
Chase, Hester 14.8
Benefits
Chase, Hester 14.9
Benefits
Gormel, Thomas 27.1
Benefits
4-11
003787
Table 4-1
Comment
ID 1
Gregory, Maureen Wiley 52.1
Benefits
Benefits
Gormel, Joyce 75.6
Benefits
Boss, Sarah F. 79.4
Benefits
Gormel, Joyce 91.1
Benefits
Brooks, Colin 107.2
Benefits
Hirschey, Urban C. 113.12b
Benefits
Project Purpose, Public Need, and
Benefits
Benefits
Planning Board Members Cape Vincent Planning Board 112.2
Benefits
Benefits
Benefits
Benefits
Benefits
Benefits
Recreation Wiley, Karen 99.4
Safety and Security Davis, Andrew NYSDPS 4.46
4-12
003788
Table 4-1
Comment
ID 1
Safety and Security Falcon, Spencer, MD 13.1
Safety and Security Chase, Hester 14.6
Safety and Security Zovistoski, Mary 38.2
Safety and Security Hirschey, Urban C. 40.4
Safety and Security Boss, Mark 45.1
Safety and Security Moehs, Charles, MD, MPH 62.1
Safety and Security Hludzenski, Kathryn A. 67.1
Safety and Security Freislich, Michele L. 73.1
Safety and Security Gormel, Joyce 75.4
Safety and Security Pundt, Art 76.1
Safety and Security Article: Telegraph 88.1
Safety and Security Wiley, Karen 99.6
Safety and Security Haskins, Janet and James 105.1
Safety and Security Docteur, David H. 110.1
Safety and Security E-Mail 110.3
Safety and Security Hludzenski, Ed 113.14
Safety and Security/Facility Layout and
Boss, Sarah F. 79.14
Design
Moehs, Charles, MD, MPH 92.1
Design
SEQR Process Falcon, Mary 12.4
SEQR Process Caddick, Jennifer and Aaron Vogel 19.3
Land Trust
Land Trust
SEQR Process Hanson, Rollin V 71.1
SEQR Process Simpson, Carol 74.1
SEQR Process Gormel, Joyce 75.1
SEQR Process Boss, Sarah F. 79.3
4-13
003789
Table 4-1
Comment
ID 1
SEQR Process Dziekan, Andrew 87.1
SEQR Process Levy, Ann E. 96.1
SEQR Process Drabicki, Judy, Esq. Wind Power Ethics Group 98.1
SEQR Process Nasca, Jack NYSDEC 113.19
Socioeconomics LeTendre, Gerard 11.7
Socioeconomics Caddick, Jennifer and Aaron Vogel 19.8
Land Trust
Socioeconomics Vail, Alan 26.2
Socioeconomics Gormel, Thomas 32.1
Socioeconomics Gormel, Joyce 35.1
Socioeconomics Hirschey, Urban C. 40.2
Socioeconomics Gregory, Maureen Wiley 57.1
Socioeconomics Hludzenski, Kathryn A. 66.1
Socioeconomics Boss, Sarah F. 79.13
Socioeconomics Wiley, Karen 99.1
Socioeconomics Schneider, Clifford P. 111.4
Traffic and Transportation Davis, Andrew NYSDPS 4.26
Traffic and Transportation Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.4
Traffic and Transportation Gormel, Thomas 28.1
Traffic and Transportation Zovistoski, Mary 38.1
4-14
003790
Table 4-1
Comment
ID 1
Traffic and Transportation Hirschey, Urban C. 43.2
Traffic and Transportation Boss, Mark 45.2
Traffic and Transportation Gregory, Maureen Wiley 54.1
Traffic and Transportation Boss, Sarah F. 79.11
Traffic and Transportation/
Construction
Utilities and Community Services Hirschey, Urban C. 39.1
Utilities and Community Services Boss, Mark 45.3
Visual Resources Tomasik, Steven for Jack Nasca NYSDEC 1.13b
Visual Resources Tomasik, Steven for Jack Nasca NYSDEC 1.14
Visual Resources Davis, Andrew NYSDPS 4.39
Visual Resources Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 7.6
Visual Resources Harris, Michael 8.1
Visual Resources Falcon, Mary 12.8
Visual Resources Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.10
Visual Resources Faulknham, R. Dennis 23.1
Visual Resources Zovistoski, Mary 38.6
Visual Resources Hirschey, Urban C. 40.6
4-15
003791
Table 4-1
Comment
ID 1
Visual Resources Gregory, Maureen Wiley 50.2
Visual Resources Doull, Melodee 60.1
Visual Resources Levy, Ann E. 78.1
Visual Resources Gormel, Thomas 97.2
Visual Resources Brooks, Colin 107.1
Visual Resources Schneider, Clifford P. 111.6
Visual Resources Planning Board Members Cape Vincent Planning Board 112.5
Visual Resources Boss, Sally 113.1
Visual Resources Byrne, John 113.2b
Visual Resources Hambrose, Harold 113.7
Visual Resources Hirschey, Sally 113.11
Visual Resources Hirschey, Urban C. 113.12a
Visual Resources/Cultural Resources Bragdon, Brooks 49.1
Visual Resources/Noise Wiley, Karen 99.7
Visual Resources/Recreation/Cultural
Resources
Visual Resources/Safety and Security Chase, Hester 14.16
Water Resources Tomasik, Steven for Jack Nasca NYSDEC 1.3
Water Resources Tomasik, Steven for Jack Nasca NYSDEC 1.13a
Water Resources Stilwell, David and Tim Sullivan USFWS 2.17
4-16
003792
Table 4-1
Comment
ID 1
Water Resources Davis, Andrew NYSDPS 4.15
Water Resources Falcon, Mary 12.1
Water Resources Caddick, Jennifer and Aaron Vogel 19.6
Land Trust
Land Trust
Water Resources Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.2
Water Resources Faulknham, R. Dennis 24.1
Water Resources Macura, Daniel 61.2
Pressly & Associates, Inc., Cherry
Water Resources Pressly, Nicholas 81.1
Valley, NY
Valley, NY
Valley, NY
Valley, NY
Valley, NY
Water Resources Planning Board Members Cape Vincent Planning Board 112.9
1
Comment ID represents a combination of the Comment Letter ID (before decimal) and Comment ID within letter (after decimal) as
identified in Table 3-1.
4-17
003793
Table 4-2
Saint Lawrence Windpower Project SDEIS Response Summary Ordered by Subject
Subject Commenter Agency Comment ID 1
Alternatives Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 11.4
Alternatives Byrne, Tatyana 25.16
Alternatives Docteur, Mary 31.3
Alternatives Metzger, Don 73.10
Alternatives Docteur, David 73.26
Alternatives Brown, Tom 73.40
Alternatives Chase, Hester 73.58
Alternatives/Noise Byrne, Tatyana 25.17
Alternatives/Noise Docteur, Mary 31.4
Climate and Air Quality Stilwell, David USFWS 1.3
Climate and Air Quality Byrne, Tatyana 25.11
Climate and Air Quality LaMora, David 45.2
Climate and Air Quality Macura, David 49.5
Construction Tomasik, Stephen NYSDEC 2.23
Construction Davis, Andrew NYSDPS 4.3
Construction Boss, Mark 16.2
Construction Boss, Sarah 17.4
Construction Byrne, Tatyana 25.2
Construction Hubbard, Sandy 42.4
Construction Macura, David 49.2
Construction Macura, Joan 50.2
Construction Metzger, Don 73.12
Cultural Resources Bonafide, John NYSOPRHP 5.1
4-18
003794
Table 4-2
Cultural Resources Byrne, Tatyana 25.54
Cultural Resources Daub, Patricia 27.1
Cumulative Impacts Tomasik, Stephen NYSDEC 2.3
Cumulative Impacts Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 11.3
Cumulative Impacts Byrne, Tatyana 25.14
Cumulative Impacts Docteur, Mary 31.1
Cumulative Impacts Hirschey, Urban 39.2
Cumulative Impacts Hludzenski, Kathryn 41.2
Cumulative Impacts Metzger, Donald 54.11
Cumulative Impacts Simpson, Carol 64.1
Cumulative Impacts Ebbing, Chuck 73.41
Decommissioning Zappieri, Jeff NYSDOS 3.3
Decommissioning Davis, Andrew NYSDPS 4.21
Decommissioning Boss, Mark 16.6
Decommissioning Bragdon, Brooks 20.3
Decommissioning Byrne, Tatyana 25.6
4-19
003795
Table 4-2
Decommissioning Doull, Melodee 35.8
Decommissioning Macura, Joan 50.6
Decommissioning Metzger, Donald 54.3
Decommissioning Cullen, Cyril 73.47
Decommissioning Kobylarz, Virginia 73.51
Decommissioning Metzger, Don 73.70
Ecological Resources Stilwell, David USFWS 1.1
Ecological Resources Tomasik, Stephen NYSDEC 2.7
Ecological Resources Zappieri, Jeff NYSDOS 3.6
4-20
003796
Table 4-2
Ecological Resources Lyons, Thomas NYSOPRHP 7.5
Ecological Resources Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 11.5
Ecological Resources Evans, William Old Bird Inc. 13.1
Ecological Resources Riley, Thomas Onondaga Audubon 14.1
Ecological Resources Bell, Dolores and Michael 15.1
Ecological Resources Boss, Sarah 17.1
Ecological Resources Byrne, Tatyana 25.18
4-21
003797
Table 4-2
Ecological Resources Docteur, Mary 31.5
Ecological Resources Estelle, Douglas and Michelle 33.1
Ecological Resources Hludzenski, Kathryn 41.1
Ecological Resources Hubbard, Sandy 42.1
4-22
003798
Table 4-2
Ecological Resources Radley, Jerry 57.3
Ecological Resources Simpson, Carol 64.5
Ecological Resources Uhlig, Bob and Ruth 68.2
Ecological Resources Smith, Gerry 73.9
Ecological Resources LeTendre, Jerry 73.33
Ecological Resources Kobylarz, Virginia 73.50
Ecological Resources - Threatened & Tomasik, Stephen NYSDEC 2.19
Endangered Species
Endangered Species
Ecological Resources - Threatened & Simpson, Carol 65.1
Endangered Species
Endangered Species
Facility Layout and Design Stilwell, David USFWS 1.4
Facility Layout and Design Tomasik, Stephen NYSDEC 2.1
4-23
003799
Table 4-2
Facility Layout and Design Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 11.10
Facility Layout and Design Boss, Sarah 18.1
Facility Layout and Design Byrne, Tatyana 25.5
Facility Layout and Design Docteur, David 28.1
Facility Layout and Design Doull, Melodee 35.6
Facility Layout and Design Macura, Joan 50.1
Facility Layout and Design Metzger, Donald 54.5
Facility Layout and Design Grant, Cindy 73.3
Facility Layout and Design Johnson, Warren 73.33
Facility Layout and Design/Alternatives Boss, Mark 16.1
Facility Layout and Design/Alternatives Byrne, Tatyana 25.1
General Davis, Andrew NYSDPS 4.7
General Docteur, Dennis and Donald 29.1
General Docteur, Lee 30.1
Groundwater various landowners 74.1
Land Use and Zoning Zappieri, Jeff NYSDOS 3.1
Land Use and Zoning Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 11.2
4-24
003800
Table 4-3
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Source
Comment
Commenter Agency Date Subject
ID 1
Jefferson County Historical
Abel, Timothy J., PhD 6/4/2007 Cultural Resources 69.1
Society
Article: Los Angeles Times No Date Ecological Resources 70.4
Article: Source Unknown No Date General/Miscellaneous 70.5
Article: Telegraph 5/1/2006 Safety and Security 88.1
Article: Utica Observer Dispatch 3/8/2007 Noise 106.2
Article: Watertown Daily Times 5/31/2007 Land Use and Zoning 70.3
Boss, Mark 6/10/2007 Safety and Security 45.1
Boss, Mark 6/10/2007 Traffic and Transportation 45.2
Utilities and Community
Boss, Mark 6/10/2007 45.3
Services
Boss, Mark 6/10/2007 Facility Layout and Design 45.4
Boss, Sally 3/24/2007 Visual Resources 113.1
Boss, Sarah F. 6/1/2007 Cultural Resources 79.1
Boss, Sarah F. 6/1/2007 Land Use and Zoning 79.2
Boss, Sarah F. 6/1/2007 SEQR Process 79.3
Project Purpose, Public Need
Boss, Sarah F. 6/1/2007 79.4
and Benefits
Boss, Sarah F. 6/1/2007 Facility Layout and Design 79.5
Boss, Sarah F. 6/1/2007 Ecological Resources 79.6
Boss, Sarah F. 6/1/2007 79.7
Soils
Boss, Sarah F. 6/1/2007 Traffic and Transportation 79.11
Boss, Sarah F. 6/1/2007 Socioeconomics 79.13
Boss, Sarah F. 6/1/2007 Safety and Security / Facility 79.14
4-35
003801
Table 4-3
Comment
ID 1
Layout and Design
Bouchard, Gerry and Michelle 3/29/2007 General/Miscellaneous 84.1
Bracket, Mr. and Mrs. Montgomery 6/11/2007 General/Miscellaneous 46.1
Bragdon, Brooks 6/15/2007 Cultural Resources 18.1
Visual Resources / Cultural
Bragdon, Brooks 6/7/2007 49.1
Resources
Bragdon, Brooks 3/24/2007 Land Use and Zoning 83.2
Bragdon, Brooks 6/13/2007 General/Miscellaneous 108.1
Brooks, Colin 3/8/2007 Visual Resources 107.1
Brooks, Colin 3/8/2007 107.2
and Benefits
Brooks, Colin 3/8/2007 General/Miscellaneous 107.3
Land Use and Zoning -
Brower, Matthew NYSDA&M 6/15/2007 3.1
Agriculture
Agriculture
Agriculture
Brown, Thomas 6/4/2007 Ecological Resources 65.1
Brown, Thomas 6/4/2007 Cumulative Impacts 65.2
Brown, Thomas 3/24/2007 Facility Layout and Design 93.1
Brown, Thomas 2/21/2007 General/Miscellaneous 103.1
Brown, Thomas; R. Dennis Faulknham,
Gerard LeTendre, and Clifford 2/24/2007 Ecological Resources 104.1
Schneider
Byrne, John 3/24/2007 Facility Layout and Design 113.2a
4-36
003802
Table 4-3
Comment
ID 1
Byrne, John 3/24/2007 Visual Resources 113.2b
Save the River & 1000 Islands
Caddick, Jennifer and Aaron Vogel 6/14/2007 Cumulative Impacts 19.1
Land Trust
Caddick, Jennifer and Aaron Vogel 6/14/2007 Ecological Resources 19.2
Land Trust
Caddick, Jennifer and Aaron Vogel 6/14/2007 SEQR Process 19.3
Land Trust
Land Trust
Land Trust
Caddick, Jennifer and Aaron Vogel 6/14/2007 Water Resources 19.6
Land Trust
Land Trust
Caddick, Jennifer and Aaron Vogel 6/14/2007 Socioeconomics 19.8
Land Trust
Callery, Judith Anne 2/20/2007 General/Miscellaneous 101.1
Cape Vincent Zoning Law 3/24/2007 Land Use and Zoning 83.3
Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 6/15/2007 Facility Layout and Design 7.1
Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 6/15/2007 Visual Resources 7.6
Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 6/15/2007 Noise 7.7
Chase, Hester 6/15/2007 Ecological Resources 14.1
Chase, Hester 6/15/2007 14.2
Soils / Construction
Chase, Hester 6/15/2007 Land Use and Zoning 14.3
Chase, Hester 6/15/2007 Cultural Resources 14.5
4-37
003803
Table 4-3
Comment
ID 1
Chase, Hester 6/15/2007 Safety and Security 14.6
Chase, Hester 6/15/2007 Noise 14.7
Chase, Hester 6/15/2007 14.8
and Benefits
Chase, Hester 6/15/2007 14.9
and Benefits
Chase, Hester 6/15/2007 Facility Layout and Design 14.12
Chase, Hester 6/15/2007 General/Miscellaneous 14.15
Visual Resources / Safety and
Chase, Hester 6/15/2007 14.16
Security
Crossby, William and Barbara 6/4/2007 Ecological Resources 68.1
Cuda, Kenneth 4/5/2007 Facility Layout and Design 82.1
Davis, Andrew NYSDPS 6/13/2007 Facility Layout and Design 4.1
Davis, Andrew NYSDPS 6/13/2007 General/Miscellaneous 4.3
Davis, Andrew NYSDPS 6/13/2007 4.6
Agriculture
Davis, Andrew NYSDPS 6/13/2007 Soils / Construction / 4.7
Agriculture
Davis, Andrew NYSDPS 6/13/2007 Cultural Resources 4.8
4-38
003804
Table 4-3
Comment
ID 1
Ecological Resources / Water
Resources
Resources
Davis, Andrew NYSDPS 6/13/2007 Water Resources 4.15
Davis, Andrew NYSDPS 6/13/2007 Ecological Resources 4.16
Ecological Resources -
Davis, Andrew NYSDPS 6/13/2007 Threatened and Endangered 4.24
Species
Davis, Andrew NYSDPS 6/13/2007 Traffic and Transportation 4.26
Traffic and Transportation /
Construction
Davis, Andrew NYSDPS 6/13/2007 Land Use and Zoning 4.30
Visual Resources /
Davis, Andrew NYSDPS 6/13/2007 Recreation / Cultural 4.32
Resources
4-39
003805
Table 4-3
Comment
ID 1
Davis, Andrew NYSDPS 6/13/2007 Visual Resources 4.39
Davis, Andrew NYSDPS 6/13/2007 Safety and Security 4.46
Davis, Andrew NYSDPS 6/13/2007 Cumulative Impacts 4.47
Davis, Andrew NYSDPS 6/13/2007 Alternatives 4.50
Dimmick, Kris Bernier, Carr, and Associates 6/28/2007 Soils / Construction / 112.1
Agriculture
Docteur, David 3/24/2007 Cumulative Impacts 113.3
Docteur, David H. 6/9/2007 Safety and Security 110.1
Docteur, David H. 6/9/2007 Ecological Resources 110.2
Doull, Melodee 6/9/2007 Visual Resources 60.1
Drabicki, Judy, Esq. Wind Power Ethics Group 2/12/2007 SEQR Process 98.1
Duehkind, Winnie 6/5/2007 Ecological Resources 63.1
Dziekan, Andrew 6/14/2007 General/Miscellaneous 17.1
Dziekan, Andrew 3/19/2007 SEQR Process 87.1
E-Mail 6/9/2007 Safety and Security 110.3
Evans, William R. Old Bird, Inc. 6/14/2007 Ecological Resources 10.1
4-40
003806
Table 4-3
Comment
ID 1
Falcon, Mary 6/14/2007 Water Resources 12.1
Falcon, Mary 6/14/2007 Ecological Resources 12.2
Falcon, Mary 6/14/2007 SEQR Process 12.4
Falcon, Mary 6/14/2007 Cultural Resources 12.5
Falcon, Mary 6/14/2007 Facility Layout and Design 12.6
Falcon, Mary 6/14/2007 12.7
and Benefits
Falcon, Mary 6/14/2007 Visual Resources 12.8
Falcon, Mary 6/14/2007 Alternatives 12.10
Falcon, Spencer, MD 6/14/2007 Safety and Security 13.1
Faulknham, R. Dennis 6/12/2007 Visual Resources 23.1
Faulknham, R. Dennis 6/12/2007 Water Resources 24.1
Faulknham, R. Dennis 6/12/2007 Ecological Resources 24.2
Freislich, Michele L. No Date Safety and Security 73.1
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/13/2007 Ecological Resources 21.1
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/13/2007 Water Resources 21.2
4-41
003807
Table 4-3
Comment
ID 1
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/13/2007 Traffic and Transportation 21.4
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/13/2007 Land Use and Zoning 21.6
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/13/2007 Cumulative Impacts 21.7
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/13/2007 Noise 21.8
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/13/2007 Cultural Resources 21.9
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/13/2007 Visual Resources 21.10
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/13/2007 Facility Layout and Design 21.11
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/14/2007 Alternatives 22.2
Gary, Brianna NYSDEC 10/19/2007 Ecological Resources 6.1
Gaudette, Richard and Jan No Date General/Miscellaneous 15.1
Gormel, Joyce 6/11/2007 Cultural Resources 33.1
4-42
003808
Table 4-3
Comment
ID 1
Gormel, Joyce 6/11/2007 Ecological Resources 34.1
Gormel, Joyce 6/11/2007 Socioeconomics 35.1
Gormel, Joyce 6/11/2007 Facility Layout and Design 37.1
Gormel, Joyce 6/5/2007 SEQR Process 75.1
Gormel, Joyce 6/5/2007 General/Miscellaneous 75.3
Gormel, Joyce 6/5/2007 Safety and Security 75.4
Gormel, Joyce 6/5/2007 75.6
and Benefits
Gormel, Joyce 3/24/2007 91.1
and Benefits
Gormel, Thomas 6/11/2007 27.1
and Benefits
Gormel, Thomas 6/11/2007 Traffic and Transportation 28.1
Gormel, Thomas 6/11/2007 Ecological Resources 29.1
Gormel, Thomas 6/11/2007 Facility Layout and Design 30.1
Gormel, Thomas 6/11/2007 Cultural Resources 31.1
Gormel, Thomas 6/11/2007 Socioeconomics 32.1
Gormel, Thomas 3/24/2007 Cumulative Impacts 95.1
Gormel, Thomas 3/24/2007 General/Miscellaneous 97.1
Gormel, Thomas 3/24/2007 Visual Resources 97.2
Graf, David 3/14/2007 General/Miscellaneous 100.1
Gregory, Maureen Wiley 6/6/2007 Cultural Resources 50.1
Gregory, Maureen Wiley 6/6/2007 Visual Resources 50.2
Gregory, Maureen Wiley 6/6/2007 Project Purpose, Public Need 52.1
4-43
003809
Table 4-3
Comment
ID 1
and Benefits
Gregory, Maureen Wiley 6/6/2007 Ecological Resources 53.1
Gregory, Maureen Wiley 6/6/2007 Traffic and Transportation 54.1
Gregory, Maureen Wiley 6/6/2007 Socioeconomics 57.1
Gregory, Maureen Wiley 6/6/2007 58.1
and Benefits
Hambrose, Harold 3/24/2007 Visual Resources 113.7
Hambrose, Johanna 3/24/2007 Cumulative Impacts 113.8
Hanson, Rollin V No Date SEQR Process 71.1
Hanson, Rollin V No Date Cultural Resources 71.2
Hanson, Rollin V 3/24/2007 Cumulative Impacts 113.9
Harris, Michael 6/15/2007 Visual Resources 8.1
Haskins, Janet and James 3/7/2007 Safety and Security 105.1
Henchy, Harold 3/24/2007 Cumulative Impacts 113.10
Hirschey, Sally 3/24/2007 Visual Resources 113.11
Hirschey, Urban C. 6/12/2007 39.1
Services
Hirschey, Urban C. 6/12/2007 Facility Layout and Design 39.2
Hirschey, Urban C. 6/12/2007 Land Use and Zoning 39.3
Hirschey, Urban C. 6/12/2007 Socioeconomics 40.2
Hirschey, Urban C. 6/12/2007 Cultural Resources 40.3
Hirschey, Urban C. 6/12/2007 Safety and Security 40.4
Hirschey, Urban C. 6/12/2007 Visual Resources 40.6
Hirschey, Urban C. 6/12/2007 Alternatives 40.7
Hirschey, Urban C. 6/12/2007 Physiography, Geology, and 40.10
4-44
003810
Table 4-3
Comment
ID 1
Soils
Hirschey, Urban C. 6/10/2007 Ecological Resources 43.1
Hirschey, Urban C. 6/10/2007 Traffic and Transportation 43.2
Hirschey, Urban C. 6/10/2007 Noise 43.7
Hirschey, Urban C. 3/24/2007 Visual Resources 113.12a
Hirschey, Urban C. 3/24/2007 113.12b
and Benefits
Hludzenski, Ed 3/24/2007 Cumulative Impacts 113.13
Hludzenski, Ed 3/24/2007 Safety and Security 113.14
Hludzenski, Kathryn A. 6/5/2007 Socioeconomics 66.1
Hludzenski, Kathryn A. 6/5/2007 Safety and Security 67.1
Internet Article: Daily-John.com No Date General/Miscellaneous 90.1
Jury, Charles No Date Noise 25.1
Kemmis, Richard J. 2/20/2007 General/Miscellaneous 102.1
LaPlante, J.O. 6/4/2007 Ecological Resources 70.1
LeTendre, Gerard 6/14/2007 Ecological Resources 11.1
LeTendre, Gerard 6/14/2007 Facility Layout and Design 11.3
4-45
003811
Table 4-3
Comment
ID 1
LeTendre, Gerard 6/14/2007 Socioeconomics 11.7
LeTendre, Gerard 6/14/2007 Noise 11.9
Letter to Editor: Watertown Daily Times 3/18/2007 Noise 94.1
Letter: NYSDEC 4/6/2007 Noise 111.9
Levy, Ann E. 6/1/2007 Visual Resources 78.1
Levy, Ann E. 3/24/2007 SEQR Process 96.1
Liner, Jillian M. Audubon New York 6/11/2007 Ecological Resources 47.1
Physiography, Geology and
Macura, Daniel No Date 61.1
Soils
Macura, Daniel No Date Water Resources 61.2
Merchant, Jerry 6/13/2007 General/Miscellaneous 20.1
Metzger, Don 3/24/2007 Cumulative Impacts 113.15a
Metzger, Don 3/24/2007 Facility Layout and Design 113.15b
Moehs, Charles, MD, MPH 6/7/2007 Safety and Security 62.1
Safety and Security / Facility
Moehs, Charles, MD, MPH 3/24/2007 92.1
Layout and Design
Nasca, Jack NYSDEC 5/9/2007 5.1
Soils
Soils
Soils
Nasca, Jack NYSDEC 3/24/2007 SEQR Process 113.19
Petras, Leigh and James 6/14/2007 Facility Layout and Design 16.1
Project Purpose, Public Need,
Planning Board Members Cape Vincent Planning Board 6/28/2007 112.2
and Benefits
4-46
003812
Table 4-3
Comment
ID 1
and Benefits
and Benefits
Planning Board Members Cape Vincent Planning Board 6/28/2007 Visual Resources 112.5
and Benefits
Planning Board Members Cape Vincent Planning Board 6/28/2007 Water Resources 112.9
and Benefits
and Benefits
Pressly, Nicholas Pressly & Associates, Inc. 5/29/2007 Water Resources 81.1
Pressly, Nicholas 5/29/2007 General/Miscellaneous 81.6
Pundt, Art 6/1/2007 Safety and Security 76.1
Reinhart, Marianna 3/24/2007 Facility Layout and Design 113.16a
Reinhart, Marianna 3/24/2007 Facility Layout and Design 113.16b
Schneider, Clifford P. 3/12/2007 Noise 106.1
Schneider, Clifford P. 6/12/2007 Facility Layout and Design 111.1
Schneider, Clifford P. 6/12/2007 Socioeconomics 111.4
Schneider, Clifford P. 6/12/2007 Visual Resources 111.6
Schneider, Clifford P. 6/12/2007 Ecological Resources 111.7
4-47
003813
Table 4-3
Comment
ID 1
Schneider, Clifford P. 3/24/2007 Cumulative Impacts 113.17a
Schneider, Clifford P. 3/25/2007 Noise 113.17b
Simpson, Carol 6/5/2007 SEQR Process 74.1
Simpson, Carol 3/24/2007 Facility Layout and Design 113.18
Smith, Gerald 6/8/2007 Ecological Resources 109.1
Stilwell, David and Tim Sullivan USFWS 6/15/2007 2.1
and Benefits
and Benefits
Stilwell, David and Tim Sullivan USFWS 6/15/2007 Construction 2.3
Stilwell, David and Tim Sullivan USFWS 6/15/2007 Ecological Resources 2.4
Stilwell, David and Tim Sullivan USFWS 6/15/2007 Facility Layout and Design 2.5
Soils / Ecological Resources
Stilwell, David and Tim Sullivan USFWS 6/15/2007 Water Resources 2.17
4-48
003814
Table 4-3
Comment
ID 1
Stilwell, David and Tim Sullivan USFWS 6/15/2007 Threatened and Endangered 2.38
Species
Species
Species
Species
Species
Stilwell, David and Tim Sullivan USFWS 6/15/2007 Cumulative Impacts 2.43
Stilwell, David and Tim Sullivan USFWS 6/15/2007 Alternatives 2.44
Tomasik, Steven for Jack Nasca NYSDEC 6/15/2007 Ecological Resources 1.1
4-49
003815
Table 4-3
Comment
ID 1
Tomasik, Steven for Jack Nasca NYSDEC 6/15/2007 Cumulative Impacts 1.2
Tomasik, Steven for Jack Nasca NYSDEC 6/15/2007 Water Resources 1.3
Tomasik, Steven for Jack Nasca NYSDEC 6/15/2007 Construction 1.7
Operations and Maintenance /
Tomasik, Steven for Jack Nasca NYSDEC 6/15/2007 1.9
Decommissioning
Decommissioning
Tomasik, Steven for Jack Nasca NYSDEC 6/15/2007 Threatened and Endangered 1.11
Species
Soils
Tomasik, Steven for Jack Nasca NYSDEC 6/15/2007 Water Resources 1.13a
Tomasik, Steven for Jack Nasca NYSDEC 6/15/2007 Visual Resources 1.13b
Tomasik, Steven for Jack Nasca NYSDEC 6/15/2007 Visual Resources 1.14
Tomasik, Steven for Jack Nasca NYSDEC 6/15/2007 Cultural Resources 1.17
Stone Building Appreciation
Uhlig, Robert 6/15/2007 Cultural Resources 9.1
Society
Vail, Alan 6/12/2007 Alternatives 26.1
Vail, Alan 6/12/2007 Socioeconomics 26.2
Vail, Alan 6/12/2007 Facility Layout and Design 26.6
4-50
003816
Table 4-3
Comment
ID 1
Walker, Tom and Mabel No Date Ecological Resources 64.1
Walker, Tom and Mabel No Date Land Use and Zoning 64.2
Wiley, Karen 2/16/2007 Socioeconomics 99.1
Wiley, Karen 2/16/2007 Facility Layout and Design 99.2
Wiley, Karen 2/16/2007 Recreation 99.4
Wiley, Karen 2/16/2007 General/Miscellaneous 99.5
Wiley, Karen 2/16/2007 Safety and Security 99.6
Wiley, Karen 2/16/2007 Visual Resources / Noise 99.7
Zovistoski, Mary 6/10/2007 Traffic and Transportation 38.1
Zovistoski, Mary 6/10/2007 Safety and Security 38.2
Zovistoski, Mary 6/10/2007 Cultural Resources 38.3
Zovistoski, Mary 6/10/2007 General/Miscellaneous 38.4
Zovistoski, Mary 6/10/2007 Facility Layout and Design 38.5
Zovistoski, Mary 6/10/2007 Visual Resources 38.6
Zovistoski, Mary 6/10/2007 Alternatives 38.7
1
Comment ID represents a combination of the Comment Letter ID (before decimal) and Comment ID within letter (after decimal)
as identified in Table 3-1.
4-51
003817
Table 4-4
Saint Lawrence Windpower Project SDEIS Response Summary Ordered by Source
Comment
ID 1
Bell, Dolores and Michael 5/28/2009 Ecological Resources 15.1
Bell, Dolores and Michael 5/28/2009 Noise 15.2
Bell, Dolores and Michael 5/28/2009 Visual Resources 15.4
Bell, Dolores and Michael 5/28/2009 Operations and Maintenance 15.5
Bell, Dolores and Michael 5/28/2009 Socioeconomics 15.6
Bell, Dolores and Michael 5/28/2009 Noise/Visual Resources 15.7
Bell, Dolores and Michael 5/28/2009 Project Purpose, Public Need and Benefits 15.9
Bonafide, John NYSOPRHP 5/28/2009 Cultural Resources 5.1
Boss, Mark 5/25/2009 Facility Layout and Design/Alternatives 16.1
Boss, Mark 5/25/2009 Construction 16.2
Boss, Mark 5/25/2009 Water Resources 16.3
Boss, Mark 5/25/2009 Decommissioning 16.6
Boss, Sally 5/16/2009 Land Use and Zoning 73.55
Boss, Sarah 5/26/2009 Ecological Resources 17.1
Boss, Sarah 5/26/2009 Socioeconomics 17.3
Boss, Sarah 5/26/2009 Construction 17.4
Boss, Sarah 5/26/2009 Operations and Maintenance 17.5
4-52
003818
Table 4-4
Comment
ID 1
Boss, Sarah 5/26/2009 Water Resources 17.7
Boss, Sarah 5/26/2009 Safety and Security 17.9
Boss, Sarah 5/26/2009 SEQR Process 17.11
Boss, Sarah 5/29/2009 Facility Layout and Design 18.1
Bourquin, Don 5/16/2009 Project Purpose, Public Need and Benefits 73.62
Bowers, Bert 5/16/2009 Project Purpose, Public Need and Benefits 73.63
Bowers, Bert 5/16/2009 Noise 73.65
Bragdon, Brooke 5/16/2009 SEQR Process 73.46
Bragdon, Brooks 5/24/2009 SEQR Process 19.1
Bragdon, Brooks 5/24/2009 Visual Resources 19.2
Bragdon, Brooks 5/24/2009 Socioeconomics 19.4
Bragdon, Brooks 5/28/2009 Project Purpose, Public Need and Benefits 20.2
Bragdon, Brooks 5/28/2009 Decommissioning 20.3
4-53
003819
Table 4-4
Comment
ID 1
Brown, Mary Jane 5/28/2009 Visual Resources 21.1
Brown, Tom 5/16/2009 Visual Resources 73.39
Brown, Tom 5/16/2009 Alternatives 73.40
Burpee, Edith 5/28/2009 Visual Resources/Cumulative Impacts 22.1
Burton, Darrell 5/26/2009 SEQR Process 23.1
Burton, Marlene 5/26/2009 SEQR Process 24.1
Byrne, John 5/16/2009 Noise 73.25
Byrne, Tatyana 5/28/2009 Facility Layout and Design/Alternatives 25.1
Byrne, Tatyana 5/28/2009 Construction 25.2
Byrne, Tatyana 5/28/2009 Water Resources 25.3
Byrne, Tatyana 5/28/2009 Facility Layout and Design 25.5
Byrne, Tatyana 5/28/2009 Decommissioning 25.6
Byrne, Tatyana 5/28/2009 Physiography, Geology, and Soils 25.7
Byrne, Tatyana 5/28/2009 Traffic and Transportation 25.10
Byrne, Tatyana 5/28/2009 Climate and Air Quality 25.11
4-54
003820
Table 4-4
Comment
ID 1
Byrne, Tatyana 5/28/2009 Safety and Security 25.13
Byrne, Tatyana 5/28/2009 Cumulative Impacts 25.14
Byrne, Tatyana 5/28/2009 Socioeconomics 25.15
Byrne, Tatyana 5/28/2009 Alternatives 25.16
Byrne, Tatyana 5/28/2009 Alternatives/Noise 25.17
Byrne, Tatyana 5/28/2009 Ecological Resources 25.18
Byrne, Tatyana 5/28/2009 Visual Resources 25.23
Byrne, Tatyana 5/28/2009 Noise 25.24
Byrne, Tatyana 5/28/2009 Telecommunications 25.26
Byrne, Tatyana 5/28/2009 Operations and Maintenance 25.31
Byrne, Tatyana 5/28/2009 SEQR Process 25.37
4-55
003821
Table 4-4
Comment
ID 1
Byrne, Tatyana 5/28/2009 Project Purpose, Public Need and Benefits 25.48
Byrne, Tatyana 5/28/2009 Land Use and Zoning 25.52
Byrne, Tatyana 5/28/2009 Cultural Resources 25.54
Chapman, Tom 5/16/2009 Project Purpose, Public Need and Benefits 73.31
4-56
003822
Table 4-4
Comment
ID 1
Chase, Hester 5/16/2009 Alternatives 73.58
Ciocci, Theresa 5/16/2009 Safety and Security 73.24
Ciocci, Theresa 5/16/2009 Socioeconomics 73.74
Clark, John 5/16/2009 Project Purpose, Public Need and Benefits 73.35
Corbin, James FOX Broadcasting 5/12/2009 Telecommunications 10.1
Cullen, Cyril 5/16/2009 Decommissioning 73.47
Cullen, Cyril 5/16/2009 Land Use and Zoning 73.48
Cullen, Geoffrey 5/30/2009 SEQR Process 26.1
Cullen, Geoffrey 5/30/2009 Visual Resources 26.2
Cullen, Geoffrey 5/30/2009 Socioeconomics 26.3
Daub, Patricia 5/28/2009 Cultural Resources 27.1
Davis, Andrew NYSDPS 5/28/2009 Utilities and Community Services 4.2
Davis, Andrew NYSDPS 5/28/2009 Construction 4.3
Davis, Andrew NYSDPS 5/28/2009 General 4.7
Davis, Andrew NYSDPS 5/28/2009 SEQR Process 4.10
Davis, Andrew NYSDPS 5/28/2009 Telecommunications 4.15
4-57
003823
Table 4-4
Comment
ID 1
Davis, Andrew NYSDPS 5/28/2009 Operations and Maintenance 4.17
Davis, Andrew NYSDPS 5/28/2009 Decommissioning 4.21
DeLong, Sam 5/16/2009 Safety and Security 73.67
Docteur, David 5/28/2009 Facility Layout and Design 28.1
Docteur, David 5/28/2009 Visual Resources 28.2
Docteur, David 5/28/2009 Noise 28.3
Docteur, David 5/28/2009 Safety and Security 28.4
Docteur, David 5/16/2009 Alternatives 73.26
Docteur, David 5/16/2009 Socioeconomics 73.28
Docteur, Dennis and Donald 5/29/2009 General 29.1
Docteur, Lee No Date General 30.1
Docteur, Mary 5/28/2009 Cumulative Impacts 31.1
Docteur, Mary 5/28/2009 Socioeconomics 31.2
Docteur, Mary 5/28/2009 Alternatives 31.3
Docteur, Mary 5/28/2009 Alternatives/Noise 31.4
Docteur, Mary 5/28/2009 Ecological Resources 31.5
Docteur, Mary 5/28/2009 Visual Resources 31.10
Docteur, Mary 5/28/2009 Noise 31.11
4-58
003824
Table 4-4
Comment
ID 1
Docteur, Mary 5/28/2009 Telecommunications 31.13
Docteur, Paul 5/29/2009 Safety and Security 32.1
Docteur, Paul 5/29/2009 Operations and Maintenance 32.3
Docteur, Paul 5/29/2009 SEQR Process 32.4
Doull, Melodee 5/28/2009 Project Purpose, Public Need and Benefits 35.1
Doull, Melodee 5/28/2009 Operations and Maintenance 35.2
Doull, Melodee 5/28/2009 Safety and Security 35.3
Doull, Melodee 5/28/2009 SEQR Process 35.4
Doull, Melodee 5/28/2009 Facility Layout and Design 35.6
Doull, Melodee 5/28/2009 Decommissioning 35.8
Doull, Melodee 5/28/2009 Socioeconomics 35.9
Doull, Melodee 5/28/2009 Land Use and Zoning 35.13
Ebbing, Chuck 5/16/2009 Cumulative Impacts 73.41
Ebbing, Chuck 5/16/2009 Noise 73.43
Edgar, Chris 5/16/2009 Project Purpose, Public Need and Benefits 73.68
Estelle, Douglas and Michelle 5/27/2009 Ecological Resources 33.1
Evans, William Old Bird Inc. 5/29/2009 Ecological Resources 13.1
4-59
003825
Table 4-4
Comment
ID 1
Falcon, Mary 5/16/2009 Socioeconomics 73.61
Falcon, Spencer 5/16/2009 Safety and Security 73.66
Freislich, John and Michelle 5/30/2009 Safety and Security 34.1
Freislich, John and Michelle 5/30/2009 Noise 34.2
Freislich, John and Michelle 5/30/2009 SEQR Process 34.3
Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 5/22/2009 SEQR Process 11.1
Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 5/22/2009 Land Use and Zoning 11.2
Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 5/22/2009 Cumulative Impacts 11.3
Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 5/22/2009 Alternatives 11.4
Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 5/22/2009 Ecological Resources 11.5
Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 5/22/2009 Facility Layout and Design 11.10
Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 5/22/2009 Water Resources 11.12
Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 5/22/2009 Noise 11.13
Gauthier, Bob 5/16/2009 Project Purpose, Public Need and Benefits 73.36
Grant, Cindy 5/16/2009 Safety and Security 73.1
Grant, Cindy 5/16/2009 Noise 73.2
Grant, Cindy 5/16/2009 Facility Layout and Design 73.3
4-60
003826
Table 4-4
Comment
ID 1
Grant, Cindy 5/16/2009 Socioeconomics 73.7
Grant, Cindy 5/16/2009 Project Purpose, Public Need and Benefits 73.8
Haskins, Janet 5/16/2009 Safety and Security 73.45
Henchy, Harold 5/4/2009 Water Resources 36.1
Hetzler, Eileen 5/26/2009 Socioeconomics 37.1
Hetzler, Stephen 5/26/2009 Socioeconomics 38.1
Hirschey, Urban 5/28/2009 SEQR Process 39.1
Hirschey, Urban 5/28/2009 Cumulative Impacts 39.2
Hludzenski, Kathryn 5/26/2009 Safety and Security 40.1
Hludzenski, Kathryn 5/29/2009 Ecological Resources 41.1
Hludzenski, Kathryn 5/29/2009 Cumulative Impacts 41.2
Hubbard, Sandy 5/28/2009 Ecological Resources 42.1
Hubbard, Sandy 5/28/2009 Socioeconomics 42.3
Hubbard, Sandy 5/28/2009 Construction 42.4
Hubbard, Sandy 5/28/2009 Operations and Maintenance 42.5
Hubbard, Sandy 5/28/2009 Water Resources 42.7
Hubbard, Sandy 5/28/2009 Safety and Security 42.9
4-61
003827
Table 4-4
Comment
ID 1
Hubbard, Sandy 5/28/2009 SEQR Process 42.11
Johnson, Warren 5/16/2009 Facility Layout and Design 73.33
Jolliff, Tom 5/16/2009 Operations and Maintenance 73.53
Jury, Charles No Date SEQR Process 43.1
Jury, Ellen No Date Telecommunications 44.1
Kenney, Gail 5/16/2009 Project Purpose, Public Need and Benefits 73.38
King, Gary 5/16/2009 Project Purpose, Public Need and Benefits 73.30
Kobylarz, Virginia 5/16/2009 Project Purpose, Public Need and Benefits 73.49
Kobylarz, Virginia 5/16/2009 Ecological Resources 73.50
Kobylarz, Virginia 5/16/2009 Decommissioning 73.51
LaMora, David 5/27/2009 SEQR Process 45.1
LaMora, David 5/27/2009 Climate and Air Quality 45.2
LaMora, David 5/27/2009 Land Use and Zoning/Visual Resources 45.3
LaMora, David 5/27/2009 Land Use and Zoning 45.5
LaMora, David 5/27/2009 Noise 45.6
Lawrence, Rick 5/16/2009 Project Purpose, Public Need and Benefits 73.32
Leschord, Paul No Date Land Use and Zoning 46.1
LeTendre, Gerard 5/29/2009 SEQR Process 47.2
4-62
003828
Table 4-4
Comment
ID 1
LeTendre, Jerry 5/16/2009 Ecological Resources 73.33
LeTendre, Jerry and Judith 5/19/2009 SEQR Process 48.1
Lyons, Thomas NYSOPRHP 5/29/2009 SEQR Process 7.1
Lyons, Thomas NYSOPRHP 5/29/2009 Visual Resources 7.2
Lyons, Thomas NYSOPRHP 5/29/2009 Ecological Resources 7.5
Lyons, Thomas NYSOPRHP 5/29/2009 Noise 7.8
Lyons, Thomas NYSOPRHP 5/29/2009 Project Purpose, Public Need and Benefits 7.9
Macura, David 5/27/2009 Physiography, Geology, and Soils 49.1
Macura, David 5/27/2009 Construction 49.2
Macura, David 5/27/2009 Traffic and Transportation 49.4
Macura, David 5/27/2009 Climate and Air Quality 49.5
Macura, David 5/27/2009 Safety and Security 49.7
Macura, Joan 5/28/2009 Facility Layout and Design 50.1
Macura, Joan 5/28/2009 Construction 50.2
Macura, Joan 5/28/2009 Water Resources 50.3
Macura, Joan 5/28/2009 Decommissioning 50.6
4-63
003829
Table 4-4
Comment
ID 1
Mahrer, Carolyn 5/19/2009 Safety and Security 51.1
Mahrer, Michael and Susan No Date Safety and Security 52.1
Mason, Elaine and Paul 5/19/2009 Project Purpose, Public Need and Benefits 53.1
Mason, Paul 5/16/2009 Project Purpose, Public Need and Benefits 73.37
McTaggert, Pat 5/16/2009 Safety and Security 73.54
Metzger, Don 5/16/2009 Alternatives 73.10
Metzger, Don 5/16/2009 Construction 73.12
Metzger, Don 5/16/2009 Water Resources 73.13
Metzger, Don 5/16/2009 Decommissioning 73.70
Metzger, Don 5/16/2009 Visual Resources 73.71
Metzger, Don 5/16/2009 Telecommunications 73.72
Metzger, Donald 5/26/2009 SEQR Process 54.1
Metzger, Donald 5/26/2009 Decommissioning 54.3
Metzger, Donald 5/26/2009 Facility Layout and Design 54.5
Metzger, Donald 5/26/2009 Safety and Security 54.6
Metzger, Donald 5/26/2009 Utilities and Community Services 54.7
Metzger, Donald 5/26/2009 Telecommunications 54.8
Metzger, Donald 5/26/2009 Water Resources 54.10
Metzger, Donald 5/26/2009 Cumulative Impacts 54.11
Moehs, Charles 5/28/2009 Safety and Security 56.1
Radley, Jarvis 5/16/2009 Project Purpose, Public Need and Benefits 73.52
Radley, Jerry No Date Socioeconomics 57.1
Radley, Jerry No Date Safety and Security 57.2
Radley, Jerry No Date Ecological Resources 57.3
4-64
003830
Table 4-4
Comment
ID 1
Radley, Pattie Marie 5/28/2009 Project Purpose, Public Need and Benefits 58.1
Reed, Alfred and Maria 5/29/2009 Socioeconomics 59.1
Reed, Alfred and Maria 5/29/2009 Noise 59.2
Riley, Thomas Onondaga Audubon 5/28/2009 Ecological Resources 14.1
Ross, Pat 5/19/2009 Safety and Security 60.1
Ryon, Doug 5/28/2009 Visual Resources 61.1
Schneider, Clif 5/16/2009 Noise 73.44
Schneider, Clifford 5/20/2009 Noise 62.1
Schneider, Clifford 5/20/2009 Utilities and Community Services 62.14
4-65
003831
Table 4-4
Comment
ID 1
Schoeberlein, Donna 5/23/2009 Safety and Security 63.1
Schoeberlein, Donna 5/23/2009 Socioeconomics 63.2
Simpson, Carol 5/28/2009 Cumulative Impacts 64.1
Simpson, Carol 5/28/2009 Socioeconomics 64.2
Simpson, Carol 5/28/2009 Ecological Resources 64.5
Simpson, Carol 5/28/2009 Visual Resources 64.9
Simpson, Carol 5/28/2009 Noise 64.10
Simpson, Carol 5/28/2009 Telecommunications 64.11
Simpson, Carol 5/29/2009 Ecological Resources - Threatened & 65.1
Endangered Species
Endangered Species
Sirianni, Paul 5/16/2009 Project Purpose, Public Need and Benefits 73.34
Smith, Gerry 5/16/2009 Ecological Resources 73.9
Steinhouse, Barbara 5/29/2009 Safety and Security 66.1
Stilwell, David USFWS 5/29/2009 Ecological Resources 1.1
Stilwell, David USFWS 5/29/2009 Climate and Air Quality 1.3
Stilwell, David USFWS 5/29/2009 Facility Layout and Design 1.4
Stilwell, David USFWS 5/29/2009 Water Resources 1.6
4-66
003832
Table 4-4
Comment
ID 1
Thomas, Carol and Dan 5/28/2009 Socioeconomics 67.1
Thomas, Carol and Dan 5/28/2009 Land Use and Zoning 67.6
Tomasik, Stephen NYSDEC 5/29/2009 Facility Layout and Design 2.1
Tomasik, Stephen NYSDEC 5/29/2009 Safety and Security 2.2
Tomasik, Stephen NYSDEC 5/29/2009 Cumulative Impacts 2.3
Tomasik, Stephen NYSDEC 5/29/2009 Physiography, Geology, and Soils 2.5
Tomasik, Stephen NYSDEC 5/29/2009 Physiography, Geology, and Soils/ Water 2.6
Resources
Tomasik, Stephen NYSDEC 5/29/2009 Ecological Resources 2.7
Tomasik, Stephen NYSDEC 5/29/2009 Ecological Resources - Threatened & 2.19
Endangered Species
4-67
003833
Table 4-4
Comment
ID 1
Tomasik, Stephen NYSDEC 5/29/2009 Water Resources 2.20
Endangered Species
Tomasik, Stephen NYSDEC 5/29/2009 Construction 2.23
Uhlig, Bob and Ruth 5/19/2009 Operations and Maintenance 68.1
Uhlig, Bob and Ruth 5/19/2009 Ecological Resources 68.2
Uhlig, Bob and Ruth 5/19/2009 Visual Resources 68.3
various landowners Groundwater 74.1
Vooder, Linda 5/19/2009 Safety and Security 69.1
White, Beth 5/16/2009 Project Purpose, Public Need and Benefits 73.14
White, Harvey 5/16/2009 Project Purpose, Public Need and Benefits 73.56
White, Kenneth 5/16/2009 Project Purpose, Public Need and Benefits 73.29
Wiley, Karen and Richard 5/16/2009 Safety and Security 70.1
Williams, Sharon 5/19/2009 Safety and Security 71.1
Williams, Tina 5/28/2009 Visual Resources 72.1
Williams, Tina 5/28/2009 SEQR Process 72.2
Williams, Tina 5/28/2009 Project Purpose, Public Need and Benefits 72.3
Zappieri, Jeff NYSDOS 5/26/2009 Land Use and Zoning 3.1
Zappieri, Jeff NYSDOS 5/26/2009 Water Resources 3.2
Zappieri, Jeff NYSDOS 5/26/2009 Decommissioning 3.3
Zappieri, Jeff NYSDOS 5/26/2009 Ecological Resources 3.6
Zappieri, Jeff NYSDOS 5/26/2009 Traffic and Transportation 3.9
Zappieri, Jeff NYSDOS 5/26/2009 SEQR Process 3.12
1
4-68
003834
Table 4-5
Saint Lawrence Windpower Project DEIS Comments Requiring No Response
1
Comment ID Commenter Agency Date
4.49 Davis, Andrew State of New York Department of Public Service 6/13/2007
11.1 LeTendre, Gerard 6/14/2007
14.8 Chase, Hester 6/15/2007
15.1 Gaudette, Richard and Jan No Date
19.2 Caddick, Jennifer and Aaron Vogel Save the River and 1000 Islands Land Trust 6/14/2007
20.1 Merchant, Jerry 6/13/2007
27.1 Gormel, Thomas 6/11/2007
46.1 Bracket, Mr. and Mrs. Montgomery 6/11/2007
58.1 Gregory, Maureen Wiley 6/6/2007
70.2 LaPlante, J.O. 6/4/2007
70.3 Article: Watertown Daily Times No Date
70.4 Article: Los Angeles Times No Date
70.5 Article: Source Unknown No Date
81.6 Curriculum Vitae 5/29/2007
82.1 Cuda, Kenneth 4/5/2007
83.3 Cape Vincent Zoning Law 3/24/2007
87.1 Dziekan, Andrew 3/19/2007
96.1 Levy, Ann E. 3/24/2007
99.5 Wiley, Karen 2/16/2007
100.1 Graf, David No Date
103.1 Brown, Thomas 2/21/2007
106.2 Schneider, Clifford P. 3/12/2007
113.10 Henchy, Harold 3/24/2007
1
Comment ID represents a combination of the Comment Letter ID (before decimal) and Comment ID within letter
(after decimal) as identified in Table 3-1.
4-69
003835
Table 4-6
Saint Lawrence Windpower Project SDEIS Comments Requiring No Response
Comment ID 1 Commenter Agency Date
1.8 Stilwell, David USFWS 5/29/2009
3.12 Zappieri, Jeff NYSDOS 5/26/2009
4.1 Davis, Andrew NYSDPS 5/28/2009
5.3 Bonafide, John NYSOPRHP 5/28/2009
7.9 Lyons, Thomas NYSOPRHP 5/29/2009
10.2 Corbin, James FOX Broadcasting 5/12/2009
14.6 Riley, Thomas Onondaga Audubon 5/28/2009
15.9 Bell, Dolores and Michael 5/28/2009
20.14 Bragdon, Brooks 5/28/2009
23.1 Burton, Darrell 5/26/2009
24.1 Burton, Marlene 5/26/2009
26.1 Cullen, Geoffrey 5/30/2009
29.1 Docteur, Dennis and Donald 5/29/2009
30.1 Docteur, Lee no date
34.3 Freislich, John and Michelle 5/30/2009
48.1 LeTendre, Jerry and Judith 5/19/2009
51.1 Mahrer, Carolyn 5/19/2009
52.1 Mahrer, Michael and Susan No date
53.1 Mason, Elaine and Paul 5/19/2009
54.9 Metzger, Donald 5/26/2009
58.1 Radley, Pattie Marie 5/28/2009
60.1 Ross, Pat 5/19/2009
61.1 Ryon, Doug 5/28/2009
63.1 Schoeberlein, Donna 5/23/2009
66.1 Steinhouse, Barbara 5/29/2009
69.1 Vooder, Linda 5/19/2009
4-70
003836
Table 4-6
70.1 Wiley, Karen and Richard 5/16/2009
71.1 Williams, Sharon 5/19/2009
72.3 Williams, Tina 5/28/2009
73.7 Grant, Cindy 5/16/2009
73.8 Grant, Cindy 5/16/2009
73.14 White, Beth 5/16/2009
73.20 Doull, Melodee 5/16/2009
73.21 Hirschey, Urban 5/16/2009
73.25 Byrne, John 5/16/2009
73.27 Docteur, David 5/16/2009
73.29 White, Kenneth 5/16/2009
73.30 King, Gary 5/16/2009
73.32 Lawrence, Rick 5/16/2009
73.34 Sirianni, Paul 5/16/2009
73.35 Clark, John 5/16/2009
73.36 Gauthier, Bob 5/16/2009
73.37 Mason, Paul 5/16/2009
73.38 Kenney, Gail 5/16/2009
73.45 Haskins, Janet 5/16/2009
73.52 Radley, Jarvis 5/16/2009
73.56 White, Harvey 5/16/2009
73.61 Falcon, Mary 5/16/2009
73.62 Bourquin, Don 5/16/2009
73.68 Edgar, Chris 5/16/2009
73.71 Metzger, Don 5/16/2009
1
Comment ID represents a combination of the Comment Letter ID (before decimal) and
Comment ID within letter (after decimal) as identified in Table 3-2.
4-71
003837
4.1 Responses Ordered by Subject

Many comments addressed similar questions or concerns and, therefore, have been grouped
according subject matter. The following responses are arranged according to subject matter
based on the primary issue raised in the comment. The following table provides a quick
reference guide to subject matter headings for the comment responses.
SUBJECT PAGE
Alternatives ......................................................................................... 4-73
Climate and Air Quality...................................................................... 4-74
Construction........................................................................................ 4-75
Cultural Resources .............................................................................. 4-77
Cumulative Impacts ............................................................................ 4-82
Decommissioning ............................................................................... 4-87
Ecological Resources .......................................................................... 4-89
Facility Layout and Design............................................................... 4-120
General/Miscellaneous...................................................................... 4-131
Groundwater ..................................................................................... 4-134
Land Use and Zoning........................................................................ 4-134
Noise ................................................................................................. 4-138
Operations and Maintenance............................................................. 4-148
Physiography, Geology, and Soils .................................................... 4-150
Project Purpose, Public Need and Benefits....................................... 4-153
Recreation ......................................................................................... 4-156
Safety and Security ........................................................................... 4-156
SEQR Process ................................................................................... 4-163
Socioeconomics ................................................................................ 4-166
Telecommunications ......................................................................... 4-171
Traffic and Transportation ................................................................ 4-174
Utilities and Community Services .................................................... 4-175
Visual Resources............................................................................... 4-176
Water Resources ............................................................................... 4-184
4-72
003838
ALTERNATIVES
DEIS Response 2.44 Please see DEIS Response to Comment 2.6.
DEIS Response 4.50 Please see Section 7.7 of the SDEIS.
DEIS Response 4.51 Please see DEIS Response to Comment 4.50
DEIS Response 4.52 Please see DEIS Response to Comment 4.47
DEIS Response 4.53 Please see Section 7 of the SDEIS. The Project design has been
revised through an iterative process which complied with industry best
practices and all requirements by the Town of Cape Vincent Planning
Board with regard to setbacks. The Project has not located facilities in
the Lake District or River District in the Town of Cape Vincent.
DEIS Response 4.54 SLW has given serious consideration to a range of alternative facility
arrangements to respond to applicable siting criteria and agency
preferences. That process resulted in reduction of the Project from 96
turbines to 51 turbines, and significant revisions from the original
projected Project layout. No Project facilities are proposed in the Lake
District or River District in the Town of Cape Vincent.
DEIS Response 12.10 The alternatives analyses in the DEIS were supplemented by
additional analyses in Section 7 of the SDEIS. All alternatives
required to be evaluated under SEQRA have been evaluated. The
analyses were not misleading.
DEIS Response 22.2 Section 7 of the SDEIS provides additional discussion of alternatives.
DEIS Response 26.1 Section 7.1 of the SDEIS contains additional analysis of the “no
action” alternative.
DEIS Response 26.7 The current layout is 51 turbines.
DEIS Response 38.7 Section 7 of the SDEIS provided additional discussion of alternatives.
DEIS Response 40.7 Section 7 of the SDEIS provides additional discussion of alternatives.
SDEIS Response 11.4 Illustrations of a typical transmission interconnect facility can be
found in Exhibits 2.2.6 and 2.2.7. The facility in Lyme will be
approved as part of the Site Plan Review in the Town of Lyme. The
existing Lyme Substation is visible from the public road. The SLW
facility may also be visible from the road, consistent with the existing
substation. SLW has proposed visual mitigation for the Town of
Lyme and will offset any visual impacts through that mitigation, if in
fact the facility is visible from the road.
SDEIS Response 11.11 The main portion of the Project is not located on the shorefront, or in
what the NYSDOS has identified as a coastally significant area. The
only part of the Project that overlaps the Coastal Area is the crossing
of the Chaumont River by the proposed transmission line. The
transmission line must be constructed to link to the substation in
4-73
003839
Lyme. In order to do so, the transmission line must cross the River,
and pass through a portion of the coastal area.
SDEIS Response 25.16 Yes, the FEIS layout includes the referenced setbacks established by
the Planning Board of Cape Vincent.
SDEIS Response 25.17 Comment noted. This comment addresses issues outside the scope of
the EIS.
SDEIS Response 31.3 Please see response to Comment 25.16.
SDEIS Response 73.10 The SDEIS describes Alternative 2 in Section 7.7.2. Alternative 2 is
an alternate transmission line route (adjacent to the DANC water line).
SDEIS Response 73.11 Comment noted. The comment questions the applicable regulations,
not the substantive content of the EIS.
SDEIS Response 73.40 SLW has utilized one alternative turbine site (T-25) because of noise
impacts. The Project is viable in Cape Vincent, where SLW obtained
landowners who are willing to be participants in the wind farm. Other
locations in NYS are also viable, but SLW does not have leases with
those landowners, and is a private company without the power of
eminent domain.
SDEIS Response 73.58 The commenter does not give specifics on which alternative he is
commenting on; not reasons why he believes the alternative should be
developed. The Planning Board cannot respond to this comment
without knowledge of those specifics.
CLIMATE AND AIR QUALITY

SDEIS Response 1.3a Wind energy generation results in reductions in air emissions because
of the way the electric power systems work. According to a 2008
NREL Report, wind energy is a preferred power source on an
economic basis because the operating costs to run the turbines are very
low because there are no fuel costs. Thus, when the wind turbines
produce power, electricity supplies from other sources will be reduced
or not brought online. Almost always, the most expensive power will
be backed down or avoided. Typically, wind power will displace
generation at individual fossil fuel-fired power plants, which have
higher operating costs and substantial fuel costs. Not only does wind
power displace CO2 emissions, it also displaces other emissions such
as NOx and SO2. According to NYSERDA (2005) and using New
York State's displacement mix of 15 percent coal, 65 percent natural
gas, 10 percent oil, and 10 percent imports; wind power displaces
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003840
approximately 0.63 tons of CO2, 0.0007 tons of NOx, and 0.0013 tons
of SO2 per MWh.
A number of real-world experiences have shown the following: 1) In
2007, wind energy in the U.S. reduced CO2 emissions by over 28
million tons. On average, each MWh of wind energy reduced CO2
emissions by 1200 pounds; 2) A study of a grid operator in Texas
concluded that adding 3000 MW of wind energy to the state's grid
would reduce carbon dioxide emissions by about 5.5 million tons per
year, sulfur dioxide emissions by 4000 tons per year, and nitrous oxide
emissions by about 2000 tons per year; 3) the 30 MW Kaheawa wind
plant in Hawaii offsets power from oil-burning power plants, reducing
oil imports by almost 10 million gallons per year.
SDEIS Response 25.11 Wind power does not produce air emissions. There will be no
negative effect on ozone in the region. No mitigation is necessary.
CONSTRUCTION
DEIS Response 1.7 Specific procedures that will be implemented to ensure that concrete is
handled properly during construction to limit impacts to groundwater,
surface water and wetlands are located in Appendix C-8 of the FEIS.
Such procedures include:
x Removal of all solid waste, hazardous materials, and construction
debris from the site and manage disposal in a manner consistent
with all applicable state and federal regulations.
x Disposal of excess concrete in a designated area. Under no
circumstances shall excess concrete be left on the surface in active
agricultural areas.
x Rinsing concrete trucks in designated areas, outside of active
agricultural areas.
x Managing all rinsate in accordance with the requirements of the
Storm Water Pollution Prevention Plan (SWPPP).
DEIS Response 1.19 A preliminary Construction Environmental Monitoring Plan is set
forth in Appendix C-14 of the FEIS. The final plan will be prepared
after permits are obtained and the applicable permit conditions are
known.
DEIS Response 2.3 Up to five permanent meteorological towers will be constructed. Even
monopole-type structures at the 80m and 100m height require some
guying in order to ensure safety of the tower. SLW will minimize
impacts to wildlife by placing bird deflectors on the guy wires in the
fashion shown in Exhibit 2-3 of the FEIS.
4-75
003841
DEIS Response 2.9 Permanent access roads are proposed to be 17 feet in width, which is
consistent with other wind projects in New York State.
DEIS Response 2.11 A PLC trencher will likely be used for installing underground cabling.
The impact to vegetation from such equipment will only be 12 feet
maximum. Ditch width will be approximately 2 feet.
DEIS Response 2.12 Directional drilling for this project is cost prohibitive. SLW is only
crossing 2 perennial streams. SLW will use conventional trenching for
installation of cables through the linear wetlands, and utilize
sedimentation and erosion control practices, as specified in the draft
SWPPP in Appendix C-8 of the FEIS.
SDEIS Response 2.23 A complete and detailed Construction Environmental Monitoring
Program will be developed after all permits have been obtained. A
draft outline of the Plan, along with some draft sections, can be seen in
Appendix C-14.
SDEIS Response 4.3 SLW has conducted an initial construction feasibility evaluation of the
proposed transmission line route. The Design Criteria for the
engineering analysis is included in C-7. A more detailed evaluation
and site plan will be developed prior to construction based on the
Design Criteria.
SDEIS Response 4.23 Turbine blades, towers, nacelles, transformers and all other related
equipment are available for delivery in 2010 and 2011. Delivery of
equipment is expected in late 2010 through mid 2011.
SDEIS Response 16.2 If the lines are going to be in agricultural fields, they will be 48 inches
below grade, to facilitate continued agricultural practices. No
agricultural practices are currently being done below bedrock;
therefore, if the cable is below bedrock, it will not interfere with
agricultural practices at a depth of 6 inches below bedrock.
SDEIS Response 16.4 Construction plans related to concrete and measures to limit impacts to
surface water, wetlands, and underground waters are described in the
SWPPP. A copy of the project's draft SWPPP is included in Appendix
C-8. The Applicant will submit a final Stormwater Pollution
Prevention Plan (SWPPP) prior to construction in accordance with the
SPDES General Permit for Construction Activity, GP-0-08-001.
SDEIS Response 17.4 The environmental monitor will be an independent and objective third
party, who likely will work for the consulting firm that is hired to
implement the Environmental Construction Compliance Monitoring
Program. The NYSDEC will approve the Program and the review the
resumes of the monitors, if desired by that agency. The monitors will
be paid by SLW. The monitors will send their reports to the
consulting firm and SLW and applicable agencies will be provided the
reports in a timely manner.
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SDEIS Response 73.12 Foundations will be removed to a depth of 48 inches below grade and
collection cables will not be removed.
CULTURAL RESOURCES
DEIS Response 1.17 Section 3.7 of the SDEIS includes discussion of historic preservation
studies completed and their conclusions. Review correspondence
provided by the NYSHPO was also included in Appendix F of the
SDEIS.
DEIS Response 1.18 Archaeological studies to identify pre-contact and historic period sites
have been completed and their results were included in Appendix H of
the SDEIS.
DEIS Response 4.8 An Architectural study was performed in accordance with SHPO
requirements, as was included in the SDEIS. Site plan and profile
drawings will be provided as requested in the Site Plan Review.
DEIS Response 4.34 Please see Appendix H of the SDEIS.
DEIS Response 9.1 Please see SDEIS Exhibit 3.7.1, Historic Properties Evaluated within
the Five Mile Area of Potential Effect, detailing the proximity of
Historic Properties to proposed turbine locations within the SLW
Project area. As described in Appendix C-6 of the FEIS (Residential
Well Study and Mitigation Plan), "Construction activities can generate
ground-transmitted vibration forces that may result in ground
disturbance and can potentially affect existing features proximal to the
activity. These generated vibrations attenuate over distance from the
source. The magnitude of the vibration and the attenuation rate are
related to the construction method used for excavation (e.g.,
mechanical, blasting), type of construction equipment (e.g., hydraulic
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excavators, front end loaders), and conductivity of the surface and

subsurface substrates (e.g., sands, clays, frozen soils, bedrock)...it is
assumed that standard excavation equipment would be used and no
blasting would be required Using such equipment and techniques,
vibration effects typically are below levels of perception at distances
of 500 feet from the source. Even considering the use of controlled
blasting, construction vibrations should be well below the threshold for
residential damage." No stone buildings within the Project area are
located within 500 feet of a proposed turbine location.
DEIS Response 12.5 The commenter has not identified a source for the information she
believes to be true. Neither SLW, nor SHPO has identified any
information documenting the existence of an Indian burial ground
traversing the abandoned railroad bed. However, the USACE will
formally consult with the Onondaga nation regarding routing the
overhead transmission line along the old railroad bed, as part of its
review of the Section 404 permit application.
DEIS Response 14.5 Please see responses to Comments 12.5, 48.1 and 51.1.
DEIS Response 18.1 Please see “Letter from Nancy Herter, SHPO, to Blayne Gunderman,
Acciona Energy, October 30, 2008” and “Letter from Nancy Herter,
SHPO, to Blayne Gunderman, Acciona Energy, July 16, 2008” in
Appendix F – Agency Correspondence of SDEIS: “The SHPO has
reviewed the Phase IB Cultural Resources Investigation Report,
prepared by TRC and dated February 6, 2008m in accordance with
Section 106 of the National Historic Preservation Act of 1966, as
amended. Based upon this review, the SHPO has no further
archaeological concerns.
DEIS Response 21.9 Please see response to Comment 48.1.
DEIS Response 31.1 Since the DEIS, SLW has consulted with the Towns to develop a
Visual Mitigation Plan. In general, the Towns have identified various
projects that would mitigate visual impacts. They include restoration
of the Fire Hall clock in Cape Vincent, painting structures at the
Tibbett's Lighthouse, restoration of vaults at a public cemetery, and
burying of a transformer at the Tibbett's Lighthouse. SLW is also
supporting a vegetative screening fund, through which applicants may
seek funding for vegetative plantings to screen their historic homes
from visual impacts associated with facility structures.
DEIS Response 33.1 Please see responses to Comments 12.5, 50.1 and 51.1.
DEIS Response 38.3 The Project will participate in a MOA with USACE and NYSHPO
regarding mitigation of visual impacts. The MOA is proposed to
include restoration of the Fire Hall clock in Cape Vincent, painting
structures at the Tibbett's Lighthouse, restoration of vaults at a public
cemetery, and burying of a transformer at the Tibbett's Lighthouse.
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SLW is also supporting a vegetative screening fund, through which

applicants may seek funding for vegetative plantings to screen their
historic homes from visual impacts associated with facility structures.
DEIS Response 48.1 The SDEIS (January 2009: Table 3-26) identified visual impacts on
historic resources of local and state significance. SLW is in
consultation with the Town of Cape Vincent and the NYS OPRHP
concerning appropriate mitigation measures. A Memorandum of
Agreement will detail actions SLW will take, in agreement with
OPRHP, to mitigate adverse effects of historic resources.
DEIS Response 50.1 Archeological reports have been submitted to OPRHP who have
issued a letter that the Project will have no adverse effect on
archeological resources. Plans for mitigating adverse effects on
historic buildings is currently being negotiated between SLW, the
Town of Cape Vincent and OPRHP (Please see response to Comment
48.1).
DEIS Response 51.1 Archeological surveys have been completed and reports have been
submitted to OPRHP. OPRHP has issued a letter stating its conclusion
that the Project will have no adverse effect on archeological resources.
Archeological reports are usually considered confidential, but findings
have been summarized in the DEIS and SDEIS (Section 3-7). The
USACE will initiate consultation with the Onondaga Native American
tribe regarding impacts on their cultural resources. In addition, a
proposed Unanticipated Discoveries Plan (located in the FEIS in
Appendix C-9) details the procedures to follow if archeological sites or
human remains are unexpectedly discovered during Project
construction.
DEIS Response 69.1 Phase I archeological and architectural reports have been submitted to
SHPO and commented upon. Also see response to Comment 18.1.
DEIS Response 71.2 Comments noted. Please see responses to Comments 48.1 and 51.1
DEIS Response 79.1 Neither SHPO nor the project's Architectural Resources Assessment
identifies the Dodge Bay Cemetery as a significant historical resource
or eligible resource.
DEIS Response 83.1 Historical background information was presented in the Phase 1A
cultural resources report provided in the SDEIS in Appendix H.
Revised Project layouts reduced impacts on historic buildings. Please
see response to Comments 9.1 and 48.1.
DEIS Response 86.1 Please see response to Comment Letter 48.1.
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SDEIS Response 5.1 Comment noted. The referenced Appendix is located in Appendix A
of the FEIS.
SDEIS Response 5.2 The Planning Board requested specific visual simulations be
performed, in their comments on the project's DEIS. These included:
"A revised visual impact study will need to be done based on the new
Project map. This revised visual impact study is to include at least 2
locations from the waters of Lake Ontario inland and 3 locations from
the waters of the St. Lawrence River inland. There is to be an
additional location taken from on the water in the vicinity of the
Tibbets Point Lighthouse focusing downriver. Another such location is
to be taken from the Cedar Point State Park area while on the water
looking back toward the Tibbets Point Lighthouse. Further explanation
of the visual study methodology will need to be submitted to
substantiate the study."
SLW provided these simulations and methodology narrative in its
SDEIS. Although specific vantage points are indicated on each
simulation, because of the relatively flat topography of the area,
turbines will be seen, except where vegetative screened. SLW is
working with the Town to manage impacts to significant resources,
whether that is screening or other type of mitigation.
The CV Planning Board has not requested that the Project perform any
additional simulations. The additional simulations provided in the
SDEIS give an adequate representation of how the facility will visually
impact the area.
SDEIS Response 5.3 Comment noted.
SDEIS Response 5.4 SLW has been working with the local communities (Julie Gosier in
Lyme, and Tom Rienbeck in Cape Vincent) to address visual impacts
and mitigation efforts to historically-significant structures and
locations. SLW is interested in discussing screening with members of
the communities; however, it is unlikely that all visual impacts can be
addressed in that way. Some of the mitigation projects that the Towns
have indicated they are interested in supporting include having the
Tibbett's Point Lighthouse Buildings repainted, burying the
Lighthouse Transformer (moving underground to restore the
lighthouse grounds to original appearance), fence restoration to the
Market Street Cemetery, restoration of the Cape Vincent Fire Hall
clock, and potential renovation of two vaults at the Three Mile Bay
Cemetery. SLW will include OPRHP on communication regarding
this topic.
SDEIS Response 5.5 GPS data was sent to OPRHP on 7-1-08.
SDEIS Response 6.1 Comment noted. The Project, as currently proposed, is below the 80
MW jurisdictional threshold for issuance of a CPCN by the PSC
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SDEIS Response 6.3 SLW has taken an approach to siting the wind farm that would
accommodate community concerns regarding size of the Project while
still designing a project of viable size, economically. SLW will
continue to work with the community to avoid and minimize visual
impacts of the facility. It is unreasonable to avoid all impacts, and
SLW understands that the Project will ultimately have an adverse
effect on visual resources. SLW will work with the Towns or
NYSHPO to mitigate unavoidable impacts.
SDEIS Response 19.3 Setbacks for the Project have been established by the Cape Vincent
Planning Board. SLW has met, or exceeded, all setback requirements,
including the setbacks from the River and the Village. The Project
will not affect the historic designation of Mr. Brooks' home, but
regardless, a fund will be set up with the Town to provide vegetative
screening for qualifying applicants.
The Project visual characteristics were thoroughly assessed in Section
3.8 of the SDEIS. Pertaining to historic resources, 12 of the 38
identified historic properties/districts have visibility indicated. The
other 26 are either screened sufficiently, have no visibility, or are
filtered by other buildings or structures. SLW has developed a
mitigation plan to offset or eliminate the views from these important
resources, in order to preserve the culture of the community. This plan
is currently under review by members of the Town, and will be sent to
SHPO in the near future.
SDEIS Response 20.8 The analysis of potential impacts on historic properties establishes that
there will not be significant adverse impacts on such properties. To
mitigate the impacts that may occur, SLW is proposing several types
of mitigation. In general, the Towns have identified various projects
that they would be supportive of, in relation to mitigation of visual
impacts. They include restoration of the Fire Hall clock in Cape
Vincent, painting structures at the Tibbett's Lighthouse, restoration of
vaults at a public cemetery, and burying of a transformer at the
Tibbett's Lighthouse. SLW is also supporting a vegetative screening
fund, through which applicants may seek funding for vegetative
plantings to screen their historic homes from visual impacts associated
with facility structures.
SDEIS Response 20.9 The Applicant has prepared an Archaeological Unanticipated
Discovery Plan, as set forth in Appendix C-9 of the FEIS to be
implemented during construction activities. The plan includes the
procedure for notifying the SHPO of the discovery. At this point,
compensation has not been discussed with the Onondaga Nation. The
Onondaga Nation has had a chance to review the Archeological Report
and has not made comments.
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SDEIS Response 20.10 No known archaeological resources were identified in Dodge Bay
based upon SLW’s literature search. In addition, SHPO has not
identified Dodge Bay as a significant archeological resource in its
assessment of the area.
SDEIS Response 27.1 Comment noted. The SEQR process for the Project has complied with
or exceeded all applicable requirements. There have been multiple,
and extended, opportunities for public comment.
CUMULATIVE IMPACTS
DEIS Response 1.2 The nearest known wind project to SLW is the Maple Ridge project
roughly 40 straight lines miles to the southeast in Lewis County. Post
construction monitoring studies at this site based on approximately 5
months of study estimated that between approximately 3 and 9 birds’
fatalities per turbine occurred per year. Within Jefferson County there
are currently three proposed wind projects which, based on public
information provided about these projects, could result in up to 288
turbines. In addition, Wolfe Island Canada includes 86 turbines.
Provided all these projects are constructed and including SLW, there
could be up to 374 turbines within an approximately 20 mile radius of
SLW. Under the above described scenario and if the monitoring
results from Maple Ridge are accurate, then between approximately
1100 and 3400 bird fatalities could result annually from all 4 projects.
It is important to place potential bird mortality in context. While
direct impacts from wind turbines to birds have been a concern, the
relative percent of bird deaths from wind turbines, when compared to
other sources of human caused bird mortality, is small. For example,
based on information published in scientific literature it is estimated
that up to 100 times more birds die from collisions with buildings and
windows than wind turbines (Erickson et al. 2001). The contribution
from wind turbines to the total annual bird mortality from human
sources is relatively small and not expected to cause cumulative
impacts to be significant provided they are not already significant.
DEIS Response 1.16 Sections 4.1.7 and 4.1.8 of the SDEIS contain the requested
assessment.
DEIS Response 2.43 The proposed BP Cape Vincent wind project is located directly south
of the St Lawrence site. The proposed PPM Horse Creek Wind project
is located south and east of the St. Lawrence site. Additional
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proposals for the area are unknown but possible due to the wind
potential in the Cape Vincent peninsula region. Cumulative effects on
birds and bats for all three known projects were discussed in Section 4
of the SDEIS.
DEIS Response 4.48 Please see Response to Comment 4.47.
DEIS Response 4.49 Comment noted.
DEIS Response 21.7 Please see response to 113.17a and 113.3.

DEIS Response 65.2 There is no evidence that operation of wind farms will increase ozone
levels.
DEIS Response 95.1 Please see response to Comments 113.17a and 113.3.
DEIS Response 113.3 An updated shadow flicker report is included as Appendix C-10 of the
FEIS. An updated Noise Modeling Assessment is included as
Appendix C-4 of the FEIS.
DEIS Response 113.6 Additional discussion of Cumulative Impacts was provided in Section
4.0 of the SDEIS. Please see Response for Comment 39.1 for a
discussion of mitigation associated with transmission interconnection.
DEIS Response 113.8 Please see Section 2.8.2, Site Restoration Process Description in the
SDEIS: "In accordance with the guidelines of the New York State
Department of Agriculture and Markets, a monitoring and remediation
period of two years immediately following the completion of any
decommissioning and restoration activities will be provided. The two-
year period allows for the effects of climatic cycles such as frost
action, precipitation and growing seasons to occur from which various
monitoring determinations can be made. Remaining agricultural
impacts can be identified during this period and follow-up restoration
efforts will be implemented."
DEIS Response 113.9 The Project layout complies with setback criteria established by the
Town of Cape Vincent Planning Board.
DEIS Response 113.13 Numerous studies have shown that real estate values are likely not to
be negatively affected. Please see response to Comment 11.7. A well
survey was included in the FEIS in Appendix C-6. Modern turbines
have sensors that trigger turbine shutdown when ice collects on blades.
There is no documented proof of the existence of harmful infrasound
from turbines. A recent white paper developed by a group of doctors
and acoustic scientists explains that “Infrasound at a frequency of 20
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Hz (the upper limit of infrasound) is not detectable at levels lower than

79 dB. Infrasound at 145 dB at 20 Hz and at 165 dB at 2 Hz can
stimulate the auditory system and cause severe pain. These noise
levels are substantially higher than any noise generated by wind
turbines. The US Food and Drug Administration (FDA) has approved
the use of infrasound for therapeutic massage at 70 dB in the 8 to 14
Hz range. In light of the FDA approval for this type of therapeutic use
of infrasound, it is reasonable to conclude that exposure to infrasound
in the 70 dB range is safe. According to a report of the National
Research Council (NRC), low frequency sound is a concern for older
wind turbines but not the modern type.” SLW will incur compensation
expenses for impacts that are not anticipated, but that it is deemed to
be responsible for, through the Complaint Resolution Process. That
Process is described in a revised Plan in Appendix C-11 of the FEIS.
DEIS Response 113.15a From Section 2.8.3, Cost of Decommissioning from the SDEIS, "The
estimated cost of decommissioning and expected salvage value of
wind components will be reassessed and certified by a Professional
Engineer at appropriate intervals throughout operation of the project.
SLW will pay for any costs of decommissioning that are not covered
by the salvage value."
DEIS Response 113.17a A three-year study plan was not required to adequately assess impacts
to birds and bats. SLW has been in coordination with NYSDEC and
USFWS to address inadequacies they felt required more information.
SLW has conducted a multitude of bird and bat studies, as can be
accessed on the website or in the SDEIS and this FEIS. In addition,
SLW has committed to a Wildlife Protection Plan, which can be
reviewed in draft form in Appendix C-13. The visual analyst for the
Project was identified in the DEIS as Saratoga Associates. Credentials
for Matt Allen, consultant, can be found on Saratoga Associates
website at www.saratogaassociates.com. Rion NL-32 and NL-22
sound level meters (ANSI Type 1 and 2, respectively) were used at 5
of the 6 positions. A Norsonic 118, ANSI Type 1, 1/3 octave band
analyzer was used at Position 6 to record the frequency spectrum of
the sound as well as the overall A-weighted levels measured by the
other instruments. The meters were all enclosed in watertight boxes
with the microphones supported away from the cases to minimize any
local reflections. The 5 Rion microphones were protected from wind-
induced self-noise by extra-large 180 mm (7 inches) diameter foam
windscreens (ACO Model WS7-80T). The Norsonic meter had a
special environmental microphone housing (Norsonic Type 1212)
where the microphone tip is protected from wind by mesh covered
slots and an external foam windscreen.
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SDEIS Response 2.3 The poles that are proposed for the SLW Project will be physically
adequate to carry lines that may be needed by BP's proposed project.
SLW has, and will continue to work with BP on an agreement for
sharing a transmission line.
SDEIS Response 11.3 Cumulative visual impacts are discussed in the SDEIS between pages
4-14 and 4-16. The SDEIS indicates that visual impacts of the St.
Lawrence and Cape Vincent projects, together, would be perceived as
if the St. Lawrence project were approximately 3 times its proposed
size (the Cape Vincent project will have a greater impact than the St.
Lawrence project, since it is greater in size). The SDEIS states that the
two projects, if both were built, would encompass the majority of land
area in the Town of Cape Vincent, and would be dominant and
widespread. SLW proposes to work with the Town to minimize these
impacts and mitigate them to the extent practicable through vegetative
screening and historical restoration projects.
SDEIS Response 39.2 The Project footprint presented in the FEIS layout consists of
approximately 80 acres (total) for turbines, including permanent gravel
pads at each turbine location, 14.7 miles of permanent roads, and a
total Project site under lease agreement of up to 7849 acres.
SDEIS Response 41.2 Cumulative effects under the Endangered Species Act (ESA) are
effects of future non-federal actions that are reasonably certain to
occur within the action area in the foreseeable future. These types of
actions include:
x continued population growth, particularly in Cape Vincent
Township;
x new housing developments and subdivisions to accommodate
population growth;
x increased infrastructure (roads, utilities) to accommodate new
developments;
x increased gravel/materials mining to accommodate development
and infrastructure;
x increased energy development including other wind projects
without a federal nexus;
x logging of state and private forests;
x future agriculture practices on private land; and
x unknown stochastic events such as disease and climate change.
The proposed SLW Project will not contribute to population growth
and associated development activities such as new housing
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subdivisions, but it is designed to accommodate future power needs

associated with growth and development. Jefferson County, including
Cape Vincent Township, is undergoing noticeable population growth.
Approximately 23 percent of the total number of housing structures
built in Cape Vincent Township since 1940 has been between 2001
and 2008 (Table 6). A number of scattered rural residential home sites
and subdivisions have been established in Cape Vincent Township and
in particular along the coastal regions of Lake Ontario. The City of
Watertown, approximately 20 miles to the southeast within the
fall/winter action area has also experienced substantial growth over the
past decade necessitating infrastructure upgrades along the I-81
corridor between Watertown and Glen Park. Developments have the
effect of reducing agricultural land and forests and activities associated
with those landscapes such as farming, livestock production, and
logging. These types of activities may contribute cumulative effects to
Indiana bats by reducing suitable summer habitat, creating more
disturbances, reducing foraging and secluded sheltering/roosting
opportunities, and creating more collision hazards. Agriculture in
Jefferson County has likely benefited Indiana bats by providing the
habitat mosaic suitable for Indiana bat occurrence. Reduction of
agriculture, forests, and open rural space in Jefferson County due to
housing, subdivisions and other development reduces the amount of
suitable habitat for Indiana bats.
Due to the windy nature of Jefferson County and the Cape Vincent
peninsula, at least two additional wind projects have been proposed for
the region: the Cape Vincent wind project and the Horse Creek wind
project, and one other Wolfe Island, Canada, is currently operational.
The proposed Cape Vincent project would be located due south of
SLW and the proposed Horse Creek Project approximately six miles
southeast of SLW. The Wolfe Island, Canada project is located
approximately two miles northeast of SLW. With the exception of
Wolfe Island, similar baseline studies including mist-net surveys for
Indiana bats have occurred at these sites and have documented Indiana
bat occurrence throughout the region (see Kerns et al. 2007b; Woodlot
Alternatives 2006). As with SLW and the abundance of wetland and
waters of the U.S. in the Cape Vincent region, it is unlikely that either
of these projects could be constructed without requiring a permit from
the USACE, for potential impacts to water resources. This federal
permit requirement would require that these projects under go similar
review under the ESA regarding potential impacts to Indiana bats.
Similarly, additional projects in the region such as highway
construction under federal jurisdiction, and development on Fort Drum
would each necessitate review under Section 7 of the ESA.
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The magnitude of cumulative effects on Indiana bats is difficult to

measure. While cumulative effects to Indiana bats may be occurring
due to increased growth and development in the area, substantial
catastrophic events such as white nose syndrome (WNS) are likely to
have greater cumulative effects on Indiana bats than the Project itself
or continued human encroachment on Indiana bat habitat. White nose
syndrome is a poorly understood ailment related to the death of
thousands of bats in the northeastern U.S. Loss of winter fat stores,
pneumonia, and the disruption of hibernation and feeding cycles are
associated with the death of infected bats. The disease is proving
catastrophic to infected bat populations with mortality rates exceeding
90 percent over two years for infected caves.
SDEIS Response 54.11 The commenter has not been specific in this comment, and it is,
therefore, impossible to identify the specific cumulative impacts of
concern to him. However, the SDEIS develops a complete analysis of
cumulative impacts from the Project. Please see Section 4 of the
SDEIS for this analysis.
SDEIS Response 55.1 Please see response to Comment 54.11
SDEIS Response 64.1 Please see response to Comment 25.14. See also Response to
Comment 1.9.
SDEIS Response 73.41 Please see Appendix C-4 for the revised noise impact analysis for the
final layout. In addition, a thorough analysis is located in Section
2.3.3 of the FEIS.
SDEIS Response 73.42 The commenter did not provide specific enough comments to address
this in a reasonable fashion. SLW stands by the potential impacts it
will have on the environment in its SDEIS and this FEIS. In response
to the noise comment – there is a revised noise impact analysis in
Appendix C-4 and relevant sections of this FEIS that may more fully
address any questions or concerns that the commenter may have
relating to noise.
DECOMMISSIONING
SDEIS Response 3.3 Approximately 1.6 miles of the transmission line are proposed to run
through Ashland Flats Wildlife Management Area in Cape Vincent
and Lyme. The State Department of Environmental Conservation
controls this area. The NYSDEC will be consulted to determine the
appropriate decommissioning activities. Wetlands are also associated
with the abandoned railroad corridor. In addition to the NYSDEC, the
US Army Corps of Engineers (USACE) also regulates certain
activities in wetlands; therefore, the USACE may also be a potential
governing authority. As with construction, potential impacts to
wildlife, wetlands, and the water line, associated with
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decommissioning, will also have to be considered and the magnitude

of unavoidable impacts to these resources would influence the removal
decision. Poles will be sawn flush with the ground unless a
government agency or landowner agreement requires removal at a
greater depth.
SDEIS Response 3.4 Decommissioning bonding will be established as required in site plan
review.
SDEIS Response 4.21 At the end of project life, it will be a standard procedure that all
foundations will be removed to a depth of 48 inches below grade,
unless the landowner requests differently. Access roads will be
removed at the landowner's request. Underground collection cabling
will not be removed, unless necessary, as it is typically more
environmentally impactful to remove them than to leave them intact.
In addition, the O&M Building/Substation will be removed to 48
inches below grade.
SDEIS Response 16.6 For the transmission line decommissioning the conductors will be
removed and stored in a pre-approved location. The supporting poles
will be removed and the holes filled in with compatible sub-grade
material. In areas where environmental damage from complete
removal may outweigh the benefits, the poles will be sawed flush with
the surrounding grade (determined by appropriate governing
authority). The poles will be stored in a pre-approved location. Stored
conductors and poles will be later removed and transported to
appropriate facilities for salvage or disposal. Bonding for
decommissioning cost will be addressed in Site Plan Review.
SDEIS Response 20.3 Bonding for project decommissioning will be addressed in Site Plan
Review. SLW also anticipates that it will be required to post bonds for
restoration of public roads utilized by SLW for transportation of
oversized loads and construction equipment.
SDEIS Response 25.64 Funding of decommissioning cost will be addressed in Site Plan
Review as required by the Planning Board.
SDEIS Response 54.4 Concrete foundations will be removed to a depth of 48 inches below
grade.
SDEIS Response 73.19 SLW anticipates that any new owner will be required to adhere to all
requirements imposed upon the Project in the special use permit. All
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commitments the SLW has made will be required by any new

owner/operator. Yes.
SDEIS Response 73.47 Funding of decommissioning will be established in Site Plan Review
as required.
SDEIS Response 73.51 St. Lawrence Windpower, LLC is responsible for repair,
decommissioning and restoration of the proposed project.
ECOLOGICAL RESOURCES
DEIS Response 1.1 The final report for the avian and bat pre-construction studies is
complete and was included in Appendix E of the SDEIS. Mitigation
measures and are discussed in the draft Wildlife Protection Plan
(WPP) in Appendix C-13 of the FEIS and adaptive management
measures are described in the Indiana bat Biological Assessment (BA)
in Appendix C-3 of the FEIS.
DEIS Response 1.6 An Invasive Species Plan has been completed and was provided as
Appendix D to the SDEIS
DEIS Response 1.11 SLW will avoid Blanding's Turtle habitat to the extent possible by
installing and maintaining silt fence around potential habitat that may
be influenced by the construction of the Project during construction
and restoration. In addition, SLW will hire a biological monitor
during construction near those areas to ensure that the area is clear of
Blanding's Turtle prior to daily construction efforts. A complete
explanation of avoidance and minimization techniques is described in
the draft Wildlife Protection Plan in Appendix C-13 of the FEIS.
DEIS Response 2.4 Comment noted. The design of the Project avoids forested areas to the
maximum extent practicable.
DEIS Response 2.7 Study results did not indicate that bird or bat use was significantly
more concentrated in one area than another. Results of the site studies
do not suggest that relocating turbines within the proposed Project area
would alter avian risk or change avian impacts. However, SLW has
moved turbines to avoid a sensitive roosting area for the short-eared
owl.
DEIS Response 2.8 During Project construction, bird nests located on or along Project
roads, turbine pads or other infrastructure during the breeding season
for most birds in the region (McGowan and Corwin 2008; April 15 –
August 1) will be noted and marked by a Project biologist in order to
minimize the risk that active nests would be destroyed. All
construction employees will receive training pertaining to sensitive
environmental issues and known nesting areas on the site (Please see
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Section 8.1). A professional environmental monitor will provide

expertise and guidance, and ensure the enforcement of environmental
protection criteria outlined in the permits. During operations, the site
manager will notify and train all SLW personnel of the location of
nests located within infrastructure. Preventative measures will be
taken to minimize the risk of destruction of the nest (e.g. flagging,
signs or cone placement) and avoidance of the nest site to minimize
disturbance of the nest will be implemented to the extent feasible. A
draft Wildlife Protection Plan is set forth in Appendix C-13 of the
FEIS.
DEIS Response 2.16 The referenced statement was included in the SDEIS, on page 3-44.
DEIS Response 2.21 The St. Lawrence wind project will not impact or interfere with efforts
to establish the SLWGMD. Please see response to Comment 17.17 on
the SDEIS.
DEIS Response 2.22 As previously stated in Responses to Comment 1.4 and Comment
2.17, potential natural resource impacts are limited to minor wetland
and associated intermittent streams crossings. The methodology used
to determine such impacts was described in Section 3.2 and Appendix
C of the SDEIS, and is further described in the Joint Permit
Application.
DEIS Response 2.23 Section 3.3 of the SDEIS contained an updated discussion of reptiles
and amphibians potentially found in the Project area and the potential
impacts on such species. Appendix E of the SDEIS included a report
of potential Blanding’s Turtle habitat and how the Project can
minimize impacts to the Blanding’s Turtle. Please also see response to
Comment 1.11.
DEIS Response 2.24 The initial assessment of presence/absence of mammals in the
proposed Project area was based on evaluation of habitat types present.
Initial assessment of threatened and endangered species was
determined by querying the New York Natural Heritage Program
databases. Listed bat species are discussed in the bat specific section
(3.3.3) of the SDEIS. Specific bats surveys were conducted in 2006-
2007, and have shown the presence of the Indiana bat, a mammal, near
the Project. SLW has developed a Biological Assessment of the
Indiana bat, which is located in Appendix C-3 of the FEIS.
Avoidance, minimization, and mitigation measures are found in that
document and also in the draft WPP in Appendix C-13 of the FEIS.
DEIS Response 2.25 The SDEIS included modified text indicating that Indiana bat is a state
and federally listed endangered species. Further information is
provided in the FEIS.
DEIS Response 2.26 Please see response to Comment 2.24 and 2.25.
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DEIS Response 2.27 Comment noted. Please see responses to Comments 2.24 and 2.25.
DEIS Response 2.28 Please see response to Comments 1.14, 2.10, 2.16, and 2.17 of the
SDEIS.
DEIS Response 2.29 Please see the revised analyses presented in Section 3.3.7 and
Appendix E of the SDEIS, the Biological Assessment of the Indiana
bat included in Appendix C-3 of the FEIS, and the responses to
Comments 1.9, 1.14, and 1.15.
DEIS Response 2.30 The avian and bat studies report in Appendix E of the SDEIS
compares raptor migration passage rates in the Project area to Derby
Hill and other hawk watch sites in New York. The configuration of
the coastline around the Cape Vincent peninsula would require raptors
following the lake shore to move westward before continuing on to the
north. It is more likely that raptors that have moved through the Derby
Hill area continue on a more northerly track and pass east of the site.
It is also more likely that raptors migrating through the Cape Vincent
area are more dispersed due to fewer topographic features and land
forms that could concentrate raptor movement.
An analysis of flight path direction for all raptors observed during the
raptor migration surveys was conducted to help determine the
significance of migration through the area. The analysis looked at the
dispersion of flight paths of raptors recorded during the two years of
raptor migration surveys. The results of the analysis corroborate the
movement pattern suggested above indicating that there is not a
significant concentration of migrant raptors in the Cape Vincent area.
The analysis showed a general trend in northward and southward
movement during the appropriate season, however, the dispersion of
movement directions was not significantly different than random. The
analysis indicated abundant scatter in movement direction suggesting
movement of local raptors was considerable. Had there been a
substantial migration through the area the northerly or southerly
directions would have been significantly greater.
DEIS Response 2.31 The report containing avian migration data in the vicinity of the
Project Site is complete and available for review in Appendix E of the
SDEIS. Results of the study and subsequent analysis of raptor flight
data do not indicate that the St. Lawrence project area experiences
migration that is greater than other sites studied in New York or other
eastern states.
DEIS Response 2.32 Section 3.3.5 of the SDEIS presented project-specific breeding bird
information. The Project sponsor is unaware of any efforts to increase
productivity of grassland and waterbirds in the area. Assuming the
service's efforts include lands in the Project area, the Project is likely
to protect these areas from other development that may eliminate
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grassland areas entirely such as residential subdivision and second

home developments. Alternative developments in the Project area are
likely to facilitate an increase human growth in the region with
additional indirect effects such as increased traffic, infrastructure, pets,
recreation, and vegetation/habitat change that would further impact
grassland nesting birds.
DEIS Response 2.33 The report containing winter raptor use data from one year, and one
additional winter, of site surveys is complete and available for review
in Appendix E of the SDEIS.
DEIS Response 2.35 The final report for the avian and bat pre-construction studies is
complete and is available for review in Appendix E of the SDEIS. The
report includes a discussion of the results and potential impact
assessment based on the site specific studies. In addition, SLW
conducted a spring breeding bird survey, focused on threatened and
endangered species that may habitat in the Project area in Spring 2009.
That report is available in Appendix C-2 of the FEIS.
DEIS Response 2.36 A draft monitoring plan was prepared and has been provided to the
agencies for review and comment. A draft of the revised Plan was
available in Appendix E of the SDEIS. The suggested mitigation
measure is noted and has been considered.
DEIS Response 2.37 Please see Appendix C-14 of the FEIS for a preliminary Construction
Environmental Monitoring Plan. Trained biologists will be hired to
clear areas prior to construction efforts in order to avoid and minimize
injury or death to wildlife. Workers will also be trained in how to
identify, report, and handle impacted wildlife.
DEIS Response 2.38 Thank you, these protocols were used in the Indiana bat studies
performed.
DEIS Response 2.39 The bald eagle has been de-listed and is no longer a threatened species.
However, SLW has recently obtained the Service's new regulation
concerning bald and golden eagles. Because no eagle nests have been
identified, either through data gathered from the NYSDEC or the
Project bird studies, and the use of the Project area by eagles is
negligible, no impacts to bald or golden eagles is anticipated. A draft
Biological Assessment related to the Indiana bat is contained in
DEIS Response 2.40 Because turbine placement will not occur directly on identified
wetlands, the largest potential adverse affect on Blanding’s turtle
populations in the vicinity of the Project is likely to be during the
construction phase when roads and equipment are in heavy use. SLW
has discussed impacts to Blanding's Turtle with NYSDEC Region 6.
SLW has moved one access road (to Turbine 32) and has agreed to
install and maintain silt fence near potential Blanding's Turtle habitat
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that may be affected by Project construction. In addition, a biologist

will be hired to clear the area prior to construction activities, in order
to ensure no Blanding's Turtles are in the area. Please see Section 3.3
and Appendix E of the SDEIS for a further discussion of potential
impacts on Blanding’s Turtle and related mitigation measures.
DEIS Response 2.41 The assessment of potential impacts on bald eagles is revised in
Section 2.2.2 of the FEIS, after finalization of the new Eagle Act rules.
DEIS Response 2.42 Mist-netting was performed for 2 years. Reports addressing the results
of mist-netting studies were presented in Section 3.3 and Appendix E
of the SDEIS. SLW has been in coordination with the USFWS,
USACE, and NYSDEC to determine potential effects to the Indiana
bat. The USACE has developed a BA for Indiana bats for the Project
and will initiate formal consultation with the USFWS to determine
conservation measures for avoiding, minimizing, and mitigating
potential impacts from the Project on Indiana bats. A copy of the BA
is located in Appendix C-3 of the FEIS.
DEIS Response 4.13 An expanded discussion of potential impacts on Significant Fish and
Wildlife Habitats (SCFWH) adjacent to or downstream from the
Project area was contained in Section 3.3.8 of the SDEIS.
DEIS Response 4.14 These coastal resources are greater than 0.5 miles from the proposed
Project and will be unaffected by the Project with the possible
exception of French Creek, which is likely to be minimally affected by
the Project.
DEIS Response 4.16 The Avian and Bat Studies Interim Report (May 2007) was included in
the SDEIS and circulated with appropriate notice to involved agencies
and the public.
DEIS Response 4.17 Multiple years of raptor studies have been completed and were
discussed in Section 3.3 and Appendix E of the SDEIS.
DEIS Response 4.18 The avian impact assessment for St. Lawrence is based on results from
monitoring studies in the eastern U.S., including the available results
from the Maple Ridge project. Please see Section 3.3 of the SDEIS.
DEIS Response 4.19 While not every portion of the current Project area was covered in the
studies; the surveys are applicable to the whole Project area due to
similarity of habitat and landform. In addition the applicability of
nocturnal migration surveys over a much larger area has been
confirmed by the NYSDEC. Only transmission facilities are proposed
for the Wildlife Management Area and Coastal Zone Habitats.
DEIS Response 4.20 Field studies in the Project area have not found that avian and bat use
or migration over the site suggest that impacts would be greater than
other wind projects in New York. A post construction monitoring plan
is included in Appendix E of the SDEIS and will be implemented to
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determine the level of avian and bat impacts to be compared to other

wind projects. In the event that direct fatality impacts are significantly
greater than other reported impacts from projects in New York or
determined to be causing a significant impact on avian or bat
populations, then adaptive management principles will be applied by
implementing facility management or compensatory mitigation to
reduce impacts to acceptable levels or benefit species populations to
compensate for impacts. Potential impacts to and mitigation measures
for Indiana bats will be addressed through formal consultation with the
USFWS in compliance with the Endangered Species Act.
DEIS Response 4.21 Results of the studies are presented in Table 3-15 and Appendix E of
the SDEIS. During the breeding bird survey 1,040 individual birds of
59 different species were observed in the Project area. The studies
were conducted during the appropriate time of year to address the
resources of concern.
DEIS Response 4.22 Results of the studies are presented in Table 3-15 and Appendix E of
the SDEIS. The winter surveys focused on waterfowl and raptor use of
the Project area. Based use, defined as the number of birds Please
seen per survey, unidentified gull species and Canada goose were the
two most common wintering species in the Project area. The most
common raptor observed during the winter season was rough-legged
hawk. For most raptor species only a few individuals were observed in
the winter.
DEIS Response 4.24 Additional analyses of potential impacts on threatened and endangered
species studies are presented in Section 3.3.7 of the SDEIS and
Section 2.2 of the FEIS.
DEIS Response 4.25 Only transmission line facilities are planned for construction in the
Ashland Flats WMA. No transmission line facilities will be located in
areas of the Ashland Flats Wildlife Management Area where habitat
manipulation and clearing of forest cover for grassland species
management has occurred. St. Lawrence Wind power encourages
preservation of grassland ecosystems and construction of the Project
will likely preclude further development and conversion of grassland
within the Project area.
DEIS Response 4.31 Visual effects of the Project on coastal areas and impacts on historic
resources are detailed in Appendix H of the SDEIS. Effects of
construction on coastal resources, such as sedimentation and erosion
from a project site on vulnerable significant habitat locations
downstream from the construction site are discussed in greater detail in
the Storm Water Pollution Prevention Plan (SWPPP) in Appendix C-8
of the FEIS.
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DEIS Response 6.1 The information was included in the report, and is located in Appendix
E of the SDEIS. The updated map showing the spring and fall radar
survey locations was provided to NYSDEC.
DEIS Response 6.2 The information was included in the report, and is located in Appendix
E of the SDEIS.
DEIS Response 6.3 This information was provided to Brianna Gary, directly, at NYSDEC.
A spreadsheet of observation data including flight direction, distance
to birds observed, and maps of raptor movements and the analysis of
raptor flight directions was provided.
DEIS Response 6.4 This was corrected in the SDEIS.
DEIS Response 6.5 Overall the data for flight height is used for calculating a relative index
for exposure of a species to the proposed turbines. The index is based
on a species flight behavior and takes into account of varying
conditions over the study period by averaging across all observations
for that species. In most cases, the index is based on relatively few
observations for any given species. Dividing the information into
seasons further dilutes the number of observations used in calculating
the risk index and therefore is more likely to misrepresent the true
average behavior of a species.
DEIS Response 6.6 Most proposed wind projects in New York are not located in or near
hawkwatch sites and as such, migrant raptor numbers are likely to be
small. When compared to the nearby Horse Creek Windfarm, raptor
migration passage rate for SLW was very similar. Overall spring
passage rate at the Horse Creek site was ~12 raptors per observer hour.
This was greater than the St. Lawrence site in 2006 (~7.5 raptors per
observer hour) but less than in 2007 (~15 raptors per observer hour). It
is also likely that the passage rate at St. Lawrence is inflated due to the
methods that were used. Survey days and times were selected when it
was expected that more raptors would be migrating. It is likely that if
more survey hours had been conducted the average passage rate would
be less than what was reported due to inclusion of data from days not
conducive to raptor migration. These counts are still well below
established hawk watch sites for spring migrant raptors.
In addition to the general summary of raptor migration, a detailed
analysis of flight path direction for all raptors observed during the
raptor migration surveys was conducted to help determine the
significance of migration through the area. The analysis looked at the
dispersion of flight paths of raptors recorded during the two years of
raptor migration surveys. The results of the analysis indicated that
there was a substantial number of local raptors recorded during the
survey which indicates that the passage rate reported is inflated for
migrant raptors. The analysis showed a general trend in northward and
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southward movement during the appropriate season, however, the

dispersion of movement directions was not significantly different than
random. The analysis indicated abundant scatter in movement
direction suggesting movement of local raptors was considerable. Had
there been a substantial migration through the area the northerly or
southerly directions would have been significantly greater. The
reported passage rate (number per observer hour) includes the local
raptors recorded during the surveys so over represents raptor
migration.
DEIS Response 6.7 A post construction mortality study plan has been developed is
provided as part of the draft WPP in Appendix C-13 of the FEIS.
DEIS Response 6.8 Additional surveys were conducted in Spring 2009 in the southern
portion of the Project area. The results of these studies are set forth in
DEIS Response 6.9 Under the current Project design, no turbines will be located in
forested areas and no fragmentation of forests in the Project area will
occur. Other BBS survey locations that were conducted were near and
within forest patches in the Project area. It is unlikely that the forests
in the northeast would have any additional species or greater
concentrations of any species based on avian use estimates. In
addition, most concern for the regional avifauna has been around
grassland nesting species due to the unique grassland habitats that
occur in the region. Most of the historic forest cover has been
removed from the region and most remnant patches are not
characterized by unique features or old growth characteristics which
could support unique species. The Project area is primarily agriculture
based with pasture/hay fields, cropland, and grassland being the
dominant vegetation types. A post construction breeding bird study
has been proposed (Please see Appendix C-13 of the FEIS) for the
project.
DEIS Response 6.10 Surveys were conducted within the window recommended by the
USGS for BBS. By conducting surveys late in the window it is
possible that abundance estimates of breeding birds are actually
inflated due to recently fledged hatch year birds being counted and
included in the data set. Because some species may be missed if they
are only visible or vocal early in the spring, SLW performed another
BBS in spring 2009. The results of that study are located in Appendix
C-2 of the FEIS.
DEIS Response 6.11 Please see response to comment 2-21.
DEIS Response 6.12 The information requested was provided directly to Brianna Gary at
NYSDEC.
DEIS Response 6.13 Please see response to Comments 2.7 and 2.8.
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DEIS Response 6.14 A scope of work has been submitted to NYSDEC for review. Meeting
was held with NYSDEC and USFWS to discuss the scopes and
process.
DEIS Response 6.15 Report has been completed and has been submitted to NYSDEC for
review. A post construction monitoring plan has being developed and
a draft plan has been submitted to the agencies for review and
comment. A draft revised Plan is available to review in the SDEIS in
Appendix E.
DEIS Response 10.1 The study report was also included in the SDEIS, which was subject to
an additional extended comment period.
DEIS Response 10.2 Project turbines consist of the following measurements: Tower: 80
meters (262 feet) Turbine blades: 82 meters maximum (269 feet).
Therefore, the total height of the towers would be (Tower height) + 0.5
(blade length) or a total of 397 feet. The studies that have been
performed go beyond the height of the towers, and are adequate for
analyzing reasonably foreseeable impacts of the Project.
DEIS Response 10.3 Data were represented in an accurate and understandable manner. The
scope of the first year's work provided to NYSDEC was accepted and
the report format was consistent with standard methods. Nocturnal
radar surveys were performed in the fall during a 63-day period from
August 15 to October 15 (taking into consideration the main bat
migration period) and during a 50-day period in the spring from April
19 to June 8.
DEIS Response 10.4 This comment misunderstands the methods, constraints, and
limitations of marine radar surveys and the characteristics of nocturnal
avian migration. The study design for the baseline studies was
discussed with the NYSDEC prior to study initiation. The exact
location of the sampling station cannot be randomly located because
the visibility of targets can be obscured by ground clutter. The final
radar station location was determined based on the constraints of radar
surveys to provide good radar visibility. The locations complied with
the recommendations of the NYSDEC. The radar station location used
in the fall was located approximately 0.4km from the shoreline at the
nearest location; the radar station location used in the spring was
located approximately 1.6km from the shoreline at the nearest
location.
The comment also erroneously assumes that migration density over
water is lower, when, in fact, water courses such as rivers and riparian
corridors are known to concentrate avian migrants and likely have
higher density than many overland areas. The St. Lawrence River
north of the Project runs in a southwest to northeast orientation which
is nearly perpendicular (not parallel) to the primary orientation of
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avian migration in the spring and fall. As shown in the results of the
study the primary orientation of the fall migration during the study
period was south-southwest and the spring migration was northeast or
roughly parallel to the St. Lawrence River indicating that migration
density over the river was likely higher than over the land thus biasing
the results higher for the study area. In reality, the results of the study
likely overestimate migration over the site. The reason for sampling
passage rate in vertical mode, as indicated in the report, is to get a
more accurate estimate of total migration over a site because vertical
mode samples a higher airspace than horizontal mode and thus is a
better representation of the overall migration passage rate over a site.
DEIS Response 10.5 The comment assumes that nocturnal migrants vary their flight
patterns based on the surface topography and features. Studies have
shown that the majority of nocturnal migrant movement patterns
appear to be independent of surface features (e.g., Mabee et al 2006).
Most nocturnal migrants fly at altitudes that are well above the height
of variation in surface elevation and most migrants are likely utilizing
weather patterns and winds aloft to facilitate long distance movements.
Assuming, however, that the comment is correct and more songbirds
are migrating inland along the St. Lawrence River, then the studies
should have recorded higher than average numbers of nocturnal
migrants based on the location of the radar sampling. This was not the
case and the mean passage rate was lower than the overall mean for
New York.
DEIS Response 10.6 Please see page 9 (in Appendix E of the SDEIS) of the report for
direction data of targets. Due to constraints and limitations of marine
radar, collecting direction data by altitude is not possible. But as noted
on page 9, there was some channeling of migration noted in the
survey.
DEIS Response 10.7 The comment reveals a lack of understanding of the broad scientific
knowledge base regarding nocturnal migration. Countless studies
using marine radar, NEXRAD, acoustics, infrared imagery, and visual
techniques have found that nocturnal migration in every location
studied, occurs in broad front migration patterns. It is likely that any
location surveyed within the SLW Project area would have substantial
numbers of migrants passing overhead, as determined by the marine
radar survey conducted for the project.
Also, based on numerous studies, nocturnal migration patterns are
variable in space and time within and across seasons and years, and are
likely more closely tied to weather events than to surface topography
or conditions. It is unlikely that other study techniques would suggest
different results and would likely underestimate the magnitude of
migration over the site. For example, acoustic methods only count
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birds that call during migration and only within a few hundred meters
above ground level, so underestimate the relative abundance of avian
migrants passing over a site. An acoustic survey would have results
biased toward the low end of the migration spectrum.
Studies also have shown that the vast majority of migrants fly at
altitudes that minimize risk of collision with ground based structures.
The NYSDEC has compiled summaries of the migration studies
conducted for proposed wind projects in New York. The mean flight
altitude for migrants as determined by marine radar is well over 400
meters above ground level. And finally, results of monitoring studies
at wind projects have corroborated the low impact estimate based on
the pre-construction surveys (see response to Comment 13-3 above).
Overall, the results of numerous studies that suggest nocturnal
migration occurs everywhere, is variable in space and time, and that
the vast majority of migrants are not at risk, do not suggest that micro-
siting turbines within the site would minimize risk to nocturnal
migrants.
An analysis of flight path direction for all raptors observed during the
raptor migration surveys was conducted. The analysis showed a
general trend in northward and southward movement during the
appropriate season; however, the dispersion of movement directions
was not significantly different than random. The analysis indicated
abundant scatter in movement direction suggesting movement of local
raptors was considerable. Had there been a substantial migration
through the area the northerly or southerly directions would have been
significantly greater.
DEIS Response 10.8 The observed flight direction for nocturnal migrants as based on the
radar data was generally in a southwesterly direction during the fall
and northeasterly direction in the spring, which is roughly parallel to
the St. Lawrence River. There was no indication that abundance of
nocturnal migrants changed in relation to the river and the data
suggests that the river may have been a factor influencing migration
orientation. Also, the relationship of weather variables to migration
was inconclusive likely due to the fact that weather variables recorded
at ground level were dissimilar to variables at 400-500 m above
ground level where the vast majority of nocturnal migrants were
recorded.
DEIS Response 10.9 The studies performed by SLW were scoped using the NYSDEC’s
Wind Turbine Guidelines. The scope of work was discussed with
NYSDEC and is representative of how studies in NY have been
performed.
DEIS Response 11.1 Comments noted.
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DEIS Response 11.2 SLW is equally concerned about the impacts of wind energy projects
on bats. Please see the details on how SLW has committed to
protecting bats in the draft WPP in Appendix C-13 of the FEIS.
DEIS Response 11.4 Blanding's Turtle is not endangered in NYS of in the U.S.; however, it
is a threatened species. SLW will protect the Blanding's turtle, and
other sensitive species, in a manner that will ensure population
viability. Please see the draft WPP in Appendix C-13 of the FEIS for
specifics on how SLW will avoid, minimize, and mitigate impacts on
these important resources.
DEIS Response 11.5 Please see responses to Comment 1.3 and 1.4.
DEIS Response 11.6 For birds and bats, the color of the wind turbines is generally not an
affective form of deterrent for collisions. While all bats can see, they
rely on echolocation to navigate and color does not play a large role.
The factors most likely to determine the risk of collision for birds are
weather, tower height, tower support mechanisms, tower lighting, and
location in landscape.
DEIS Response 12.2 Please see response to Comments 1.1, 2.35, 4.17, and 4.22.
DEIS Response 12.3 The draft Bird and Bat Monitoring Program was included in the
SDEIS in Appendix E. An updated monitoring plan is described in the
Wildlife Protection Plan, located in Appendix C-13 of the FEIS.
DEIS Response 14.1 Yes. A total of only approximately 0.72 acres of forested land will be
removed for the construction of the turbines, access roads, and
substation. Forest clearing for the overhead transmission line will be
limited to a 100-foot right-of-way and will involve hand-clearing.
Forested areas on either side the right-of-way will remain intact.
DEIS Response 14.11 In addition to acoustical monitoring, the presence/absence of Indiana
bats in the Project area was determined by mist-netting conducted by a
biologist recognized by the USFWS as qualified to conduct surveys for
the species.
DEIS Response 14.14 SLW has not received any comment from the Audubon Society on any
bird habitat associated with Pleasant Valley Road. Based on a review
of Important Bird Areas in Jefferson County, this area is not
designated as an Important Bird Area. Wilson Bay and Marsh, which
is located to the west of Pleasant Valley Road is designated by the
NYSDEC as Coastal Zone Significant Fish and Wildlife Habitat.
Based on impairment assessments of Coastal Zone Significant Fish
and Wildlife Habitats (See Section 3.3.8 and Table 3.18 of the
SDEIS), the Project will not destroy or impair habitat viability of
Wilson Bay and Marsh.
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DEIS Response 19.5 The number of years of pre-construction studies for wildlife is
consistent with other wind development projects and has been
adequate to assess impacts. However, SLW is committed to ensuring
that the Project will not have significant impacts on wildlife, and will
undertake post-construction monitoring studies to assess mortality. If
mortality is greater than expected, and is significant, the Project will
undertake measures to mitigate those impacts.
DEIS Response 21.1 A three-year study plan was not required to adequately assess impacts
to birds and bats. SLW has been in coordination with NYSDEC and
USFWS to address inadequacies they felt required more information.
SLW has conducted a multitude of bird and bat studies, as can be
accessed on the website or in the SDEIS and this FEIS. In addition,
SLW has committed to a Wildlife Protection Plan, which can be
reviewed in draft form in Appendix C-13.
DEIS Response 21.14 Thank you for the information on the USFWS Service Interim
Guidance on Avoiding and Minimizing Wildlife Impacts from Wind
Turbines. Guidance provided in the document was among the many
criteria used to design the Project layout.
DEIS Response 34.1 There are approximately 6 species of heron that potentially occur in
the Project area. The commenter has not identified a particular species
of heron, so this response addresses herons in general. Herons require
open water to feed and most herons are migratory in parts of their
range where food is not available in the winter. Herons in the Project
area are migratory arriving in spring generally sometime in April and
departing in fall generally between mid-September to late October.
Herons typically fly short distances at altitudes between 30 and 60
meters above the ground. During Spring and Fall migration they often
fly at altitudes between 300 and 500 meters. Please see also response
to Comment 1.2.
DEIS Response 63.1 Screening would not be a practical method for protecting birds and
bats because of the size of the turbines and the potential turbulence
generated.
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DEIS Response 65.1 Please refer to the additional studies in Appendix E of the SDEIS and
in Section 2.2.2 and Appendix C-2 of the FEIS. Cumulatively, the
studies presented in the EIS fully and adequately evaluate impacts on
these species.
DEIS Response 68.1 SLW has conducted additional studies since publication of the DEIS
based on standardized guidelines provided by the USFWS and the
NYSDEC to assess impacts to birds and bats. These studies are
presented in Appendix E of the SDEIS, and in Appendix C-2 of the
FEIS. Please see also response to Comments 1.1, 2.35, 4.17, and 4.22.
DEIS Response 79.8 Potential impacts to birds and bats were further analyzed in Sections
3.3.3 through 3.3.7 of the SDEIS and Sections
DEIS Response 110.2 While there is a paucity of studies addressing shadow flicker affects on
fish, adverse effects resulting from shadow flicker are not anticipated.
Results of the shadow flicker study for the site indicate that shadow
flicker would not extend into the Saint Lawrence River or Lake
Ontario. Most of the Project area would experience less than 30 hours
of shadow flicker a year (less than 0.4 percent of the total year). In
addition, most of the tributaries within the Project area do not contain
fish. For those few that do, shadow flicker effects would be further
reduced by vegetation that borders the narrow stream channels
throughout the Project area.
SDEIS Response 1.1 Comment noted. SLW has been coordinating with USFWS and
USACE regarding ESA applicability of the Indiana bat. To date, a
Biological Assessment has been developed (see Appendix C-3) under
Section 7 of the ESA. Future consultation will result in a Biological
Opinion by the USFWS.
SDEIS Response 1.2 An additional BBS was conducted in the Project area in
spring/summer 2009 to more fully assess the potential impacts to
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breeding bird, namely threatened and endangered species (see

Appendix C-2). Prior to construction, SLW will continue to work with
the USFWS and NYSDEC to avoid, minimize and ultimately mitigate
impacts (see Agency Correspondence in Appendix A-1) SLW is also
committed to a comprehensive Post-Construction Monitoring Plan,
which is detailed in the project’s Wildlife Protection Plan (WPP - see
draft WPP in Appendix C-13).
SDEIS Response 1.9 Based on the best available information, little brown bat is one of the
species most likely affected by WNS. Little brown bat is not,
however, one of the most commonly impacted species at wind
turbines. At wind projects in the eastern U.S. that have been
monitored, approximately 9.1 percent of the observed fatalities have
been little brown bats. At Maple Ridge, over the three years of study
44 of 720 bat fatalities (~6.1 percent) recorded were little brown bats.
The vast majority of bats impacted by wind turbines have been what
are referred to as “tree” bats or species of the Lasiurus genus. Three
species of bats, eastern red bat, hoary bat, and silver-haired bat, have
comprised more than 72 percent of all the bat fatalities found at wind
projects in the eastern U.S. that have been monitored. These species
are long-distant migrant species that occupy forested or wooded areas
and typically roost in trees. Based on the best available information to
date, WNS has not been recorded in these bat species.
Since the onset of WNS there is concern over regional declines in the
population of Little Brown Bats. Over time, WNS is likely to reduce
the abundance of little brown bat in the Project area and could be a
significant impact to the species. While mortality from wind turbines
would be in addition to WNS, available data suggests that Little
Brown Bat mortality resulting from wind energy projects is likely to
be less significant than the mortality resulting from WNS. SLW has
developed a post-construction monitoring program (see Appendix A of
the WPP; WPP is Appendix C-13 of the FEIS. with the NYSDEC and
USFWS which will provide information on the impacts of the Project
on little brown bat and information helpful in evaluating the potential
significance of the impacts.
SDEIS Response 1.10 Please see draft Wildlife Protection Plan (WPP) in Appendix C-13 of
the FEIS.
SDEIS Response 1.11 One of the primary objectives of the baseline studies was to determine
if additional studies may be warranted based on results from the first
year. The overall results of the studies from the site did not suggest
that impacts from a wind project at the location would be any different
than other wind projects in New York (e.g. Maple Ridge); however,
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there were a few areas where additional information would help

confirm this conclusion.
The additional studies that were suggested by NYSDEC based on the
study results were a second year of raptor migration surveys, winter
surveys, and additional surveys for bats on the site, which were
undertaken.
Also, during early Project scoping and consultation with the
NYSDEC, the potential for the Project to be within a spring migratory
pathway for raptors was a concern. Spring migrant raptors moving
through New York follow the southern and eastern shores of the great
lakes as they move around these large water bodies.
Contrary to what the comment indicates, two years of surveys for
spring migrant raptors were conducted and adequate data were
collected to assess the risk to migrants. The results of the two years,
conducted according to methods of the NYSDEC, indicate that the
Project area does not receive a concentration of migrant raptors
moving through it. Based on the topography of the area with no ridges
to concentrate updrafts and the shape of the lake in the region of the
project, it is likely that raptors follow more dispersed routes as they
move north through this region of New York instead of traveling west
to stay along the actual lake shore. In addition to the diurnal surveys,
two seasons of nocturnal radar studies were also conducted. Results of
these surveys are consistent with all other radar studies in New York
and indicate low risk to nocturnal migrants, the vast majority of which
fly well above the heights of modern turbines.
SDEIS Response 1.12 SLW has reviewed the new regulations promulgated by the USFWS
regarding bald and golden eagles. While bald eagles may occur in the
SLW Project area, their relative abundance is much lower than some
other species of raptors and based on the best available information,
impacts to the species from the Project are not expected. To date,
there are no known reports of bald eagle fatalities for wind projects
throughout the U.S., suggesting that the species is at lower risk than
some other species of raptors. In addition, no bald or golden eagle
nests were observed, or are known to be located in, the St. Lawrence
Windpower Project area. SLW does not expect fatalities of bald or
golden eagle to occur.
SDEIS Response 1.14 Wildlife studies at the Project site have been ongoing since 2005.
Since the SDEIS submittal, additional studies on breeding birds were
performed in spring/summer 2009 to further identify state-listed
threatened and endangered bird species that may utilize the area during
breeding. The results of this breeding bird study show that sensitive
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grassland species utilize mostly the southern part of the Project and
have been found in few numbers.
Also since the SDEIS, SLW has obtained multiple years of short-eared
owl data from Region 6 NYSDEC and, in cooperation with NYSDEC
has rearranged various roads and turbine locations in order to avoid, to
the extent feasible; the owl's main documented roosting habitats.
Bat studies performed at the SLW site showed typical usage of the
area, in relation to other sites that have been studied, and are adequate
in showing risk to these species. However, the studies also indicated
the presence of the Indiana bat, a federally-listed species. Multiple
years of data have been collected to pin-point the location and
population size of the maternal colony of summer resident Indiana bat
near the project. The detailed Biological Assessment (BA) of the
Indiana bat is located in Appendix C-3 of the FEIS.
SLW will continue to cooperate with the NYSDEC and USFWS to
prepare a Wildlife Protection Plan (WPP) in order to document the
project's commitment to avoiding, minimizing, and ultimately
mitigating - during construction and operation - impacts to wildlife
species. SLW has committed to a thorough post-construction
monitoring plan; see draft WPP in section C-13 of this FEIS.
SDEIS Response 1.15 This recommendation is based on a single year of study. To SLW's
knowledge, the position taken in the comment does not represent
officially adopted policy of USFWS or other species agencies with
jurisdiction over the project. A second year of study at the Casselman
Wind Project is in process. The second year of study should help to
demonstrate whether the first year data regarding changing cut-in
speed to reduce bat fatalities are reproducible. It is the intent of the
Project to develop a WPP for operations, but not on the basis of one
year of study, and not without determining the lowest cut-in speed that
would still produce reasonable results. The draft WPP (see Appendix
C-13) has components that will give SLW and the agencies the
flexibility necessary to determine which operational adaptations will
best benefit the Project and species of concern.
SDEIS Response 2.7 SLW received the Cape Vincent maps from NYSDEC after submitting
the SDEIS. Items 1-3 referred to in NYSDEC Comments are included
in Section 2.2 of the FEIS. SLW has committed to a post-construction
bird monitoring and reporting plan, in collaboration with NYSDEC.
Post-construction monitoring will be addressed in the project's WPP.
A draft WPP is included in Appendix C-13.
SDEIS Response 2.8 SLW will correct the report to reflect NYSDEC comment.
SDEIS Response 2.9 Because the Project is located within a few miles of Lake Ontario, the
additional surveying for raptors was discussed with NYSDEC during a
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meeting on 7-16-07 after the first year or surveying was completed.

During that meeting, a brief overview was given of the results of the
first year of study. The meeting minutes for that meeting state, "Mark
Woythal indicated that more observation days for raptors would be
helpful to more fully characterize migrant passage rates and spatial
use, particularly since weather conditions play a large role in the
movement of a large number of migrants over a relatively short period
of time. Raptor surveys need to be extended at least through November
in order to fully capture golden eagle migration."
In response to this meeting, a second year winter raptor study was
performed with the objective of estimating the spatial and temporal
use of the sites by late fall migrant and wintering raptors with a focus
on golden eagles and short-eared owls. The overall survey methods
were the same as those for the original pre-project studies approved by
NYSDEC except that three additional survey plots were added to the
survey. Surveys were be conducted by counting all raptors seen at six
point count stations for 30-minute periods per point. Other large birds
such as waterfowl and waterbirds were also recorded during the
surveys. The original three survey points used in the pre-project
studies were used, and an additional three points were established in
between the original points for greater coverage of the study area. All
survey points were visited each survey day. A total of 16 survey days
were conducted over the period from approximately October 15, 2007
to March 31, 2008.
In addition to the standard point-count surveys, all raptors and other
large birds seen while traveling between the points were recorded.
Surveys were conducted during daylight hours and the survey route
varied each week so that point counts were conducted at each station at
different times of the day. Due to the shortened day length during the
winter, all times of day were utilized to insure that all points are
covered each survey day. These two years of study, helped to develop
a thorough analysis of potential risk to raptors. An analysis of flight
path direction for all raptors observed during the raptor migration
surveys was conducted. The analysis showed a general trend in
northward and southward movement during the appropriate season;
however, the dispersion of movement directions was not significantly
different than random. The analysis indicated abundant scatter in
movement direction suggesting movement of local raptors was
considerable. Had there been a substantial migration through the area
the northerly or southerly directions would have been significantly
greater.
SDEIS Response 2.10 Table 3-11 does indicate that the number of birds observed per hour
for the Cape Vincent area is higher than other sites, most likely
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because birds tend to avoid flying over water and thus are concentrated
along the shorelines of Lake Ontario and the St. Lawrence River. In
general, there is not good correlation between pre-construction raptor
use, based on survey data, and post-construction mortality, which may
partly be due to the lack of post-construction mortality studies but also
because raptors will avoid turbines they can see. The revised raptor
analysis is set forth in section 2.3 of the FEIS.
SDEIS Response 2.11 A breakdown of total land area proposed to be utilized by the Project
is illustrated in Table 2-1 in Section 2.2.2.2 of the FEIS. Included in
this section are details on the types of habitats that would be affected
by the proposed Project (see Table 2-1). Rates at which complete
restoration would take place are described in Section 2.2.2.3.
Project construction generally lasts between 6-9 months. It is
anticipated that hand-clearing of trees in environmentally-sensitive
areas near the substation and along the transmission line will occur in
winter 2010, when impacts to roosting bats will not occur. General
Project construction would begin in April 2011 and conclude in
fall/winter. Any temporary impacts to the Project site will be restored
upon completion of construction, and should take approximately one
month to completely perform. Mowing will not need to occur near
access roads, underground cables, or around turbines. If NYSDEC
requests that mowing occur near post-construction monitoring around
turbines, this could be discussed with landowners. A more thorough
discussion on these items is addressed in Section 2.2.2.3 of the FEIS.
SDEIS Response 2.12 Table 1-1 has been amended. It is included as Table 1-1 of the FEIS.
SDEIS Response 2.13 SLW has reviewed the Article 11 permit requirements and has
discussed possible ways to avoid impacts to state threatened and
endangered species. SLW met with NYSDEC and USFWS on August
24, 2009 to discuss specific areas of concern over the SDEIS-proposed
layout. In response to those concerns, SLW has adjusted roads in
sensitive areas to avoid impacts to the Blanding's turtle and short-eared
owl. SLW also proposes to move 5 turbines that were located in or
around a documented short-eared owl roosting habitat. SLW will
work with the agencies to avoid, to the extent practicable, impacts to
threatened and endangered species. In the event that all impacts
cannot be avoided, SLW will develop the necessary information in
order to obtain an incidental take permit from NYSDEC. In the draft
WPP (Appendix C-13 of the FEIS), SLW has committed to other
avoidance and minimization efforts, and will continue to work with the
NYSDEC to ensure that impacts to wildlife species result in a "net
conservation benefit" cumulatively.
SDEIS Response 2.14 SLW performed a targeted BBS in summer 2009 in response to
NYSDEC comment. The protocol utilized did not adhere specifically
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to the Guidelines for Conducting Bird and Bat Studies at Commercial

Wind Energy Facilities; NYSDEC Region 6 requested that their
Regional Protocol be used. SLW consultant, WEST, consulted with
Region 6 in order to capture all suggested study purposes. A copy of
the resulting BBS, with the amended scope, is available in Appendix
C-2 of this FEIS. In addition, as described in the Post-Construction
Monitoring Plan in the WPP (Appendix C-13), SLW will conduct
additional pre-construction surveys in the spring preceding
construction to provide baseline information specific to the proposed
post-construction methods. These surveys will be repeated the first
two years of operation, and at least one additional year (either third,
fourth or fifth year).
SDEIS Response 2.15 The Project may result in potential short-term and long-term impacts
due to fragmentation of the landscape. SLW has routed access roads,
where practicable, along hedgerows and field boundaries to minimize
the effects on grassland birds. SLW has minimized roads, to the
greatest extent feasible, in order to lessen these impacts. During
construction, underground cables will be installed using a PLC
trencher, a piece of machinery which digs a trench, lays the cable, and
buries it in during one pass, In addition, SLW will hire a biologist that
is an expert in breeding birds, to monitor the trenching and road
installation efforts in order to avoid impacting nesting bird species.
Because displacement of bird species due to wind facilities is
relatively unknown, SLW has committed to performing a 3-year
Grassland Bird Species Displacement study after construction. This,
and more, information on avoidance, minimization, and mitigation of
effects can be found in the WPP in Appendix C-13 of this FEIS.
SDEIS Response 2.16 At the time the studies started, the B&B Guidelines were not available.
SLW consulted with NYSDEC Central Office regarding scope and
length of study. After the first year or study, the report was reviewed
by Central Office staff and another meeting was held to determine
additional study required. At that time, additional winter raptor study
was suggested, to capture potential golden eagle and other winter
raptor information, including short-eared owl. SLW performed the
additional winter raptor study. SLW has been in communication with
NYSDEC Central Office and has accepted comments on the potential
for studies pre-construction and post-construction. SLW will continue
to be open to reasonable requests for additional studies to further
assess impacts in the future.
SDEIS Response 2.17 Although SLW agrees that wildlife impacts at the Cape Vincent and
all wind projects are site-specific, the Project's consultants have
utilized the best data that are currently available as a basis for
assessing impacts, and have applied their expert professional judgment
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to that data. Currently, there are no known wind projects or studies of

wind projects in native grassland habitats in the northeastern or eastern
U.S. (ecologically similar area). In light of this, the best available
information is that from other regional wind projects. As more wind
power facilities are permitted and undergo post-construction studies,
this information will grow into a better picture of the potential impacts
that wind facilities have on wildlife species. Until that time, however,
SLW believes it has developed the best possible impact assessment,
one which fully satisfies the requirements of SEQRA.
SDEIS Response 2.18 Please see draft WPP in Appendix C-13 of the FEIS.
SDEIS Response 2.19 In response to NYSDEC's concern, SLW has undertaken an additional
spring/summer BBS study in 2009 to help address the impacts to
threatened and endangered species and their locations within the
Project area, and SLW developed a series of maps which overlay the
Project components with sensitive species found during various studies
with a focus on seasonal use (DEC winter data on the short-eared owl,
northern harrier, hawks; Riveredge Associates data on nesting and
general habitat of the Blanding's turtle; WEST data on breeding birds;
and Sanders Environmental data on summer habitat of Indiana bats.)
Collectively, the data utilized fully and adequately characterize the
seasonal use of the Project site. On August 24, 2009, SLW met with
NYSDEC, USFWS, and USACE to discuss these potential impacts
and to develop a plan to avoid and minimize as many of these as
possible, and ultimately discuss mitigation options. These maps and a
description of how SLW will avoid and minimize impacts seasonally
are located in an overall draft WPP in Appendix C-13 of this FEIS.
SDEIS Response 2.22 DEC provided Blayne Gunderman with the name of Glenn Johnson,
Blanding's turtle expert in Potsdam, to determine what habitat in the
Project area would be suitable for Blanding's turtle. Mr. Johnson
determined that several areas in and around the Project site would be
suitable either for nesting, or general purposes. In Johnson's report, he
indicates the measures that would avoid or mitigate impacts to the
Blanding's turtle, and in the draft WPP (see Appendix C-13),
developed in cooperation with the NYSDEC, SLW sets out
commitments it has made to avoid and minimize any impacts to this
species during construction of the project. These measures are fully
sufficient to avoid impacts to Blanding's turtles.
SDEIS Response 3.7 The avian and bat monitoring studies conducted for the Project were
developed in consultation with, and the scopes were approved by, the
State and federal wildlife protection agencies. Those studies were
fully adequate to characterize the use by avian species of the areas that
are potentially affected by the project. The comment seeks additional
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characterization with respect to areas that are distant from the project,
and not within the reasonably anticipated areas of impact of the
project. A comprehensive WPP will be implemented during Project
construction and operation. The Plan was developed in consultation
with NYSDEC and USFWS to protect wildlife species in and around
the Project area. Please see Appendix C-13 for a draft WPP.
SDEIS Response 3.8 The statement identifies the potential for causing abandonment,
however, states that based on the information available is not expected
to. The reader appears to have taken these statements out of context
from the SDEIS. The Project is not anticipated to have direct effects to
the maternal colony. In fact, the Project is proposing to obtain a
conservation easement that will protect the maternal colony and its
habitat for the life of the project.
Indirect impacts, such as disturbance and displacement effects, are not
expected to be large enough to cause abandonment of the maternal
colony. Maternal roosting areas are likely to move over time with or
without the proposed Project.
A more thorough assessment of impacts to the Indiana bat is in the
Biological Assessment (BA) that has been developed in conjunction
with the USACE, NYSDEC, and USFWS, The BA is set forth in
SDEIS Response 7.5 Comment noted. Please see draft WPP in Appendix C-13.
SDEIS Response 11.5 Please see responses to Comments 13.1, 13.2, and 13.3.
SDEIS Response 11.6 Please see responses to Comments 47.8.
SDEIS Response 11.8 A Biological Assessment (BA) has been
prepared for the Project in consultation with the USFWS in accordance
with Section 7 of the Endangered Species Act and is included as
Appendix C-3 in the FEIS.
The BA concludes that the SLW Project will result in the loss of some
Indiana bat habitat but this loss (~2.5 acres) is not expected to be great
enough to lead to harassment or harm of Indiana bats to the extent to
meet the definition of “take”. In addition, Project planning measures
will be used to avoid and minimize habitat loss impacts by cutting
trees when Indiana bats would not be present on site. Loss of habitat
impacts from the SLW Project will not lead to take of individual
Indiana bats and this potential impact is not likely to adversely affect
Indiana bats.
Operation of the Project could potentially lead to direct mortality of
Indiana bats if they were to collide with a turbine blade or die from
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barotrauma. Using the best available information under a suite of

assumptions, it is plausible that the Project could lead to the death of
between 0 and 3 Indiana bats per year. If the threshold of zero is
passed, the USFWS may determine that an incidental take permit is
needed for the Project. Regardless, SLW will implement a rigorous
monitoring program to determine mortality and assess causes of
mortality; an Adaptive Management Plan and a number of
conservation measures will ensure a “net-benefit” impact on the
Indiana bat.
The USFWS will review the BA and issue a Biological Opinion
regarding potential impacts and mitigation measures.
SDEIS Response 11.9 An Additional Breeding Bird Survey (BBS) was conducted in the
spring/summer 2009 (see Appendix C-2 of the FEIS). The Applicant
met with the NYSDEC to discuss surveys on August 24, 2009 and has
developed a strategy to avoid and minimize most potential impacts.
Those impacts that are not avoidable will be mitigated; however,
mitigation will take place prior to the commencement of construction,
as part of a permit condition.
To further address impacts to sensitive species, SLW has undertaken
biological assessment of one federally-listed species and has applied
for an Article 11 permit for 4 listed state species. In addition, to
further indicate the Project's commitment to the protection of
threatened and endangered species, SLW has developed a draft
Wildlife Protection Plan (WPP); set forth in Appendix C-13 of the
FEIS.
Section 3 of the FEIS describes the impacts and commitments of SLW
in relation to wildlife species.
SDEIS Response 13.1 While this comment is duly noted, there is a vast misunderstanding of
the methods, constraints, and limitations of marine radar surveys and
nocturnal avian migration in general that appears to be the basis for the
comment. The study design for the baseline studies was discussed with
the NYSDEC prior to the study initiation, including the radar survey
location. Due to constraints of radar surveys the exact location of the
sampling station cannot be randomly located or the visibility will be
obscured by ground clutter. The final radar station location was
determined based on these constraints to provide good radar visibility
and within the recommendations of the NYSDEC. The radar station
location used in the fall was located approximately 0.4km from the
shoreline at the nearest location; the radar station location used in the
spring was located approximately 1.6km from the shoreline at the
nearest location.
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The comment also erroneously assumes that migration density over

water is lower, when in fact water courses such as rivers and riparian
corridors are known to concentrate avian migrants and likely have
higher density than many overland areas. The St. Lawrence River
north of the Project runs in a southwest to northeast orientation which
is nearly perpendicular (not parallel) to the primary orientation of
avian migration in the spring and fall. As shown in the results of the
study the primary orientation of the fall migration during the study
period was south-southwest and the spring migration was northeast or
roughly parallel to the St. Lawrence River indicating that migration
density over the river was likely higher than over the land thus biasing
the results higher for the study area. In reality, the results of the study
likely indicate a worse-case scenario or over estimate migration over
the site. The reason for sampling passage rate in vertical mode, as
indicated in the report, is to get a more accurate estimate of total
migration over a site because vertical mode samples a higher airspace
than horizontal mode and thus is a better representation of the overall
migration passage rate over a site.
SDEIS Response 13.2 Please see page 9 (in Appendix E of the SDEIS) of the report for
direction data of targets. Due to constraints and limitations of marine
radar, collecting direction data by altitude is not possible. But as noted
on page 9, there was some channeling of migration noted in the
survey.
SDEIS Response 13.3 Based on the preconstruction radar study results, it is calculated that
greater than 4,290,000 targets passed over the site during the spring
and fall migration seasons when the study was conducted. The targets
represent both migrant birds and migrant bats. Based on results from
the Maple Ridge wind project monitoring studies, the three year
average number of fatalities was 7.4 birds per turbine per year and
11.4 bats per turbine per year. It is reasonable to utilize this Maple
Ridge data because monitoring studies around the country have shown
that bird and bat mortality at wind projects within a region are more
similar than projects across regions. The Maple Ridge project is
located about 40 miles southeast of the SLW Project Site, and shares
several relevant characteristics, including its proximity to the SLW
site, it being situated in an agricultural setting, and the presence of
mixed deciduous trees in NYS Under the assumption that mortality at
SLW would be similar to Maple Ridge, the closest wind project to
SLW, then it could be expected that 400 birds and 600 bat fatalities
would occur per year if 51 turbines are constructed. Under the
assumption that 80 percent of these fatalities are migrants, then less
than 0.02 percent of the total number of migrants passing over the site
would be impacted. This is the type of data on which the collision
impacts are based.
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SDEIS Response 13.4 The comment is noted, but lacks an understanding of the broad
scientific knowledge base regarding nocturnal migration. Countless
studies using marine radar, NEXRAD, acoustics, infrared imagery, and
visual techniques have found nocturnal migration in every location
studied, supporting the theory of broad front migration patterns. It is
likely that any location surveyed within the SLW Project area would
have substantial numbers of migrants passing overhead, as determined
by the marine radar survey conducted for the project. Also, based on
numerous studies, nocturnal migration patterns are variable in space
and time within and across seasons and years, and are likely more
closely tied to weather events than to surface topography or
conditions. It is unlikely that other study techniques would suggest
different results and would likely underestimate the magnitude of
migration over the site. For example, acoustic methods only count
birds that call during migration and only within a few hundred meters
above ground level, so underestimate the relative abundance of avian
migrants passing over a site. An acoustic survey would have results
biased toward the low end of the migration spectrum. Studies also
have shown that the vast majority of migrants fly at altitudes that
minimize risk of collision with ground based structures. The NYSDEC
has compiled summaries of the migration studies conducted for
proposed wind projects in New York. The mean flight altitude for
migrants as determined by marine radar is well over 400 meters above
ground level. And finally, results of monitoring studies at wind
projects have corroborated the low impact estimate based on the pre-
construction surveys (see response to Comment 13.3 above). Overall,
the results of numerous studies that suggest nocturnal migration occurs
everywhere, is variable in space and time, and that the vast majority of
migrants are not at risk, do not suggest that micro-siting turbines
within the site would minimize risk to nocturnal migrants.
SDEIS Response 13.5 While the radar study was designed by the NYSDEC and USFWS
prior to the Guidelines, it was conducted according to the Guidelines
as currently written.
SDEIS Response 13.6 Thank you for the additional information. The breeding bird surveys
for the Project were designed to address the objectives identified in the
report and suggested by the agencies charged with managing public
wildlife resources. As such, species at primary risk where
development was planned were targeted in the studies. Specifically,
the agencies requested that breeding bird surveys occur at proposed
turbine locations, and as such, are more appropriate for estimating
potential impacts from the Project than general regional studies.
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SDEIS Response 14.2 We appreciate the expression of concern, but no reasons are provided
for the basis of the concern. SLW has investigated the presence of the
species included in this comment (see Appendix C-2); the whip-poor-
will and rough-legged hawk have been excluded from potential
adverse impacts to threatened and endangered species based on the
findings of the studies. However, northern harrier, short-eared owl,
and grasshopper sparrow have been included in the Article 11
assessment and permit application to the NYSDEC. That application
and associated data can be found in Appendix F to this FEIS. SLW
has also committed to avoiding, minimizing, and mitigating adverse
impacts to these (and other) species; those commitments are outlined
in the draft WPP found in Appendix C-13. Please also see response to
Comment 11.9.
SDEIS Response 14.3 There is no need for two more years of pre-construction studies in
order to assess the potential impacts of these species SLW has
developed an adequate assessment of impacts, using the various years-
worth of studies and data from other wind farms and assessments.
Please see Comment 14.2.
SDEIS Response 14.4 SLW has undertaken multiple years of scientific study of wildlife
resources at the proposed wind farm site. Using these scientific
studies and referencing other studies and data acquired by other project
sites is a standard way to assess potential impacts of wildlife. The
other studies are the best information available for understanding the
potential impacts to birds at the SLW Project by assessing pre- and
post-construction mortality data. Please see also responses to
Comments 1.14, 1.15, 2.9, 2.14, 2.15, 2.16, 2.19, and 3.7.
SDEIS Response 14.5 A draft Post-Construction Monitoring Plan was provided in the SDEIS
as Appendix E. An updated and amended Plan is provided in the draft
WPP. The draft WPP is set forth in Appendix C-13 of the FEIS.
SDEIS Response 15.1 SLW has recently obtained and utilized NYSDEC's short-eared owl
data in response to various comments such as this one. In short, SLW
rearranged portions of the Project in September 2009, as described by
the letter in Appendix A-1, in order to avoid and minimize impacts to
this species. SLW is applying for an Article 11 incidental "Take"
permit, in order to fully comply with NYS Environmental
Conservation law.
SDEIS Response 17.1 Based on results of numerous post-construction monitoring studies of
wind projects throughout the U.S., waterbirds in general, and herons,
specifically are at low risk from wind turbines. That is, there have
been very few of these species recorded as fatalities at wind turbines.
While the behavior of these species may be of general interest to the
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avian-enthusiast public, because they are not affected by wind

projects, the answers to the questions posed are of no consequence to
impact analysis. The rule of reason for environmental impact
assessment does not require every conceivable impact be addressed
simply because it can be conceived; only impacts reasonably likely to
occur must be addressed [6 NYCRR § 617.9 (b)(2)].
SDEIS Response 17.2 There has been no research to date on impacts of shadow effects from
wind turbines on wildlife. In addition, no research on shadow effects
from any structure or feature (e.g., trees, hills, clouds, buildings, cars,
towers, people, airplanes, etc.) on wildlife are known.
SDEIS Response 17.6 While there are few studies addressing shadow flicker affects on fish,
adverse effects resulting from shadow flicker are not anticipated.
Results of the shadow flicker studies indicate that shadow flicker
would not extend into the Saint Lawrence River or Lake Ontario. Most
of the Project area would experience less than 30 hours of shadow
flicker a year (less than 4 percent of the total year). In addition, most
of the tributaries within the Project area do not contain fish. For those
that do, shadow flicker effects would be further reduced by vegetation
along the narrow stream channels throughout the Project area.
SDEIS Response 17.12 According to published sources, there is no IBA on Pleasant Valley
Road. The only designated IBA's in Jefferson County are: The Fort
Drum Grasslands and Upper St. Lawrence/Thousand Islands IBA;
neither of which is located on or near Pleasant Valley Road.
SDEIS Response 17.15 The habitat located at Chaumont Barrens and Three Mile Creek will
not be impacted by the project.
SDEIS Response 17.17 SLW described the SLWGMD and discussed impacts in Section 3.8,
"Critical Environmental Areas." The St. Lawrence Windpower Project
will not interfere with efforts to establish the SLWGMD. SLW
encourages preservation of grassland ecosystems, and construction of
the Project will avoid or minimize further development and conversion
of grassland within the Project Area and areas adjacent to these
significant areas. The Project would permanently develop
approximately 30 acres of pastures/hay fields; however, where forbs
equal or outnumber grasses, this habitat is far less attractive to
grassland birds. Wind projects protect land from other types of
development, which typically result in massive loss of habitat. Wind
projects result in relatively low losses of habitat and result in long term
preservation of grassland habitat. Under the proper management
scenario for lands around turbines, improved habitat conditions may
actually benefit waterfowl and grassland birds by increasing nesting
opportunities and reproductive success.
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SDEIS Response 17.18 Information supplied by Smith (2007) was included in the more recent
data received by NYSDEC on the short-eared owl. This data helped
SLW in preparing a revised layout to avoid CV-4 short-eared owl
roosting area (see Appendix A-1 – NYSDEC Correspondence).
SDEIS Response 17.19 By utilizing actual project pre-construction wildlife data, and
comparing it to national and regional data on actual mortality from
wind farms, SLW conducted a best available assessment of wildlife
mortality for the project.
SDEIS Response 17.20 The Lead Agency has found the SDEIS to be complete, and accepted it
as such on March 25, 2009. Comment noted.
SDEIS Response 25.18 SLW performed multi-year avian and bat studies. In the SDEIS, there
were 2 years of winter raptor study and multiple years of Indiana bat
study. In the FEIS, you will also find another breeding bird study,
which focuses on threatened and endangered species.
SDEIS Response 25.19 The NYSDEC guidelines require radar study. SLW sought to follow
the guidelines that the experts at the State have set out.
SDEIS Response 25.20 Studies are chronological. Indiana bats are present near the Project
Area. A Biological Assessment (BA) has been prepared for the Project
in consultation with the USFWS in accordance with Section 7 of the
Endangered Species Act and is included as Appendix C-3 in the FEIS.
The BA proposes mitigation measures including: a 56-acre
conservation easement; an aggressive monitoring program, including
adaptive management, if necessary; monetary contributions to the
WNS fund and BWEC; and research to assist the NYSDEC in their
efforts in genetic data collection. The USFWS will review the BA and
issue a Biological Opinion regarding potential impacts and mitigation
measures.
SDEIS Response 25.21 Comment noted. Blanding Turtle report can be found in Appendix E
of the SDEIS.
SDEIS Response 25.22 A Blanding's Turtle Management Plan is included in the draft Wildlife
Protection Plan (WPP) and is provided as Appendix C-13 to the FEIS.
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SDEIS Response 33.1 The study was not designed to search for individual turtles, but rather
to identify potential habitat. Please see Appendix E of the SDEIS for
further information regarding the study methodology. Additionally, a
Blanding Turtle Management Plan is included in the draft WPP and is
provided as Appendix C-13 to the FEIS.
SDEIS Response 41.3 SLW has undertaken a complete assessment, under the Endangered
Species Act (ESA), of the Indiana bat. SLW started with a literature
and data review of existing scientific documents. In addition, SLW
performed bat acoustic monitoring, mist-netting, roost tree exit counts,
telemetry tracking, and a foraging study. This data was combined to
develop an environmental baseline for a biological assessment (BA) of
the Indiana bat, in regards to the SLW Project. Included in the
baseline were habitat surveys, an assessment of the summer and winter
Action Areas, and the species status in the Jefferson County area. The
BA then goes on to describe the effects of the proposed wind farm:
direct effects, including direct mortality and displacement; and indirect
effects, such as habitat loss, the effects on regional distribution,
cumulative, and other effects. Finally, the BA addresses the Project’s
proposed conservation measures, including easements, project design,
various monetary contributions to the species, and an aggressive
monitoring and/or adaptive management plan. Please see the BA in
Appendix C-3 for a full assessment of the potential impacts to the
Indiana bat.
SDEIS Response 41.4 No, hand-cutting of trees in the winter avoids impacts to Indiana bats.
SLW proposes to avoid those impacts along the transmission line.
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SDEIS Response 47.1 Please see responses to Comments 11.8 and 17.20.
SDEIS Response 47.3 The scope of the Bird Study performed by SLW was discussed with
NYSDEC and USFWS prior to commencement. The bird studies
followed the NYSDEC Guidelines as they were drafted in 2007.
Further, studies after that point were also scoped with the input of the
NYSDEC and USFWS, and the most recent study (threatened and
endangered grassland species) was performed strictly in accordance
with the NYSDEC Region 6 protocol. These studies, when taken
cumulatively and compared to existing population data from other
studies and literature review, are fully adequate to present a realistic
portrayal of bird populations.
The Blanding’s Turtle study was not intended to assess the population
size, but was intended to identify potential habitat for the turtle, which
it did. SLW proposes to avoid all potential habitat that the expert
identified. Cumulatively, these studies represent species identity,
populations, and/or avoidance measures as they relate to the SLW
Project.
SDEIS Response 47.4 SLW’s consultant was retained to identify where potential habitat for
Blanding's Turtle is, in relationship to the Project area. SLW is not
proposing to construct any Project facilities within any of the potential
habitat, as identified by the expert, Mr. Glenn Johnson. As you will
see in the draft WPP (Appendix C-13 of the FEIS), SLW has set out
strategies, as recommended by the consultant, to avoid mortality of
Blanding's turtle.
SDEIS Response 47.5 Please see responses to Comments 1.14, 1.15, 2.16, 2.19, 25.20, and
47.2.
SDEIS Response 47.6 Raptors were one of the primary concerns raised by the NYSDEC
during the early study development process. The potential for raptors
to migrate through the site during the spring was of primary concern
and two years of spring surveys were conducted. In addition, fall
migration surveys and winter surveys were conducted to estimate
raptor relative abundance. The studies exceeded the standards set by
NYSDEC for wind projects and no further studies of raptors are
recommended or required. The studies and results are thoroughly
described in the baseline report and an impacts evaluation made that
compares the site to known hawk migration watch sites and other wind
projects in New York. While raptors are certainly present on the site
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in all seasons, the relative abundance, as well as results of monitoring

studies at wind projects in New York and throughout the U.S., do not
suggest that potential impacts will be significant. In addition, SLW is
preparing a Wildlife Protection Plan that addresses potential impacts to
grassland nesting species including northern harrier. Based on the site
specific data and proposed mitigation measures there will not be
significant impacts to raptors from the SLW Project.
SDEIS Response 47.7 SLW has obtained 3 years of data from NYSDEC Region 6, and has
identified the areas where short-eared owls are known to exist in
relation to the Project area. Please see letter in Appendix A-1 as a
description of how SLW has proposed to avoid and minimize impacts
to the short-eared owl. In addition, this species in included in the draft
WPP that is in Appendix C-13.
SDEIS Response 47.8 On the contrary, the studies on migration were extensive, addressed
both diurnal migrants (raptors) and nocturnal migrants, and were
developed through coordination and cooperation with the NYSDEC
biologists. The primary objectives of the studies were to provide data
useful in assessing impacts. The studies followed methods
recommended by the resources agencies (NYSDEC, USFWS). In
particular, the methods were designed to provide comparable results
across locations within the Project as well as with other sites where
similar studies have been conducted. These methods are not intended
to provide a census of birds within the area, but estimates of relative
abundance which is related to risk to species and potential impacts.
SDEIS Response 47.9 Please see responses to Comments 1.14, 1.15, 2.9, 2.14, 2.15, 2.16,
2.19, 3.7, and 11.9.
SDEIS Response 47.10 An Invasive Species Management Plan was included as Appendix D to
the SDEIS. The Project is not responsible for invasive species outside
of project boundary.
SDEIS Response 57.3 Comment noted. Please see responses Comments 1.14, 1.15, 2.9, 2.14,
2.15, 2.16, 2.19, 3.7 and 11.9.
SDEIS Response 65.1 The SDEIS assessed impacts to threatened and endangered species in
Section 3. Also, please see response to Comment 11.9.
SDEIS Response 65.2 There is a possibility that northern harriers will be impacted by the
Project but the impact is likely to be spread over the full year as this
species was recorded in all seasons in the Project area. Provided the
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impact to this species is equal across all seasons it is expected that

only ¼ of the impact would occur on breeding individuals. For
example, under an assumption that on average one northern harrier is
impacted each year, one breeding individual would be impacted every
four years. This impact is immeasurable on the local, state, or
migratory population of northern harriers. SLW is developing an
Avian and Bat Protection Plan in cooperation with the NYSDEC and
USFWS for the Project that will outline measures to avoid, minimize
and mitigate impacts to all birds, including those with a higher
probability of being impacted than northern harrier.
SDEIS Response 65.3 Impacts from Wolfe Island are publicly unknown and the analysis of
cumulative impacts from Wolfe Island was outside the scope of the
analysis for SLW. Provided impacts from turbines on Wolfe Island
are similar to potential impacts from projects in NY, it is not expected
that impacts from SLW in conjunction with Wolfe Island would be
would be significant.
SDEIS Response 73.9 Please see response to Comment 15.1. See also addendum to Breeding
Bird Survey in Appendix C-2 and responses to Comments 1.14, 1.15,
2.7, 2.9, 2.14, 2.15, 2.16, 2.19, and 3.7.
SDEIS Response 73.33 Please see responses to Comments 13.1, 13.2, and 13.3.
FACILITY LAYOUT AND DESIGN

DEIS Response 2.5 Since the DEIS, the Project size has decreased by over 40 percent and
is near the minimum size to still be a viable project.
DEIS Response 2.6 SLW has utilized internal wind resource assessment in order to place
the turbines in the best possible locations with respect to wind
resource, while still maintaining required setbacks from property lines,
environmentally sensitive areas, and minimum turbulence between
turbines.
DEIS Response 2.10 Where feasible, buried electric cables will be collocated with access
roads.
DEIS Response 2.13 A description of the proposed overhead transmission line and an
impact analysis of the selected route was included in the SDEIS,
Section 7.7.1 - Overhead Transmission Line on Existing Abandoned
Railroad ROW. This placement minimizes, to the maximum extent
feasible, the impacts on habitat loss, and protects existing habitat
value.
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DEIS Response 2.14 Under the proposed layout, no turbines are proposed to be placed in
any wetland areas - or peat muck.
DEIS Response 2.34 Comment noted. SLW has reviewed the Service's Interim Guidelines.
DEIS Response 4.1 Please see Section 2.5.1 of the SDEIS.
DEIS Response 4.2 Please see response to Comment 4.22 on the SDEIS.
DEIS Response 4.4 Please see Section 2.5.2 of the SDEIS.
DEIS Response 4.5 No project facilities are proposed to be located in the River District or
the Lake District in the Town of Cape Vincent. An Architectural study
was performed in accordance with SHPO requirements, as was
included in Appendix H of the SDEIS.
DEIS Response 4.9 Section 2.5.5 of the SDEIS provides a description and location of the
overhead transmission line. Section 7.7 of the SDEIS provides
alternatives including cost and benefits for underground location. The
Chaumont River will be crossed with an overhead line. Crossing the
Chaumont River underground presents greater costs which are
unnecessary given that there are currently overhead transmission lines
crossing the Chaumont River. No transmission poles will be located
within the Chaumont River.
DEIS Response 4.10 The Project proposes to locate the electric transmission line from the
Project using an existing abandoned railroad bed. The proposed
transmission pole structures will be located on this upland fill (railroad
bed ballast) adjacent to and within 10-feet of the existing underground
water main in the railroad bed. Construction access will be
accomplished on the railroad bed without the need to cross or grade
adjacent wetlands. The Chaumont River (which no longer has a
railroad bridge) will have an overhead wire (conductor) crossing. Pole
structures will be located on both sides of the Chaumont River without
the need to construct a temporary bridge. Existing shrubs and trees in
the railroad bed will be cleared and chipped, or hauled from the right-
of-way corridor. Tree clearing adjacent to the railroad bed will be
limited to “danger trees” associated with the electric transmission line
conductors. “Danger trees” adjacent to the railroad bed that pose a
threat to the reliability of the overhead line include trees that could
fall or strike the conductors and take the transmission line out of
service. These trees will be selectively cut by hand (i.e., non-
mechanized clearing) to avoid equipment access and adverse impacts
to adjacent wetlands.
DEIS Response 4.11 Please see response to Comments 4.25 and 4.22 on the SDEIS.
DEIS Response 4.12 The floodplain overlay map was included in figure 3-6 of the SDEIS.
The Project has been designed to avoid construction in the 100-year
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floodplain, therefore no local, county or federal floodplain regulation

or programs will be applicable.
DEIS Response 4.35 Please see Appendix H. of the SDEIS.
DEIS Response 4.45 Please see Section 7 of the DEIS, Alternatives Analysis. Project size
has been reduced from 96 turbines to 51 turbines. No project facilities
are proposed in the Lake District or River District in the Town of Cape
Vincent.
DEIS Response 7.1 Comment noted. The Project layout complies with setbacks
established the Town of Cape Vincent Planning Board.
DEIS Response 7.2 The transmission line will parallel the existing Development Authority
of the North Country (DANC) waterline within the old railroad bed.
To address potential impacts to the adjacent DANC waterline
associated with construction of the electrical overhead line, SLW has
contracted an engineering firm to conduct an engineering analysis and
to prepare plan and profiles of the transmission line to minimize
interference with the waterline. The analysis will determine the level
of induced voltage and current to establish conformance of the
overhead design with requirements to protect the underground
facilities compliant with NY State regulations. The plan and profile
drawings will indicate ground profile, structure locations, conductor
sag, span lengths, line angles, and ruling span information. Design
criteria will be provided for line loading, conductor selection, structure
types, normal and maximum operating temperatures and allowable
clearance and special design considerations for the waterline. The
engineering report and plan and profile drawings will be reviewed with
DANC.
DEIS Response 7.3 The transmission line will follow the existing DANC water line and
railroad bed bordering the extreme western edge of the AWMA.
Impacts to the AWMA may occur during construction, from the use of
heavy equipment, or during operation by bird collision. To offset
impacts associated with construction of the electrical overhead line
through the AWMA, SLW will purchase property that the regional
NYSDEC has identified as a desirable acquisition having wildlife
value and will deed the property to the NYSDEC. The selected
property will be of greater wildlife-related value than the easement
area. The AWMA easement and the proposed acquisition property
have been assessed according to NYSDEC standards and assessments
were reviewed by the regional and headquarter NYSDEC offices. In
addition, any necessary above ground electric lines will follow the
Avian Power Line Interaction Committee suggested practices for
protecting avian species.
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DEIS Response 7.4 The property that is proposed to be utilized is privately owned. SLW
has obtained easements from landowners to use portions of the
property. In addition, SLW will seek and need approval from the
DANC to co-locate the proposed overhead transmission line with
DANC's underground water line. DANC is the owner and operator of
the water line, and is responsible for providing reliable service to its
municipal customers.
DEIS Response 7.5 Notification of the proposed route was given in the SDEIS document
and newspaper notifications. A public hearing was held on the SDEIS
and residents have had an opportunity to comment on the Overhead
Line Route.
DEIS Response 11.3 Based on avoidance and minimization of impacts to various resources
including wetlands, threatened and endangered species, and visual
resources, the number of turbines has been reduced to 53. Since
Acciona AW-82/1500 1.5 MW turbines will be used the total
maximum capacity of the Project has been reduced to 79.5 MW.
DEIS Response 11.9 An underground alternative for the overhead transmission line was
evaluated in Section 7 of the SDEIS, but was found to be cost-
prohibitive and to result in more significant environmental impacts
than an overhead route.
DEIS Response 14.12 SLW intends to obtain construction materials such as gravel, concrete,
wood, steel rebar, cabling and various other materials from local
sources to the maximum extent practicable.
DEIS Response 14.13 A significant portion of the workers hired for wind projects are often
local and/or in-state residents. Upstate New York has proven to be
capable of supplying skilled labor for the construction of a wind
project. As an example, approximately 200 (67 percent) of the 300
construction workers involved in Phase I of the Maple Ridge project
were from in or around Lewis County, New York and these workers
commuted to project site. Non-local and non-New York workers are
typically housed in regional hotels, inns, and motels.
DEIS Response 14.17 Please see responses to Comment 113.15a and 113.8.
DEIS Response 16.1 Alternative routing was explored prior to the SDEIS, but was not
included in the SDEIS because SLW was not able to obtain
permission, in the form of signed leases, easements, or options for
them, from landowners in that area. In addition, based on preliminary
route planning, routing the overhead transmission line along the old
railroad bed represents the least impact on the environment.
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DEIS Response 21.11 Please see responses to Comments 4.10 and 4.50.
DEIS Response 21.12 Please see Appendix K – Transmission Infrastructure Visibility Study
in the SDEIS.
DEIS Response 30.1 The Project layout complies with setback criteria established the Town
of Cape Vincent Planning Board.
DEIS Response 37.1 New gravel access roads will be created. All of these roads will be
located on leased private lands. SLW will bear the cost of maintaining
these roads, which will be maintained by full-time maintenance
personnel and through contracts with local vendors, to the extent
available.
DEIS Response 38.5 Locations of these facilities were described in detail in the SDEIS,
Sections 2.5 and 2.6.
DEIS Response 40.1 In the DEIS Executive Summary, "other components" refer to crane
pads at the end of each road adjacent to the turbine (in essence a slight
widening of the gravel access road) and a temporary on-site cement
batch plant, which may be required if nearby sources of concrete
cannot accommodate the quantities necessary to construct turbine
foundations. A complete list of Project components is listed in Table
2-2 of the DEIS.
DEIS Response 40.8 Please see responses to Comment 113.15a and 113.8
DEIS Response 41.1 Based on avoidance and minimization of impacts to various resources
including wetlands, threatened and endangered species, and visual
resources, the number of turbines has been reduced to 51. Since
Acciona AW-82/1500 1.5 MW turbines will be used the total
maximum capacity of the Project has been reduced to 77 MW.
DEIS Response 75.2 Section 1.1 is correct. Section 2.63 should have read 29 miles.
However, the number of miles of gravel road associated with the final
51 turbine layout is 14.7 miles.
DEIS Response 79.5 Please see responses to Comments 4.10 and 4.50.
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DEIS Response 79.9 Acciona AW-82/1500 and AW-77/1500 1.5 MW turbines

manufactured by Acciona Windpower, N.A. will be used for the
Project.
DEIS Response 79.10 Section 1.1 is correct. Section 2.63 should have read 29 miles.
However, the number of miles of gravel road associated with the final
51 turbine layout is 14.7 miles.
DEIS Response 93.1 In efforts to minimize impacts to various resources, SLW evaluated a
reduced project size and the final project will contain 51turbines.
Regarding setbacks, the Project layout complies with setback criteria
established by the Town of Cape Vincent Planning Board.
DEIS Response 111.1 The Town has not established any specifically applicable noise
standards or criteria. SLW is using standard noise assessment
measurement methodology to derive safe setback distances to
residents. Please see the most up-to-date noise assessment in
DEIS Response 113.2a The Federal Aviation Administration will determine the minimum
night-time lighting. SLW will adhere to the minimum night-time
lighting requirements of FAA.
DEIS Response 113.15b Please see responses to Comment 113.2.
DEIS Response 113.16a Restoration of the Project areas will be the responsibility of the
Project.
DEIS Response 113.16b The O&M building will be located in the Township of Cape Vincent
on the east side of Swamp Road approximately 800 feet south of
Favret Road. It will be located approximately 1.8 miles east of the
border of the Village of Cape Vincent. It will be located near Turbines
9.
DEIS Response 113.18 Please see response to Comments 113.17a and 113.3.
SDEIS Response 1.4 Even monopole-type structures at the 80m and 100m height require
some guying in order to ensure safety of the tower. Shorter structures
are available without guy sires, but not at the height required by the
Project. SLW will minimize impacts to wildlife by placing bird
deflectors on the guy wires in the fashion shown in Exhibit 2-3 in
Section 2 of the FEIS. Bird deflectors have been successful at
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minimizing bird fatalities, and are a best management practice of the

project’s parent company, Acciona Energy.
SDEIS Response 1.5 Directional drilling under the Chaumont River has been excluded as a
viable possibility due to the exceptionally high costs associated with
the procedure. There are many variables that can impact the subject
costs but as a rule of thumb, the installed cost for 115kV Underground
will be approximately 4-6 times more than 115kV Overhead. A rough
installed cost for 115kV Overhead is $1M to $2M per mile.
Clearing of trees will be kept to the minimum required. No
mechanized clearing will take place in wetland areas - hand clearing
will be utilized instead to avoid and minimize impacts to habitat.
SDEIS Response 2.1 SLW has been in communication with the NYSDEC Real Property
Division (Mike Contino). NYSDEC has identified a desired parcel
and SLW has had it appraised. Proposed legislation is drafted and is in
the review stage. SLW will continue to work through the process with
NYSDEC as the preferred transmission line route. The Alternate route
would result in more environmental impacts, specifically to wetlands.
SDEIS Response 2.4 Overhead collection lines would only be used as a last resort, if
underground placement would result in undue environmental impacts.
Section 2.25 of the FEIS provides further specifications for the
overhead line and preliminary design specifications and drawings are
also provided in Appendix C-7 of the FEIS.
SDEIS Response 4.5 A detailed evaluation and site plan will be conducted prior to
commencement of construction to review the potential for induced
voltages and step and touch voltage levels related to the co-location of
the transmission line with the Regional Water line. We have hired an
engineering company to perform an induced voltage analysis. The
engineer has confirmed that the induced voltage will be in compliance
with the New York State Public Service Commission Rules and
Regulations, Part 127 which states that "...overhead electric
transmission facilities shall limit the step-and-touch voltages induced
by magnetic fields of such facilities under steady state conditions to 15
volts or less at all points on existing pipelines where a person could
normally touch the pipeline or a pipeline appurtenance."
SDEIS Response 4.9 Acciona requires all work is performed to prudently design, engineer,
test, operate and maintain equipment safely, efficiently and
economically in accordance with the requirements of applicable law,
the National Electric Safety Code, the National Electric Code, the
North American Electric Reliability Council’s standards and
procedures and any applicable equipment vendor manuals and
specifications. Contractors will perform work in accordance with (a)
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the generally accepted standard of care, skill and diligence as would be

provided by a prudent engineering firm experienced in supplying
engineering services nationally in the U.S. to power-producing entities
for projects of technology, complexity and size similar to the Project,
(b) Good Utility Practice, and (c) all codes and standards applicable to
such Work A specific list of applicable codes and standards will be
developed during the detailed design phase.
SDEIS Response 4.11 Please see Construction Environmental Monitoring Plan outline in
Appendix C-14. A final plan will be developed prior to
commencement of construction.
SDEIS Response 4.16 Please see section 2.5.6 of the SDEIS. Most of the items listed in this
comment are not typically provided in an EIS. SLW will provide
more detailed construction plans during Site Plan Review. In addition,
SLW will utilize best management practices, which are described in
the Stormwater Pollution Prevention Plan (SWPPP). A draft SWPPP
is included in Appendix C-8 of this FEIS. More detailed plans will be
available pre-construction.
SDEIS Response 4.22 Figure 2-1 of the SDEIS identified the location of the switchyard and
substation. Section 2.6.7 of the SDEIS provides a description of the
substation facilities. Collection substation and transmission owner
substation design drawings and site plans will be provided as required
during the site plan review.
SDEIS Response 4.24 a) The minimum setback used from turbines to occupied structures is
1,500 feet. The minimum setback used from unoccupied structures and
electric transmission lines is 1.1 times the turbine height as measured
from the base of the turbine to the highest possible bade tip point.
b) The setbacks used are based on correspondence from the Town of
Cape Vincent Planning Board, twenty years of experience, industry
best practices, reduction of potential noise impacts and safety.
c) It is not clear what is meant by “local setback restrictions." The
project will comply with all setbacks required by the municipal boards
with jurisdiction over the project.
SDEIS Response 4.25 SLW hired Sargeant & Lundy, and engineering firm, to perform an
initial analysis of the electromagnetic fields (EMF) for the proposed
115kV transmission lines. The analysis, based on EPRI Red Book
methods, shows a maximum electric field of 1.412 kV/m and a
maximum magnetic field of 57.13 mG. Please see Exhibits 4.1.1 and
4.1.2 for diagrams.
SDEIS Response 11.10 The 115 kV transmission line will be above ground consistent with
other sources of power generation within New York State. Section
7.7.4 of the SDEIS provides an alternatives analysis for the proposed
transmission line and justification for the selected above ground
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transmission line. In addition, SLW will adhere to the standards of the

Avian Power Line Action Committee, to avoid and minimize impacts
to birds on those lines.
SDEIS Response 16.1 All 34.5 kV collection lines will be underground to the greatest extent
possible. The 115 kV transmission line is primarily not located in
agricultural fields, where it is located in agricultural fields it is located
on the edge of the field.
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Exhibit 4.1.1 – Maximum Magnetic Field of 5.73 (mG) found at Station 30184 offset – 5.00
feet (Source: Sargeant & Lundy).
EMF Calculation Notes:

1. All calculations based on the EPRI Red Book methods (2nd Edition, 1982 – infinite
straight wire with flat earth approximation).
2. These approximations are only valid for low frequency (50-60Hx) AC transmission
lines.
3. Bundles are modeled with an equivalent conductor as per EPRI Red Book 8.3.1.
4. The effects of earth return currents (earth resistivity) are ignored when calculating the
magnetic field.
5. Wire position is determined by the currently displayed weather case.
6. Wire height used is the height of the wire where the target point is projected upon.
7. All calculations assume ground is flat with same elevation as that of the centerline.
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Exhibit 4.1.2 – Maximum Magnetic Field of 1.142 (kV/m) found at Station 30184 offset –
5.00 feet (Source: Sargeant & Lundy).

lines.
magnetic field.
SDEIS Response 16.5 Section 2.2.5 of the FEIS includes the full description of the proposed
transmission line route. However, "as-built" drawings can only be
provided after the Project is constructed.
SDEIS Response 18.1 The St Lawrence Wind Power project exceeds all the requirements for
setbacks established by the Town of Cape Vincent Planning Board.
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SDEIS Response 25.62 Please see Exhibit 2-1 for illustration of what Acciona's typical
Substation/O&M building look like. SLW will be similar in features
to one of this example.
SDEIS Response 25.66 The NYISO oversees the transmission system. It has rules in place to
address the concerns expressed in this comment. SLW has complied
with the NYISO’s rules, and the NYISO has approved the System
Reliability Impact Study for the Project.
SDEIS Response 25.70 Please see Appendix A to the FEIS for the letter to the Town of Cape
Vincent Planning Board, signed by both SLW and BP.
the EIS.
SDEIS Response 54.5 St Lawrence Windpower is working with the Development Authority
of the North Country to address any potential concerns in the proposed
transmission line being located adjacent to the existing water line
through an engineering study. The Development Authority of the
North Country has reviewed the scope of the engineering study to
ensure all concerns are addressed (See Correspondence – Appendix
A). Furthermore the Development Authority of the North Country and
St Lawrence Windpower will continue to meet to discuss the progress
and results of the engineering study. Any issues relating to co-location
will be addressed between DANC and SLW, and will be considered
during the site plan review process.
SDEIS Response 73.3 Population densities (persons per square miles – p/sm) associated with
operational wind energy facilities in New York range from 25 to 2,958
p/sm with an average of 393 p/sm (see attached Table. Population
density for the Town of Cape Vincent is approximately 60 p/sm, well
below the average.
The Project would be located approximately a third of a mile from the
Village of Cape Vincent, which has a population density of
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approximately 1,414 p/sm. While higher, the average the population

density for the Village of Cape Vincent is within the range of
operational population densities.
In addition, the Village of Cape Vincent is well beyond all required
setbacks for the Project, which further ensures the safety of Village
residents. The Village is also beyond the 42 dBA predicted sound
contour for the Project. Please see Exhibit 4.4.3.
SDEIS Response 73.17 Additional visual mitigation proposed is vegetative screening,
repainting buildings at the Tibbett’s Point Lighthouse, burying electric
at the Tibbett’s Point Lighthouse, restoring 2 vaults at the Three Mile
Bay cemetery, repairing the fence at the Market Street cemetery, and
restoring the Cape Vincent Fire Hall Tower/Clock.
SDEIS Response 73.33 All 34.5 kV lines will be buried except in the case where an
environmental or geological condition exists to prevent burring. The
115 kV transmission line will be above and will be constructed to all
applicable regulations.
GENERAL/MISCELLANEOUS
DEIS Response 4.3 All documents added to the website after publication of the DEIS were
included or referenced in the SDEIS, which was sent to all involved
and interested agencies and made publicly available pursuant to
appropriate notice.
DEIS Response 4.23 The Final Report is included in Appendix E of the SDEIS.
DEIS Response 14.15 Wetlands have been field-delineated and the Project layout revised to
avoid or minimize impacts to wetlands. If construction work is
required near wetlands, the wetland will be marked so that they will be
avoided if there is not already a proposed impact to said wetland. SLW
will receive permit authorization from the USACE under Nationwide
Permits 12 and 14 for temporary and permanent impacts to wetlands.
DEIS Response 17.1 Additional mitigation measures were provided in the SDEIS. More
elaboration in mitigation measures for modifications since the SDEIS
can be found in the FEIS narrative and in the various Appendices
therein.
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Exhibit 4.1.3 - Population Density Associated with Operational Wind Energy Facilities in New York.
Population
Density
(Persons Power
Name Municipality Location Population Area Units
per square Capacity (MW)
mile)
Dutch Hill/Cohocton Wind Farm Cohocton Steuben County 2,626 54.68 48.02 125 50
Steel Winds Wind Farm Lackawanna Erie County 19,064 6.45 2957.89 20 8
High Sheldon Energy Sheldon Wyoming County 2,561 47.45 53.97 112.5 75
Noble Altona Windpark Altona Clinton County 3,160 101.43 31.16 97.5 65
Noble Chateaugay Chateaugay Franklin County 2,036 48.77 41.75 106.5 71
Noble Wethersfield Wethersfield Wyoming County 891 36.13 24.66 126 84
Noble Bliss Windpark Bliss, Eagle Wyoming County 1,194 36.48 32.73 100.5 67
Noble Clinton Windpark Clinton Clinton County 727 67.13 10.83 100.5 67
Noble Ellenburg Windpark Ellenburg Clinton County 1,812 107.29 16.89 81 54
Munnsville Munnsville Madison County 437 0.86 506.22 34.5 23
Maple Ridge Wind Farm Lowville Lewis County 4,548 36.43 124.85 321.75 195
South Holt Wind Farm East Shoreham Suffolk County 448,248 241.03 1859.74 0.1 2
(Brookhaven)
Calverton Calverton (Riverhead) Suffolk County 27,680 68.01 407.00 0.05 1
HARBEC Plastics Inc. Wind Turbine Ontario Wayne County 9,778 32.55 300.38 0.25 1
Fenner Wind Power Project Cazenovia Madison County 6,481 50.17 129.17 30 20
Madison Wind Power Project Madison Madison County 2,801 40.94 68.42 11.55 7
Wethersfield Wind Power Gainesville Wyoming County 2,333 33.91 68.80 6.6 10
Average 393.09
SLW Cape Vincent, Town Jefferson County 3,345 55.91 59.83 79.5 53
SLW Cape Vincent, Village Jefferson County 760 0.54 1413.98 79.5 53
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DEIS Response 38.4 An SDEIS was prepared to provide additional analyses of the
environmental impacts of the proposed Project. The assumptions and
other parameters on which the environmental assessment were based
were fully described in Sections 2.1, 2.5, 2.6, 4.0 and 7.0. All of the
assumptions utilized were accurate.
DEIS Response 75.3 Section 3.12.1.1 addresses "Microwave Analysis" and Section 3.13.1.1
actually addresses construction impacts and should be titled such.
This was corrected in the SDEIS.
DEIS Response 75.5 The information provided in both tables, while stated slightly
differently, is correct. The summaries in Table 1-6 are slightly more
descriptive. These tables have been revised and appeared as Tables 1-
2 and 2-3 in the SDEIS. The same language was used in both tables to
avoid confusion.
DEIS Response 81.6 Curriculum Vitae Noted.
DEIS Response 84.1 SLW has proposed a Complaint Resolution Plan, which outlines how
the Project will handle complaints of various natures during
operations. Please see Appendix C-11 for the most recent version of
the proposed plan.
DEIS Response 90.1 Article Noted.
DEIS Response 97.1 The use of the term "appropriate" was intended to convey that setbacks
determined under local, state or federal guidance or regulations would
be implemented.
DEIS Response 101.1 The Project layout had been revised and 51turbines are proposed. In
addition, the SDEIS addresses visual impacts in Section 3.8, avian
impacts in Sections 3.3.4 through 3.3.6, and noise in Section 3.10.
Section 3.13.3.2.1 of the SDEIS provided further information
regarding the risk of ice shedding and mitigation measures. Also see
response to SDEIS Comments 4.15 and 18.3.
DEIS Response 102.1 The SDEIS addresses visual impacts in Section 3.8 and noise in
Section 3.10. Regarding tourism, see response to Comments 43.8. In
addition, the Project layout complies with setback criteria established
by the Town of Cape Vincent Planning Board.
DEIS Response 107.3 This comment addresses issues outside the scope of this EIS.
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DEIS Response 108.1 Comment noted. The Project layout complies with setback criteria
established by the Town of Cape Vincent Planning Board.
SDEIS Response 4.7 Please see responses to Comments 4.9 through 4.25.
GROUNDWATER
SDEIS Response 74.1 Construction activities can generate ground-transmitted vibration
forces that may result in ground disturbance and potentially affect
existing features proximal to the activity. These generated vibrations
attenuate over distance from the source. The magnitude of the
vibration and the attenuation rate are related to the construction
method used for excavation (e.g., mechanical, blasting), type of
construction equipment (e.g., hydraulic excavators, front end loaders),
and conductivity of the surface and subsurface substrates (e.g., sands,
clays, frozen soils, bedrock). In determining the distance from
turbines for pre-construction surveys of private water supply wells, it
was assumed that standard excavation equipment would be used and
no blasting would be required. Using such equipment and techniques
generated vibration effects typically are below levels of perception at
distances of 500 feet from the source (Amick and Gendreau, 2000).
Even considering the use of controlled blasting, construction
vibrations would be well below the threshold for residential damage.
However, since site-specific geologic and hydrogeologic investigation
has not been performed in the Project Area, distances for the well
survey radius will be revisited as part of these studies and the distance
may be adjusted either nearer or further from the source.
LAND USE AND ZONING

DEIS Response 3.1 Cable depth will be 48" below grade or 6" beyond the depth of
bedrock.
DEIS Response 3.2 Collection system 34.5kV will be underground in the Project area up
to the 34.5/115kV substation. The underground lines will be located
outside of field boundaries where possible. From the substation to the
point of interconnect, the 115kV overhead line will mostly follow the
abandoned railroad bed.
DEIS Response 3.3 SLW has met with the New York State Department of Agriculture and
Markets and will follow the revised Guidelines for Agricultural
Mitigation for Windpower Projects.
DEIS Response 4.30 Efforts have been made in the Project design to minimize impacts to
wetlands and habitat areas. Wetland mapping was used to help design
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the Project to avoid NYS-regulated wetlands as well as other

jurisdictional wetlands under the Clean Water Act. The efforts to
design the Project to avoid wetland impacts have reduced the level of
wetland permit needs to that of a Nationwide Permit from the USACE
for a few stream crossings.
DEIS Response 4.33 Comment noted. Consistency review is not required so long as the
Project continues to qualify under USACE Nationwide Permits 12 and
14.
DEIS Response 4.6 Because the Project, as now proposed, will be less than 80 MW in
output, a Certificate of Public Convenience and Necessity issued by
the PSC will not be required. The Project will coordinate with the
New York State Department of Agriculture and Markets to assure that
the goals of these guidelines are being met.
DEIS Response 14.3 The Comprehensive Plan provides that the Town and the Village
should: “Discourage: Location of towers, prisons or utility facilities
where there [sic] impact would have a negative impact on scenic vistas
and tourism assets.” SLW proposes that its wind turbines be located in
Cape Vincent’s agricultural district, not in the river or lake district, the
two districts most associated with Cape Vincent’s “tourism assets.”
The Cape Vincent Correctional Facility is located in the agricultural
district south of Route 12E. Placement of wind turbines in the
agricultural district is more compatible with Cape Vincent’s 2003 Joint
Comprehensive Plan, than the Cape Vincent Correctional Facility.
Cape Vincent’s “scenic natural vistas” are already affected by the
Wolfe Island EcoPower Centre project. With the 86 wind turbines
already erected and operating in the Wolfe Island project, wind
turbines are now part of the environment of the area. The visual
impact analyses in the SDEIS demonstrate that the Project will not
have a negative impact on scenic vistas or tourism assets.
DEIS Response 14.4 SLW has not requested any changes to the laws or guidelines that
NYSDEC administers. The project layout was designed to be
compliant with the local, state and federal regulations.
DEIS Response 21.6 Siting for individual turbines was based on a number of parameters
and constraints. The USFWS and the NYSDEC were consulted in the
process and have made recommendations on moving the turbines to
avoid or minimize impacts to sensitive species.
DEIS Response 39.3 The SDEIS included corrected text indicating that electrical cables will
be buried a minimum burial depth of 48 inches in agricultural areas in
accordance with the NYS Department of Agriculture and Markets.
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DEIS Response 43.4 The Applicant is not aware of any such studies that compare land use
after a wind facility has been constructed to areas without wind
development. Regardless, a determining factor for future development
would be constraints imposed by zoning and local ordinances. In
practice, zoning is used to ensure compatible land use and prevent
future development from interfering with existing land use.
DEIS Response 79.2 The height restrictions in the Cape Vincent Zoning Law apply only to
buildings, and do not apply to the wind turbines. The wind turbines
may properly be authorized by the Planning Board pursuant to a duly
issued site plan approval.
DEIS Response 83.2 As stated in Article 2 of the Local Law to Amend the Town of Cape
Vincent Zoning Law (2006), the Town Board of the Town of Cape
Vincent recognizes the increased demand for alternative energy
generating facilities and the need for more inexpensive power that
wind turbine facilities may provide. The Zoning Law amendment
added Commercial Wind Power Facilities as an allowed Site Plan Use
in the Agricultural Residential District. In conformance with the Town
Zoning Law, the Project Area is located entirely with the Agricultural
Residential District.
SDEIS Response 3.1 Comment noted. Consistency review is not required so long as the
14. In order to qualify under Nationwide Permits 12 and 14, the
Project must not be located in areas covered by: 1) The Long Island
Sound Regional Coastal Management Program; 2) Waterfront
Revitalization Programs; 3) Significant Coastal Fish and Wildlife
Habitats; 4) Scenic Areas of Statewide Significance; and 5) Harbor
Management Plans. The SLW Project is located outside of the areas
covered by those programs/habitats.
SDEIS Response 11.2 There is no 2004 Village and Town of Cape Vincent Joint
Comprehensive Plan. To address this comment, we will assume the
commenter is referring to the 2003 Village and Town of Cape Vincent
Joint Comprehensive Plan. The commenter misquotes the relevant
portion of that Plan, which, in actuality, provides that the Town and
the Village should: “Discourage: Location of towers, prisons or utility
facilities where there [sic] impact would have a negative impact on
scenic vistas and tourism assets.” SLW proposes that its wind turbines
be located in Cape Vincent’s agricultural district, not in the river or
lake district, the two districts most associated with Cape Vincent’s
“tourism assets.” The Cape Vincent Correctional Facility is located in
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the agricultural district south of Route 12E.Placement of wind turbines

in the agricultural district is more compatible with Cape Vincent’s
2003 Joint Comprehensive Plan, than the Cape Vincent Correctional
Facility.. The commenter’s selective misquote changes the meaning of
the relevant portion of the Plan by eliminating the limit included in the
Plan that such siting is discouraged only where there is a negative
impact on scenic and tourism assets. Cape Vincent’s “scenic natural
vistas” are already affected by the Wolfe Island EcoPower Centre
project. With the 86 wind turbines already erected and operating in
the Wolfe Island project, wind turbines are now part of the
environment of the area. The visual impact analyses in the SDEIS
demonstrate that the Project will not have a negative impact on scenic
vistas or tourism assets.
SDEIS Response 20.6 Under a PILOT agreement, the proposed project will make payments
in lieu of taxes well in excess of what the applicable agricultural
assessments would produce.
SDEIS Response 20.15 The St Lawrence Wind Power project meets or exceeds all of the
setback requirements established by the Town of Cape Vincent
Planning Board. No project facilities have been proposed in the Lake
or River District in the Town of Cape Vincent. The SDEIS fully
described, and the public has had the opportunity to comment on, the
potential visual impacts of the Project.
SDEIS Response 20.16 We are not aware of any evidence that supports a link between a
decrease in property values related to operation on wind power
projects. In fact, a newer study conducted by the National Renewable
Energy Laboratory (2009) concludes that:
x Homes in the study areas analyzed do not appear to be measurably
stigmatized by the arrival of a wind facility;
x None of the various models finds strong statistical evidence that
the view of a nearby wind facility impacts sales prices in a
significant and consistent manner
x Homes in the sample that are within a mile of the nearest wind
facility, where various nuisance effects have been posited, have not
been broadly and measurably affected by the presence of those
wind facilities.
Because the evidence is that wind energy projects do not have a
statistically-measurable impact on property values in the communities
surrounding them, the construction and operation of the proposed
project should not negatively impact tax assessments. The Town of
Cape Vincent would receive an increase in tax revenue from a PILOT
agreement from the proposed Project.
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SDEIS Response 45.3 The comment does not specify the basis for the claimed deleterious
effect. The impact analyses in the EIS demonstrate that the Project
will not have such an effect on the area.
Considering the 86 turbines of the Wolfe Island EcoPower Center now
erected in the primary view shed of Cape Vincent’s River District and
Lake District, the visual impact of 51 turbines in Cape Vincent
agricultural district will be minimal.
In addressing SHPO concerns, SLW is proposing visual mitigation,
including vegetative screening and historical restoration of the
Tibbett’s Point Lighthouse, the Market Street Cemetery, the Cape
Vincent Fire Hall, and the Three Mile Bay Cemetery.
SDEIS Response 45.5 The Planning Board acted within its lawful jurisdiction in adopting its
review criteria. Those criteria do not constitute a zoning ordinance or
local law of general applicability within the Town. Rather, they are
project review criteria to be utilized in the exercise of the jurisdiction
committed to the Board under the N.Y. Town Law and the Town’s
zoning ordinance.
NOISE
DEIS Response 7.7 In response to this and other comments, SLW undertook an ambient
sound level survey to determine the average sound levels in the
summer and winter. Those results are described in Appendix L of the
SDEIS. In being conservative, since winter ambient sound levels were
found to be lower than the summer levels, winter ambient sound levels
were utilized during the noise modeling.
DEIS Response 11.9 There have been many comments based on sound levels. SLW
engaged an experienced consultant to perform ambient noise level
surveys. SLW’s surveys used the most conservative average ambient
noise levels, from winter noise monitoring surveys to model predictive
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noise levels. The most up-to-date noise assessment is located in

Appendix C-4 and Section 2.2.3 of the FEIS.
DEIS Response 14.7 Updated noise reports can be found in Appendix L of the SDEIS and
Appendix C-4 of the FEIS. The project is proposing a Complaint
Resolution Process (please see Appendix C-11 of the FEIS) in order to
determine and mitigate noise complaints after construction.
DEIS Response 94.1 Turbines have been known to disrupt sleep if setbacks are not
adequate. SLW will keep setbacks from residences at an adequate
distance to prevent sleep disruption, unless participants have waived
their setback. In addition, a Complaint Resolution Process has been
developed (and is included in Appendix C-11) which will provide a
way for noise complaints to be handled after construction of the
facility. There is no statistical evidence that wind turbines devalue
properties. In fact, a recent study performed by the Lawrence
Berkeley Lab has shown exactly that.
DEIS Response 111.2 SLW has undertaken an ambient noise assessment. The Planning
Board has not established any specifically applicable noise guidelines.
DEIS Response 111.3 Turbines will begin operation when the wind speed at hub height
reaches cut-in speed.
DEIS Response 111.5 An updated assessment is found in Section 2.2.3 and Appendix C-4 of
the FEIS.
DEIS Response 111.9 Please see response to comment 11.9.
DEIS Response 113.17b Because of concerns regarding actual sound levels occurring at the
site, SLW has performed ambient sound level surveys in the winter
and summer, including night-time monitoring. The full report can be
found in Appendix L of the SDEIS.
SDEIS Response 7.8 SLW will consult with State Parks to discuss ways to avoid and
minimize noise impacts on State parks during construction.
SDEIS Response 11.13 Paul Schomer’s review of the Hessler summertime background sound
level study associated with the BP project was essentially written on
the basis of insufficient information; specifically, he was not aware
that a wintertime survey was subsequently carried out during which
much lower background sound levels were found and that the summer
survey was undertaken only at the request of the client in an effort to
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be more thorough than is usual and evaluate seasonal differences in

environmental sound levels (typically only a winter survey is done for
projects of this nature).
In response to the specific concern expressed in the comment above,
the monitoring position on the corner of Huff Road and Route 12E was
selected to be representative of the houses that front directly on Route
12E and determine whether they experienced significantly different
sound levels due to traffic than homes elsewhere within the Project
area. Although there happened to be some construction trailers
adjacent to the monitoring station, no significant construction activities
or machinery noise occurred during either survey. This is
substantiated by the fact that the measurements at this position during
both the summer and winter surveys showed that, despite moderate
traffic activity on 12E, the L90 sound levels at this location were no
different from those at most other monitoring positions. No effort
whatsoever was made to schedule the survey to coincide with insect
noise. The survey dates were largely dictated by the time of year when
the Project was commissioned and by personnel and equipment
availability.
Moreover, the summertime survey results were essentially reported
simply to illustrate that background sound levels during the warm
weather months can to be substantially higher than during the winter.
As stated in the conclusions of Hessler’s report for the SLW Project,
the wintertime results were conservatively “taken to represent the
background, year-round [background] level.” The report clearly
acknowledges that the summer results are dominated by insect noise
and therefore very little importance is attached to them. The
summertime sound survey results were largely reported for the sake of
completeness but the much lower wintertime results were used for
design and assessment purposes. The sound level of 37 dBA is the
value measured throughout the site area during the winter when a
critical 6 m/s wind was blowing; i.e. during the wind conditions when
project noise is most likely to be prominent relative to the background
level. This winter value was used as a year-round design basis in the
modeling study. During the summer a much higher level of 44 dBA
was measured during these wind conditions – and was not used to
evaluate noise impacts because of the high frequency contamination
known to be inherent in the data.
SDEIS Response 11.14 Noise emission levels were certified not by the manufacturer, but by
an independent certification entity, WINDTEST in Germany. The
certification was performed in accordance with International
Engineering Code 61400-11 and is accepted worldwide as standard
procedures for determining noise emissions measurements.
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SDEIS Response 12.1 Updated sound data was provided in the SDEIS in response to
comments made on the DEIS, including the February and March
letters referenced by the commenter. The updated sound analysis in
Section 3.10 of the SDEIS was accepted as complete by the Lead
Agency on March 25, 2009.
SLW has had a number of calls and other exchanges with Hessler
Associates, Bernier & Carr, and Cavanaugh, Tocci, & Associates
(CTA) in the past months to discuss the best approach to items that
were of concern. CTA was provided the raw data from Hessler’s
ambient sound level study, along with final contour maps of the
expected impacts from the wind farm. Based on these data, SLW was
asked to explain specific information about when impacts may be
greater than expected in the noise modeling results. Section 2 and
Appendix C-4 of this FEIS thoroughly describe current noise impacts
assessed for the St. Lawrence Wind Farm and indicate times when
noise impacts may exceed that which is expected. In addition, SLW
has made commitments to curtail turbines or perform other mitigation,
to comply with the NYSDEC guidelines for noise impacts. Please see
Section 2.2.3 of the FEIS for a complete description of mitigation
measures SLW will deploy.
SDEIS Response 15.2 First of all, acoustic studies should be undertaken by a person with
credentials in the acoustic engineering field. It is technically
challenging to measure sound levels in a meaningful way under the
wind conditions that the turbines will operate in. Measurements under
calm conditions, for example, are largely irrelevant since the Project
will normally be idle under such conditions. Secondly, the monitoring
locations chosen by Hessler Associates, Inc., the acoustic engineering
firm that performed the sound studies for SLW, were specifically
selected to be typical and representative of the area and to measure the
sound levels experienced in a variety of settings, including along the
river shore as directed by the Planning Board (Position 3). The
remaining positions were at or near residences and farms typical of the
area. The monitor at the Woods Farm ("the largest dairy in town")
was deliberately located well away from any of the diary operations
and was not influenced by farm activities or milking operations. The
other monitors were similarly situated so that they would not be
affected by any local contaminating noises. Position 5, at a farmhouse
located directly on Rt. 12E, was chosen specifically to evaluate
whether the homes along this fairly major road experienced relatively
high sound levels due to traffic - but no significant difference was
observed; largely because the conservative (L90) level was used in the
analysis, which tends to filter out sporadic, short-duration sounds like
cars passing by. None of the monitors for the SLW survey were
located near a construction site (one of the positions for the BP project
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was situated near some construction trailers but there was no

significant construction activity at that location during the survey
period). In general, the levels recorded at all positions were similar
indicating that they were representative of the site as a whole. One
position (Position 4) on Branche Road was somewhat higher than the
others for no obvious reason - so that data was excluded from the
analysis. As a final note, a project sound level of 5 dBA above the
background level is a design goal and guideline recommendation per
the NYSDEC and should not be interpreted as a hard and fast
regulatory limit.
SDEIS Response 15.3 The independent study identified in this comment did not assess wind
turbine sound, as it relates to health issues. Low frequency noise, as it
is referenced here, has many sources, such as machinery and
transportation. This type of sound is generally always present as an
element of background noise. Low frequency noise also dissipates
quickly over distance. A recent white paper developed by a group of
doctors and acoustic scientists explains that “Infrasound at a frequency
of 20 Hz (the upper limit of infrasound) is not detectable at levels
lower than 79 dB. Infrasound at 145 dB at 20 Hz and at 165 dB at 2 Hz
can stimulate the auditory system and cause severe pain. These noise
levels are substantially higher than any noise generated by wind
turbines. The U.S. Food and Drug Administration (FDA) has approved
the use of infrasound for therapeutic massage at 70 dB in the 8 to 14
Hz range. In light of the FDA approval for this type of therapeutic use
of infrasound, it is reasonable to conclude that exposure to infrasound
in the 70 dB range is safe. According to a report of the National
Research Council (NRC), low frequency sound is a concern for older
wind turbines but not the modern type.”
SLW has been diligent about siting turbines with setbacks to homes, in
order to minimize issues related to sound. In addition, please see the
revised Noise Modeling Assessment in Appendix C-4 of the FEIS for
a complete description and illustration of sound levels that residents
may be affected.
SDEIS Response 15.7 No residences will be impacted by shadow flicker more than 30 hours
per year. Shadow flicker is not expected to create an adverse impact on
nearby residences therefore no mitigation is needed. To mitigate sound
during construction the Project will: Adhere to regular construction
work hours Mondays through Saturdays, and typically not working on
Sundays or after dark; All construction equipment will be maintained
in good working condition in order to reduce general noise emissions;
When practical, heavy equipment will be shut down when not active,
to minimize idling noise; All internal combustion engines will be fitted
with appropriate muffler systems; and Adjacent landowners will be
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advised in advance of any significant noise-causing activities and these

will be scheduled to create the least disruption to residents. In addition,
turbine locations will continue to be evaluated based upon potential
noise impacts from the St. Lawrence project, as well as potential
cumulative impacts from the St. Lawrence and BP projects.
The Project has been purposely designed to minimize environmental
noise during Project operations by siting wind turbines as far away
from existing residential receptor locations as practicable, while
keeping the Project an economically viable source of clean renewable
energy. In addition, the Project has selected the 1.5 MW Acciona AW-
82/1500 WTG, which is among the quietest wind turbines
commercially available for its class, size, and power rating.[Present a
very quick summary of model results] Given the model results, it is
not expected that mitigative measures will be required during Project
operations; however, the following options will be considered by
SLW, if needed: Implementing a complaint resolution program
whereby neighboring residents can contact SLW with their concerns.
Complaints will be logged and promptly investigated in order to
resolve any verifiable issue or exceedance condition, and mitigation
may be taken on a case-by-case basis. Elements of the complaint
resolution program include: providing a dedicated Community
Relations employee, preconstruction communication, safety and
environmental compliance briefings, providing channels for
registering a complaint, and formalized process to resolve a complaint.
SDEIS Response 25.25 Low frequency sound is generally defined as frequencies between
10Hz and 100Hz. This type of sound has many sources, such as
machinery and transportation, and is always present as an element of
background noise. Low-frequency sound weakens rapidly with
distance. The aerodynamic "whooshing" sound of a modern wind
turbine is not low-frequency sound.
SDEIS Response 25.72 An Environmental Sound Level Survey was provided in Appendix L
to the SDEIS with the requested information on pages 3-160 to 3-176
of the SDEIS.
SDEIS Response 34.2 Measurement Position 3 was established in the rear of 33835 Route
12E within a few yards of the riverbank specifically to measure sound
levels that would be experienced at the many residences along the
shoreline. This location was almost literally on the riverbank and was
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at the bottom of an embankment that largely shielded the monitor from

traffic noise on Rt. 12E. The sound levels measured at this location
did not differ in any significant way from the levels measured at the
majority of other locations further inland and followed the same,
generally wind driven trends observed at all other monitoring stations.
Because the background levels at all 6 monitoring stations distributed
over the Project were essentially similar, there is no reason to believe
that the sound levels would be substantially different at a location
between the sampling positions or anywhere else in the Project area
including elsewhere along the river shore. Consequently, the
suggested use of numerous additional monitoring stations is highly
unlikely to have resulted in a different answer.
There is nothing insufficient or inadequate about a 17 day survey,
which is longer than most such surveys performed by other engineers
for other wind projects. A full range of wind speeds and weather
conditions were observed during this period and there is no reason to
believe that a longer survey would have yielded any additional
information on typical background sound levels during the wintertime.
The latest noise guidelines recently published by the World Health
Organization (WHO) "Night Noise Guidelines for Europe," 2009
indicates that an outdoor sound level of 40 dBA or less does not result
in any significant adverse impact or sleep disturbance. Above 40 dBA
some risk of disturbance begins to slowly occur until becoming very
significant at 55 dBA. The maximum sound level predicted at any
residences in the Project area is about 43 dBA, while a level of 40
dBA or less is expected at the vast majority of homes, including all of
those along the river shore. Cavanaugh, Tocci and Associates were
hired to conduct an independent review of SLW’s sound studies for
the Town Planning Board.
SDEIS Response 45.6 Please see response to Comment 15.2. Additionally, participating
landowners were chosen for test site because SLWF has permission to
enter property from participating landowners. All the equipment used
for the SLW field survey is routinely used in harsh wintertime
conditions without any problems. All the instruments functioned
perfectly during the winter survey, despite the cold weather. The
calibration of the meters was checked at the end of the survey and the
maximum drift was -0.5 dB on one meter and less than +/- 0.2 dB on
all others, which is normal. Roughly 2500 measurements were
recorded and stored at each of the 6 positions, resulting in over 15,000
data points over each of the two surveys (summer and winter), which
ran day and night for 17 and 20 days, respectively. The 10 minute
average (Leq) and residual (L90) levels were reported and analyzed for
both surveys. Other statistical measures with significantly higher
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values, such as the L10 and Lmax, were also recorded but neglected in
the analysis. The primary measure for the background level was taken
as the conservative L90 level, which is the near-minimum sound level
that occurs during momentary quiet periods.
SDEIS Response 47.11 CTA was provided the raw data from Hessler’s ambient sound level
study, along with final contour maps of the expected impacts from the
wind farm. Based on these data, SLW was asked to explain specific
information about when impacts may be greater than expected in the
noise modeling results. Section 2 and Appendix C-4 of this FEIS
thoroughly describe current noise impacts assessed for the St.
Lawrence Wind Farm and indicate times when noise impacts may
exceed that which is expected. In addition, SLW has made
commitments to curtail turbines, or perform other mitigation, during
those times where noise may exceed NYSDEC guidelines for noise
impacts.
SDEIS Response 59.2 Please see revised impact analysis in Appendix C-4 for updated
analyses concerning each turbine location.
SDEIS Response 62.1 Please see revised noise impact analysis in Appendix C-4.
SDEIS Response 62.2 Please see revised noise impact analysis in Appendix C-4.
SDEIS Response 62.3 The study describes what Leq is, but uses L90 as its unit of measure.
SDEIS Response 62.4 After discussions between the Town’s engineer, consultant, and SLW
consultant, a revised noise impact analysis was conducted using
methods agreed upon by all parties. Another background study was
not included in this agreed-upon method. Please see Appendix C-4.
SDEIS Response 62.5 The commenter does not provide information explaining why he
thinks the background sound should be assumed at 26 dBA. The
ambient sound study that was performed by Hessler and Associates
indicated that the ambient background average for the St. Lawrence
project area was not 26 dBA.
SDEIS Response 62.6 Source levels presented in Table 3-30 of the SDEIS were obtained
from the IEC 61400-11 certified report of wind noise emissions,
undertaken for Acciona’s 82m rotor turbine and performed by
WINDTEST in Germany.
SDEIS Response 62.7 It is assumed that this comment goes along with Comment 62.5, as it is
5 dBA above the commenter’s assumption of 26 dBA background
level. The commenter does not give reason for the assumption of the
background level. The Town’s Noise consultant and Hessler, the
Project’s noise consultant, along with the Town’s engineers and
project representatives have discussed the results of Hessler’s noise
study in relation to the final revised layout provided in the FEIS. That
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discussion resulted in a revised sound assessment, which is presented

in Section 2.2.3 of the FEIS.
SDEIS Response 62.8 The ground absorption coefficient is set at 0.5, which is the standard
coefficient for a project in an agricultural setting.
SDEIS Response 62.10 See Section 2.4.3 for a description of mitigation efforts that will be
undertaken by SLW. The SLW Project layout and extent of study
complies with the recommendations in the state guidelines.
SDEIS Response 62.12 SLW disagrees that the narrative in the Noise Level Report diminishes
the importance of the state guidelines. This description was written in
order to explain fully how to interpret those guidelines.
SDEIS Response 62.16 Summertime background noise levels were taken to show that they are
generally higher than wintertime levels. SLW consultant utilized the
lower, wintertime data as a conservative way to arrive at noise
impacts.
SDEIS Response 62.17 VanDerBerg was not the consultant who performed the testing at the
Project location. Data were collected and scientifically examined by
the Project sponsored consultant. In collaboration with the Town and
its consultant, a revised study is located in Appendix C-4. Please refer
to this Appendix and the Sections in the FEIS that represent the final
layout and how noise impacts are predicted to impact the Town of
Cape Vincent.
SDEIS Response 62.18 Please see Appendix C-4 for revised Noise Impact Analysis.
SDEIS Response 73.4 Wind shear profile and thermal gradient at night, particularly during
the summertime, can result in an increase in operational noise and its
ability to propagate through the atmosphere increasing its relative
perceptibility. To our knowledge this phenomenon is observed at
many wind project sites and, unfortunately, there is no practical way of
designing or arranging a project so that operational noise is
inconsequential at all time at all neighboring residences. However,
experience evaluating newly completed projects in NY and elsewhere
shows that where project noise was observed to increase at night
relative to background level, complaints are minimal where when the
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normal, or mean, sound level is about 40 dBA or less at residences, as

is largely expected with the SLW Project. It is only when the mean
predicted level at residences is significantly higher, such as in the 45 to
50 dBA range, that further increases at night generally begin to
become substantial and problematic.
During modeling, SLW based the critical design case on what is
known and conservatively utilized the wind speed where the "normal"
turbine sound level is maximum relative to, what is considered the
near-minimum, background level as the design condition (see Report
1829-082108-A, Oct. 22, 2008 in Appendix L of the SDEIS and
Appendix C-4 of the FEIS). To ensure transparency, Hessler
explained this at some length in a presentation to the Cape Vincent
Planning Board in April 2010 (see Appendix A of the FEIS – for a
copy of the Hessler presentation to the Planning Board.).
SDEIS Response 73.5 Operational studies conducted by the project’s consultant, Hessler,
indicate strong correlation with pre-construction assessments. Please
see revised Noise Impact Analysis in Appendix C-4 for detailed
information and data.
SDEIS Response 73.57 In general, as distance increases, the sound from wind turbines
dissipates. A final noise impact analysis is located in Appendix C-4.
SDEIS Response 73.77 The overall results of the model evaluating compliance with the State
guideline show the area inside of the 42 dBA sound contour line
represents the region where sound from the Project may result in an
adverse impact. This plot indicates that the overwhelming majority of
non-participating residences will be subject to sound level increases of
less than 6 dBA, and in most cases, much less than 6 dBA. There are
only three houses just inside of the nominal 42 dBA threshold.
SDEIS Response 73.78 Please see response Comment 73.4.
SDEIS Response 73.79 Ambient noise does not significantly change throughout the Project
area; therefore it is not necessary for ambient measurements beside
each proposed turbine location. The project is paying the cost for the
Town Planning Board to hire an independent consultant to review the
noise study. Modern wind turbines of the type proposed for this project
do not generate low frequency noise.
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OPERATIONS AND MAINTENANCE

DEIS Response 1.9 Site restoration processes are described in the SDEIS in Section 2.8.2,
and these same specifications would be followed in the event of major
repair or replacement of a turbine, or other major components.
Restoration to wetlands is fully described in the Joint Nationwide
Permit application submitted tot eh USACE and NYSDEC and also in
Section 3.2.3 of the SDEIS. In addition, a draft Wildlife Protection
Plan is set forth in Appendix C-13 of the FEIS.
DEIS Response 1.10 Section 2.2.1 of the FEIS describes the wetland mitigation measures
that are proposed for the Project. In addition, the Joint Nationwide
Wetland Permit application (found on the St. Lawrence Windpower
website at www.stlawrencewind.com) includes a more detailed
description of wetland mitigation measures that the Project will
undertake to compensate for permanent wetland impacts.
SDEIS Response 4.17 Turbine maintenance, safety inspections and verification of tower
integrity is performed in accordance with the maintenance manuals
provided by the Original Equipment Manufacturer (OEM). Acciona
Energy incorporates lessons learned from their experience with the
specific equipment to ensure that the maintenances are performed in
the most efficient manner while ensuring quality. These maintenances
include visual inspections, torque checks, mechanical checks,
electrical checks and functional checks.
Collector and substation maintenance is performed annually, or as
required by the specific equipment manuals. This maintenance
includes visual as well as functional checks of the existing equipment.
During the construction phase the vegetation is cleared in the areas of
the wind turbines, collector station and transmission lines. During the
day to day operations items are handled on a case by case basis. Local
contractors are used to ensure that local requirements are met and to
ensure a high reliability and availability of the system.
Schedules are based on OEM recommendations. This is usually every
6 months for WTG components and annually for the electrical
infrastructure.
Acciona Energy works closely with the local landowners and
communities to establish processes to meet the local requirements.
SDEIS Response 15.5 Prior to construction, SLW will
communicate to neighboring residents, the Towns and permitting
agencies, the contact name and address of its Community Relations
staff and its Construction Manager (and, prior to the end of
construction, our Operations Manager). SLW will also publish a 1-
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800 number to the community that will be accessed within 24 hours by

construction or operations personnel.
Written complaints shall be directed to SLW and responded to by
SLW or its duly authorized representative within five (5) calendar days
after receipt of any such complaint. SLW will keep a log of any such
complaints received, which log will be reviewable by the Town Code
Enforcement Officer upon request.
In the event that SLW receives complaints either from neighboring
residents, Landowners or local businesses operations, SLW will
promptly work directly with the complainant and the Town, if
necessary, to investigate and resolve the issue to the satisfaction of
both parties. In the event that the complaint is not resolved to the
satisfaction of the complainant, or that an agreed upon solution is not
under development within 30 days of receipt of the complaint, the
complainant may refer the matter to the Complaint Resolution Board.
The Complaint Resolution Board will consist of three members: an
SLW designee, a Town Officer or Employee appointed to the position
annually, and an independent third party expert. The independent third
party expert member of the Complaint Resolution Board shall be
mutually agreed upon by SLW and the Town appointee, individually
for each matter considered by the Board.
The Complaint Resolution Board will hear the complaint within no
more than thirty (30) days after the appeal is made by the
Complainant, and a decision of the Board will be rendered within
thirty (30) days after the close of the complaint hearing. The decision
of the Complaint Resolution Board will set forth the manner in which
the complaint shall be resolved and the reasons why such resolution is
appropriate. In making such decision, the Complaint Resolution
Board shall take into account the terms and conditions of the special
use permit and approved site plans, and shall not require any resolution
that is inconsistent with such terms. The decision of the Complaint
Resolution Board will be final and binding upon SLW, the individual
or group filing the complaint and the Town.
A revised Complaint Resolution Procedure is set forth in Appendix C-
11 of the FEIS.
SDEIS Response 17.5 Section 3.1.3 (pages 3-15 to 3-20) of the SDEIS describes how the
Project will manage impacts of soils, geology, and topography during
and after construction of the proposed wind farm. Also, see the draft
SWPPP in Appendix C-8 of the FEIS for erosion and sedimentation
control measures. Section 2.8 (pages 2-20 to 2-25) describes how the
Project will manage impacts during decommissioning. SLW will
comply with all state, federal, and local laws and regulations during
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any repair periods and in and around the O&M building (for instance,
waste management). Further, a draft Spill Prevention, Control, and
Countermeasure (SPCC) Plan is located in Appendix C-12 of the
FEIS.
SDEIS Response 25.58 SLW will solely maintain the access roads leading to the turbines.
SDEIS Response 32.3 A revised Complaint Resolution Procedure is provided in Appendix C-
11.
PHYSIOGRAPHY, GEOLOGY, AND SOILS

DEIS Response 1.12 To date, no karst features have been identified at the Project site from
a review of available geologic maps and visible imagery. During this
review, only one potential karst feature was identified in the vicinity of
the project, a cave located northeast of the Project site in Millen Bay.
However, to address this issue, a comprehensive investigation of
possible karst features at the Project site is anticipated to be completed
as part of the Site Plan Review process. The investigation will be
carried out in three phases, as follows:
Phase 1. Geologic resources detailing local and regional surficial and
bedrock geologic investigations will be gathered and reviewed. Karst
terrain, local geologic conditions, and geologic hazards will be
assessed. Bedrock features (e.g., lithologic variations or faults mapped
by others, or areas of possible karst visible on imagery or maps) will
be interpreted. A field geologist will complete a reconnaissance of the
Project site to observe karst conditions (if visible) on a site-wide and
regional scale, and prepare for a geophysical investigations (Phase 2).
Phase 2. A non-intrusive geophysical investigation will be completed
at select turbine locations to confirm and expand upon the findings
from Phase 1. The geophysical methods are likely to include:
x Two dimensional (2-D) resistivity imaging.
x Multi-channel analysis of surface waves (MASW).
Completion of 2-D resistivity imaging would result in color-shaded
resistivity cross-sections. The investigation depth will depend on the
actual resistivity of the local soil and bedrock, but it should result in an
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investigation depth of at least 50 feet throughout the central portion of

the survey traverse.
Intact limestone is likely to produce relatively high-resistivity data
values, whereas weathered, fractured, or solutioned rock is likely to
exhibit lower resistivities. The clayey soils that are present at the
Project site will likely enhance electrode contact and possibly result in
high resistivity data quality.
Completion of MASW, a recently developed geophysical seismic
technique, is intended to estimate shear-wave velocity variations at
depths up to 100 feet (at most, sometimes less). The results would be
depicted on color-shaded diagrams, depicting lateral and vertical
variations in estimated shear-wave velocity values beneath each
traverse. Typically, low-velocity zones would be indicative of
fractures, weathering, solutioning, or softer lithologies.
Phase 3. Based on the findings of Phase 2, intrusive geotechnical
borings will be completed at locations believed to contain karst and
non-karst features to confirm the analysis and interpretation of the
geophysical results.
DEIS Response 2.15 A study of karst features will be conducted as described in Section
3.1.3 of the SDEIS; Karst features will be identified and avoided.
SLW has undertaken ample bat studies, which identified a maternal
colony (not another hibernaculum) just outside the Project area.
DEIS Response 4.7 Please see Figures 3-1 and 3-2, and Section 2.6.5 of the SDEIS.
DEIS Response 14.2 It is not clear exactly which map the commenter is referring to;
however, the land capability classification provided by the Natural
Resource Conservation Service in the County Soil Surveys represents
groupings of soils based on their capability to produce common
cultivated crops and pasture plants without deteriorating over a long
period of time. These classifications identify limitations that restrict
their use for these primarily agriculture-related activities. They are
general descriptions that apply to large areas and site specific analysis
is usually required as conditions can vary within mapped units. The
building limitations associated with many of the soils within the
Project area are related to depth of bedrock and depth to water table
(soil wetness) as indicated in Table 3-1 of the SDEIS. Neither of these
conditions produces an insurmountable limitation to development of a
wind project.
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DEIS Response 112.1 Please see Figure 2-3, Figure 2-4 and Section 2.6.1 of the SDEIS.
SDEIS Response 2.5 The investigation will be provided during pre-construction and an
adequate mitigation plan will be developed, in collaboration with
NYSDEC. However, as indicated in Section 4.2 of the SWPPP
(Appendix C-8 of the FEIS) SLW will implement a suite of best
management practices in karst areas, and develop a strategy for the site
that will be best suited to function within the tolerance limits of the
natural system. For example: drainage ditches will be designed to
divert water away from karst features; lining of foundation excavations
and associated structures will be considered or evaluated, so that when
concrete is poured into the pit there is no loss of slurry into any karst
features/formation.
SDEIS Response 2.6 A draft SWPPP is set forth in Appendix C-8 of the FEIS. Included in
Section 4.2 of the SWPPP, is a suite of best management practices that
will implemented, based on the conditions of the area. If, after the
karst/geotechnical investigation is completed during pre-construction,
amendments to the SWPPP need to occur, SLW will work with the
NYSDEC to develop the amendments and a mitigation plan, if
necessary. A list of potential mitigation options is located in Section
2.2.1 of the FEIS.
SDEIS Response 25.7 Geotechnical studies will be completed prior to the start of
construction of the project.
SDEIS Response 25.9 Prior to construction, a detailed final geotechnical investigation will be
performed to identify subsurface conditions necessary for final design
and engineering of the Project. The geotechnical investigation will
include drilling test borings at designated locations to evaluate
subsurface geology and groundwater conditions, and performing field
tests and geotechnical laboratory tests on recovered samples to
evaluate the physical and engineering properties of the strata
encountered. SLW will also perform engineering analyses to develop
design and construction specifications for foundations, site subgrade,
and fill preparation. Soil borings, or test pits as necessary, are required
at each wind turbine location, the substation, and at certain intervals
along access roads. Borings will be performed in accordance with
local requirements, such as filling boreholes with grout after testing is
complete.
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PROJECT PURPOSE, PUBLIC NEED AND BENEFITS

DEIS Response 2.1 Wind energy generation results in reductions in air emissions because
of the way the electric power systems work. According to a 2008
NREL Report, wind energy is a preferred power source on an
economic basis because the operating costs to run the turbines are very
low because there are no fuel costs. Thus, when the wind turbines
produce power, electricity supplies from other sources will be reduced
or not brought online. Almost always, the most expensive power will
be backed down or avoided. Typically, wind power will displace
generation at individual fossil fuel-fired power plants, which have
higher operating costs and substantial fuel costs. Not only does wind
power displace CO2 emissions, it also displaces other emissions such
as NOx and SO2. According to NYSERDA (2005) and using New
York State's displacement mix of 15 percent coal, 65 percent natural
gas, 10 percent oil, and 10 percent imports; wind power displaces
approximately 0.63 tons of CO2, 0.0007 tons of NOx, and 0.0013 tons
of SO2 per MWh. A number of real-world experiences have shown the
following: 1) In 2007, wind energy in the U.S. reduced CO2 emissions
by over 28 million tons. On average, each MWh of wind energy
reduced CO2 emissions by 1200 pounds; 2) A study of a grid operator
in Texas concluded that adding 3000 MW of wind energy to the state's
grid would reduce carbon dioxide emissions by about 5.5 million tons
per year, sulfur dioxide emissions by 4000 tons per year, and nitrous
oxide emissions by about 2000 tons per year; 3) the 30 MW Kaheawa
wind plant in Hawaii offsets power from oil-burning power plants,
reducing oil imports by almost 10 million gallons per year.
DEIS Response 12.7 Electrical energy generated by the Project will be supplied to the
power grid at transmission level voltages. Once it enters the grid, it
will be available to local distribution companies for distribution to
their local customers.
DEIS Response 14.9 Please see response to Comment 12b.
DEIS Response 52.1 The Project will have financial benefits to the Town of Cape Vincent
in the form of PILOT payments, job creation, lease payments to
landowners participating in the Project and visual mitigation funding
for local projects. Comments regarding the overall cost of the Project
and estimated cost per kilowatt hour are comments that address issues
outside the scope of this EIS. All town residents have the potential to
benefit from job creation, PILOT payments and visual mitigation
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funding for local projects. It is anticipated PILOT payments will be

made to the town for twenty years.
DEIS Response 75.6 The Project will seek a PILOT agreement with the Jefferson County
IDA. That agreement has not yet been negotiated.
DEIS Response 79.4 Wind power generates no emissions, and displaces carbon dioxide and
other greenhouse gases that would otherwise be emitted by fossil fuel-
fired electric generation.
DEIS Response 107.2 SLW agrees that the participating landowners benefit from the wind
facility. However, through the PILOT program, the County, Towns,
and school districts also will benefit. In addition, wind energy is a
clean form of energy generation and benefits all by not placing any
unwanted emissions into the air, like fossil generation does.
DEIS Response 112.2 Please see Figure 2-2 of the SDEIS.
DEIS Response 112.3 Comments by N.Y. State DEC, USFWS, NY Public Service
Commission, NY Ag and Markets, and NW State Historic
Preservation Office that have been submitted during the public
comment period ending 6/15/2007 were addressed in the SDEIS that
was accepted for public review by the Planning Board on March 25th,
2009.
DEIS Response 112.4 Please see Figure 2-1 of the SDEIS for location of above and below
ground transmission and distribution lines. Please see Appendix A-7 of
the SDEIS for correspondence with BP.
DEIS Response 112.7 Please see Appendix L of the SDEIS.
DEIS Response 112.10 Please see Appendix B of the SDEIS.
DEIS Response 112.11 Please see Appendix C-5 of the FEIS and Appendix G of the SDEIS.
DEIS Response 113.12b This comment addresses issues outside the scope of this EIS.
SDEIS Response 15.10 The SDEIS has been reviewed by agencies at the local, state and
federal level. All comments by the agencies and the public are
addressed in this final EIS. A moratorium on development is not
necessary as the proposed project is currently assessing the
environmental impacts.
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the EIS.
SDEIS Response 20.5 Due to environmental and engineering constraints, the size of the
Project has been reduced from the originally proposed 96 turbines in
the DEIS to the 51 turbines proposed in the FEIS.
SDEIS Response 25.57 Please see response to Comment 1-3.
SDEIS Response 25.67 Comment noted. Please see the response to Comment 25.66.
SDEIS Response 25.68 Yes. The project will inject up to an additional 79.5 MW of new
electrical power into the transmission system in the County.
SDEIS Response 73.31 Approximately 200 temporary jobs will be created during construction
and up to 8 permanent jobs will be created during operations.
SDEIS Response 73.49 Wind resource data show that Cape Vincent has an adequate resource
for wind power project(s).
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SDEIS Response 73.63 The nameplate capacity of the Project is 79.5 megawatts.
SDEIS Response 73.64 The project will not produce air or water pollution while operating.
RECREATION
DEIS Response 99.4 SLW evaluated the scenic impact of the wind turbines from multiples
sites in the Visual Resources Assessments included as appendices to
the DEIS and SDEIS. These sites were chosen through coordination
with the Towns and other agencies.
Regarding hunting and snowmobiling, both activities can continue
during operation of the Project. The turbines and other Project
components have a small development footprint compared to the
overall Project Area. Snowmobiling in the area will not be restricted
during Project operation. SLW would be pleased to reach out to local
snowmobile groups to educate snowmobilers about safety measures
associated with wind turbines. Construction impacts are expected to be
minor and short-term for the duration of the construction period, which
will mainly occur outside of the winter snow season.
SAFETY AND SECURITY

DEIS Response 4.46 Please see Section 2.5.1 of the SDEIS for a description of security
measures for wind turbines. Please see Section 2.5.6 of the SDEIS for
a description of the security measures for the substation and
interconnection facilities. The project will participate in Dig Safely
New York.
DEIS Response 13.1 An assessment of health issues and the potential for wind energy
projects to statistically impact health of nearby residents was
performed by a group of experts in 2009. The evidence and mechanics
of noise were thoroughly investigated, and the resulting conclusion
indicated that there is no documented evidence of health-related
impacts by wind turbines in the short-term or long-term, if reasonable
setback distances are maintained.
DEIS Response 14.6 Section 3.13 of the SDEIS provided further information regarding the
risk of ice shedding and mitigation measures. The use of setbacks in
accordance with local requirements from roads and property lines and
public control measures will minimize the already low public safety
risk of ice shed. Because of these setback distances to structures and
public roads, the risks of ice throw are minimal in the Project Area.
Wind turbine manufacturers have developed engineering controls that
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help to minimize safety risks associated with ice build up on wind

turbine components. These controls include the following:
x Detection of ice by a nacelle mounted sensor;
x Detection of an imbalance caused by ice formation on the blades
by the shaft vibration sensor; and
x Detection of measured wind speed below cut-in due to
anemometer icing.
x Such effects of ice accumulation can be sensed by the turbine's
computer (SCADA system) and result in the turbine being shut
down until the most of the ice melts, at which time the turbine is
manually restarted by the operator. As an additional backup, ice
detectors would be installed at previously determined locations to
notify maintenance personnel of icing conditions, which would
allow for remote switch off of the turbine by the operator.
DEIS Response 38.2 As discussed in Section 3.13 of the SDEIS, turbine transformer
cabinets will be locked. A road gate will limit public access to the
substation. Alarms and warning signage will be installed.
DEIS Response 43.5 An Emergency Response Plan (ERP) has been developed for the
Project in coordination with the Cape Vincent Fire Department and
was included as Appendix B to the SDEIS.
DEIS Response 45.1 Please see response to Comment 62.1 for response regarding Wind
Turbine Syndrome. Please see responses to Comments 38.2 and 75.4
regarding safety and emergency response planning.
DEIS Response 62.1 Low frequency noise, as it is referenced here, has many sources, such
as machinery and transportation. This type of sound is generally
always present as an element of background noise. Low frequency
noise also dissipates quickly over distance. A recent white paper
developed by a group of doctors and acoustic scientists explains that
“Infrasound at a frequency of 20 Hz (the upper limit of infrasound) is
not detectable at levels lower than 79 dB. Infrasound at 145 dB at 20
Hz and at 165 dB at 2 Hz can stimulate the auditory system and cause
severe pain. These noise levels are substantially higher than any noise
generated by wind turbines. The U.S. Food and Drug Administration
(FDA) has approved the use of infrasound for therapeutic massage at
70 dB in the 8 to 14 Hz range. In light of the FDA approval for this
type of therapeutic use of infrasound, it is reasonable to conclude that
exposure to infrasound in the 70 dB range is safe. According to a
report of the National Research Council (NRC), low frequency sound
is a concern for older wind turbines but not the modern type.” SLW
has been diligent about siting turbines with setbacks to homes, in order
to minimize issues related to sound. In addition, please see the revised
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Noise Modeling Assessment in Appendix C-4 of the FEIS for a

complete description and illustration of sound impacts.
DEIS Response 67.1 Please see response to 14.6
DEIS Response 72.1 Please see response to Comment 1.12
DEIS Response 75.4 An Emergency Response Plan (ERP) has been developed for the
Project in coordination with the Cape Vincent Fire Department and
was included as Appendix B to the SDEIS. The ERP provides details
regarding fire hazards from various Project components, including the
wind turbines, the O&M building, the collection substation, and point
of interconnection substation. The ERP also notes that material safety
data sheets (MSDS) will be obtained and stored in the construction
field office and in the O&M building. As stated in Section 3.13.3.2.4
of the SDEIS, prior to the commencement of construction, SLW will
review the ERP in cooperation with local fire departments and discuss
training and implementation of the ERP.
Town of Cape Vincent Planning Board. Please also see response to
comment 62.1.
DEIS Response 89.1 The provided article refers to studies which correlate risks of leukemia
in children who live near (less than 600 meters) high-voltage lines
(275kV to 400kV). As the referenced paper suggests potential risks
associated with electromagnetic fields (EMF) are likely related to the
voltage transmitted in the lines, distance from the power line and
amount of time spent in the EMF. The transmission lines associated
with the Project are of lower voltage (115kV) then those studied in the
referenced report.
There are no known health risks that have been conclusively
demonstrated to be caused by living near high-voltage power lines. In
1999 the National Academy of Sciences, National Research Council
(NRC) published a review of the evidence from the EMF research
program concluding that the current body of evidence does not show
that exposure to EMFs presents a human health hazard. In addition,
health affects, including cancer, associated with low-voltage
electromagnetic fields around power lines have not been scientifically
substantiated.
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DEIS Response 99.6 SLW's parent company, Acciona Energy, has constructed wind farms
in 13 countries globally and is the second largest developer in the
world. In the U.S., Acciona has constructed wind farms in North
Dakota, South Dakota, Illinois, and Oklahoma, and those projects are
currently operating in a safe and efficient manner.
DEIS Response 110.3 Among published scientific literature, this description of the two
families is known as a case series, which are of virtually no value in
understanding potential causal associations between exposure to a
potential hazard (i.e., low frequency sound) and a potential health
effect (i.e., vibroacoustic disease). Case reports have value but
primarily in generating hypotheses to test in other studies such as large
groups of people or in case control studies. The latter type of study can
systematically evaluate people with pericardial thickening who live
near wind turbines in comparison to people with pericardial thickening
who do not live near wind turbines. Case reports need to be confirmed
in larger studies, most notably cohort studies and case-control studies,
before definitive cause and effect assertions can be drawn. The reports
of the two families do not provide persuasive scientific evidence of a
link between wind turbine sound and pericardial thickening. Wind
turbines produce low levels of infrasound and low frequency sound,
yet there is no credible scientific evidence that these levels are
harmful. If the human body is affected by low, sub-threshold sound
levels, a unique and not yet discovered receptor mechanism of
extraordinary sensitivity to sound is necessary—a mechanism which
can distinguish between the normal, relatively high-level “sound”
inherent in the human body and excitation by external, low-level
sound. Essential epidemiological studies of the potential effects of
exposure at low sound levels at low frequencies have not been
conducted. Until the fuzziness is clarified, and a receptor mechanism
revealed, no reliance can be placed on the case reports that the low
levels of infrasound and low frequency sound are a cause of
vibroacoustic disease. The attribution of dangerous properties to low
levels of infrasound continues unproven, as it has been for the past 40
years. No foundation has been demonstrated for the new hypothesis
that exposure to sub-threshold, low levels of infrasound will lead to
vibroacoustic disease. Indeed, human evolution has occurred in the
presence of natural infrasound.
SDEIS Response 2.2 Construction methods for the transmission line crossing will not
require equipment to be in the Chaumont River (e.g., no structures
within 50 feet of banks). Description of the construction process,
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including methods for ensuring the safety and health of workers, and
the public, is set forth in Section 2.2.5 of the FEIS.
SDEIS Response 4.6 Vegetation around the substation consists mainly of scrub brush. There
are no danger trees outside of the proposed cleared area that will need
to be removed.
SDEIS Response 4.12 St. Lawrence Windpower, LLC will conform to the requirements for
protection of underground facilities contained in Public Service Law
§119-b, as implemented by 16 NYCRR Part 753 and will comply with
pole numbering and marking requirements, as implemented by 16
NYCRR Part 217.
SDEIS Response 4.14 All access roads to turbines will have gates where they intersect public
roads and all turbines will be locked. Substations will be fenced to
prevent access.
SDEIS Response 4.19 A draft Emergency Response Plan was developed and submitted in the
SDEIS, Appendix B.
SDEIS Response 17.9 The Planning Board is not aware of any scientifically peer-reviewed
information demonstrating a link between wind turbines and negative
health effects. Thousands of people around the world are living near
wind farms without ill effects. SLW would be amenable to addressing
the potential for specific health-related conditions to occur; however,
the commenter did not identify any specific conditions of concern to
her.
SDEIS Response 18.2 This comment offers an unsubstantiated opinion which is not
supported by the objective impact analyses in the EIS.
SDEIS Response 25.13 There is no scientific reason to use a more recent study; the Morgan
study is still valid, and ice shedding is not a topic that is continually
changing.
SDEIS Response 25.59 Turbine access doors will remain locked at all times, unless a
Technician is servicing the structure. Turbines are located on private
property, and all laws governing private property are still applicable.
SDEIS Response 25.73 The requested letter is in the Appendix. In the letter, see number 11.
SDEIS Response 32.1 In response to concerns that the sounds emitted from wind turbines
cause adverse health consequences, the American and Canadian Wind
Energy Associations (AWEA and CanWEA) established a scientific
advisory panel in early 2009 to conduct a review of current literature
available on the issue of perceived health effects of wind turbines.
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As part of this study, the “panel also considered the quality of

epidemiologic evidence required to prove harm. In epidemiology,
initial case reports and uncontrolled observations of disease
associations need to be confirmed through controlled studies with
case-control or cohort methodology before they can be accepted as
reflective of casual connections between wind turbine sound and
health effects. In the area of wind turbine health effects, no case-
control or cohort studies have been conducted as of this date.
Accordingly, allegations of adverse health effects from wind turbines
are as yet unproven. Panel members agree that the number and
uncontrolled nature of existing case reports of adverse health effects
alleged to be associated with wind turbines are insufficient to advocate
for funding further studies.” The panel concluded that:
x “Sound from wind turbines does not pose a risk of hearing loss or
any other adverse health effect in humans.
x Subaudible, low frequency sound and infrasound from wind
turbines do not present a risk to human health.
x Some people may be annoyed at the presence of sound from wind
turbines. Annoyance is not a pathological entity.
x A major cause of concern about wind turbine sound is its
fluctuating nature. Some may find this sound annoying, a reaction
that depends primarily on personal characteristics as opposed to
the intensity of the sound level.”
SDEIS Response 32.2 Benign Positional Vertigo is triggered by small particles which
become dislodged within the fluid of the inner ear. These free floating
particles activate fine, hair-like sensors within the semicircular canals
of the inner ear and trigger false signals that your head is still moving
even after it stops resulting in dizziness or vertigo. Unfortunately,
increased setbacks will not remedy this inner ear disorder.
SDEIS Response 34.1 The Planning Board and its consultants are not aware of any scientific
data that links wind turbines to fibromyalgia or to Grave's Disease.
SDEIS Response 40.1 While specific ice shed studies have not been conducted in the Project
area the trajectory that shed ice would follow is related to the ice mass
wind speed (blade speed) and position of the blade at the time the ice
is shed. While shed ice can travel up to several hundred meters in the
most extreme cases, the setbacks from roadways (200 meters) and
non-participating residences (>400 meters) would minimize the chance
of encounter with shed ice. Of the ice shed incidences summarized in
the referenced webpage provided by the commenter, most were in the
range of 70 to 85 meters from the turbine and the farthest distance
reported for thrown ice was 130 meters.
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SDEIS Response 54.6 Please see response to Comment 54.5 Standard electric wiring
practices are adequate to prevent stray voltage from occurring. Design
and engineering analysis will identify any potential risks and
mitigations prior to construction.
SDEIS Response 56.1 According to the British Epilepsy Association, approximately five
percent of individuals with epilepsy have sensitivity to light, and most
people with photosensitive epilepsy are sensitive to flickering between
16-25 hertz, although some people may be sensitive to rates as low as
3 hertz and as high as 60 hertz (British Epilepsy Association, 2007).
Modern commercial scale wind turbines rotate slowly (between 0.3
and 1.0 hertz), well below the range which may induce photosensitive
epilepsy. Regarding wind power projects, the British Epilepsy
Association (2007) further states that there is no evidence that wind
turbines can trigger seizures, and are considered harmless. The
primary concern with shadow flicker is the annoyance it could cause
for adjacent home owners.
SDEIS Response 56.2 The proposed project meets or exceeds all setbacks requested by the
health effects.
health effects. Please see response to Comment 32.1.
SDEIS Response 73.6 Historically, shadow flicker impacts do not cause significant impacts
until the threshold of over 30 hours/year is met. The shadow flicker
analysis that SLW had performed (Appendix C-10) indicates no
residents will exceed the threshold of 30 hours/year. In fact, 151 out
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of the total 177 receptors will receive 10 hours or less of anticipated

shadow flicker per year.
SDEIS Response 73.76 Historically, shadow flicker impacts do not cause significant impacts
until the threshold of over 30 hours/year is met. The shadow flicker
analysis that SLW had performed (Appendix C-10) indicates no
residents will exceed the threshold of 30 hours/year. In fact, 151 out
of the total 177 receptors will receive 10 hours or less of anticipated
shadow flicker per year. The overall results of the model evaluating
compliance with the State guideline show the area inside of the 42
dBA sound contour line represents the region where sound from the
Project may result in an adverse impact. This plot indicates that the
overwhelming majority of non-participating residences will be subject
to sound level increases of less than 6 dBA, and in most cases, much
less than 6 dBA. There are only three houses just inside of the nominal
42 dBA threshold.
SDEIS Response 73.80 Please see Appendix C-6 for the Residential Drinking Water and
Mitigation Plan.
SEQR PROCESS
DEIS Response 19.3 SLW developed a SDEIS and this FEIS to complete the SEQR process
to its fullest extent. These documents provide a full and complete
adequate assessment of environmental issues and impacts for the SLW
Project.
DEIS Response 71.1 The Board has complied with all applicable public notice and
comment requirements under SEQRA, including providing an
extended period for comments on the SDEIS.
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DEIS Response 74.1 Comment noted. Please see also response to Comments 71.1.
DEIS Response 75.1 The third alternative referenced is that the lead agency, based on
comments received from involved agencies or the public, may require
a supplemental EIS (SDEIS) prior to preparing a final EIS. SLW has
developed and submitted that SDEIS.
DEIS Response 79.3 Please see response to Comments 71.1.
SDEIS Response 4.10 a) Table 2-3 in Section 2.9 of the SDEIS provide a list of the permits,
and approvals Acciona will have to obtain to construct, operate, and
maintain the wind turbines, electric collection system, substation,
transmission line, interconnection, and associated buildings and
structures. Table 1-1 in Section 1.2 of the FEIS provides permissions
Acciona will seek and addresses additional permits and approvals
likely required to retire the Project components. b) All permits will be
obtained prior to commencement of construction.
SDEIS Response 7.1 Comment noted. Please see response to Comments 5.1 through 5.5,
and 6.1 through 6.3 for response to comments provided by John
Bonafide of the NYSOPRHP regarding cultural and historic resources.
SDEIS Response 11.1 Please see responses to DEIS Comments 21.1 through 22.2.
SDEIS Response 11.16 SLW is not relying on post-construction monitoring to assess impacts,
the need for mitigation, or currently practicable approaches to
mitigation, but rather as a tool for enhancing potential mitigation, if
the need arises, and as a tool for obtaining data that the agencies and
the wind industry may find helpful in future planning of wind farms.
SLW believes the assessment of impacts in the SDEIS and additional
information provided in the FEIS fully satisfies the applicable
requirements for an EIS.
SDEIS Response 17.11 Please see response to Comment 14.4. The studies undertaken, to
date, have been adequate to make thorough assessments of potential
impacts.
SDEIS Response 17.13 The leases are arm’s length agreements entered into between SLW and
willing landowners. If any landowner is uncomfortable with the terms,
the landowner does not have to enter into a lease. The content of the
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leases, and the interpretation and application of the lease terms, are not
within the scope of SEQRA or the jurisdiction of the Planning Board.
SDEIS Response 19.1 The DEIS and SDEIS met all applicable standards of completeness for
public review. The Planning Board has assessed impacts and has
required implementation of the reasonably practicable mitigation for
those impacts, where necessary. The DEIS and SDEIS public
comment processes provided the opportunity under SEQRA for public
involvement in assessing the impacts of the project.
SDEIS Response 25.60 Each section, if based on assumptions and not actual project-
performed studies, describes how the analysis of that section was
derived.
SDEIS Response 25.61 The Town of Cape Vincent does not currently have an Energy
Facilities Ordinance that regulates wind farms.
SDEIS Response 39.1 During, the 2-year period between the DEIS and the DEIS, SLW
revised the Project in response to comments on the DEIS and
environmental and engineering constraints. The SDEIS submittal and
comment period was conducted in accordance with SEQRA
regulations and guidelines. In fact, the 60-day period provided for
comments on the DEIS exceeded the requirements of SEQRA.
SDEIS Response 43.1 This is not the case. An amended Complaint Resolution Procedure is
provided as Appendix C-11 to the FEIS.
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SDEIS Response 45.1 The comment does not identify the basis for the claimed conflicts of
interest. No such conflicts exist under either Article 18 f the General
Municipal Law or the Attorney General’s Wind Energy Code of
Conduct. The Planning Board is Lead Agency because it is common
practice around the state for key local permitting agencies act as Lead
Agencies in the SEQR review of wind projects.
SDEIS Response 47.2 Please see responses to Comments 11.8 and 17.20.
SDEIS Response 54.1 A 60-day public comment period was provided for the SDEIS.
SDEIS Response 54.2 Actually, 3 transmission line alternatives were discussed in the SDEIS:
above ground placement in the railroad bed ROW; above ground
placement adjacent to the railroad bed ROW; and underground
placement of the transmission line within sensitive resources. These 3
alternatives are discussed between pages 7-12 and 7-16 of the SDEIS.
SDEIS Response 72.2 The project has completed a Draft Environmental Impact Statement
and a Supplemental Draft Environmental Impact Statement. Both
documents were made available for public comment for periods
exceeding the required minimum periods.
SDEIS Response 73.23 The Cape Vincent Wind Farm was, in fact, included in the cumulative
impacts section of the SDEIS.
SDEIS Response 73.46 SLW and the Planning Board have complied, and will continue to
comply with all applicable federal, state, and local regulations and
laws.
SDEIS Response 73.82 SLW has been communicating with NYSDEC regarding relocation of
turbines to avoid state endangered species critical habitat. In addition,
SLW has met most recently with NYS Department of Agriculture and
Markets to review the layout and how it affects farmland. In addition,
SLW is poised to meet with all other agencies that request such a
meeting.
SOCIOECONOMICS
DEIS Response 11.7 An expanded discussion of potential effects on property values was
included in Section 3.11 of the SDEIS.
Please see SDEIS response to Comments 15.6, 18.3, 20.16, and 25.15.
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DEIS Response 19.8 The Alternatives Section of the SDEIS (Section 7) included
explanations of costs and benefits relating to a range of alternatives to
the proposed Project.
DEIS Response 26.2 Updated tax levy data was provided in the SDEIS, Table 3-30.
Additionally, budget information from the New York State Office of
the State Controller (2006), including revenues, expenditures, and
indebtedness, was provided in Table 3-31 of the SDEIS for Jefferson
County, the Towns of Cape Vincent and Lyme, the Villages of Cape
Vincent and Chaumont, and the Thousand Island and Lyme School
Districts. As noted in the SDEIS, the Project will have a beneficial
impact on municipal budgets and taxes because the taxing jurisdictions
will receive additional revenue from the Project in the form of PILOT
and road use agreements. Additionally, the costs associated with the
potential impact of Project construction on local roads will be the
responsibility of the Applicant.
DEIS Response 26.4 A Job and Economic Development Impact Model was run for the
Project, and the results are set forth in the Socioeconomic section of
the SDEIS.
DEIS Response 36.1 The New York portion of the St. Lawrence River from Tibbett’s Point
near Cape Vincent to approximately Morristown, known as the
Thousand Islands Region, is a popular fishing area. Access to this
region is primarily via I-81 and Route 12E. While the Project will be
constructed during fishing season, the delivery route, selected in
coordination with the New York State Department of Transportation
Region 7, will minimize impacts to traffic on the local roads and in
surrounding communities. Specifically, the route has been designed to
reach the largest number of wind turbine locations while minimizing
potential impacts and potential disruption to tourism by avoiding route
12E. There are also several exits from I-81 to local roads providing
access to the region, many north of the proposed exit (48) for the
delivery of Project components. Careful selection of the proposed
delivery route will minimize potential access conflicts with fisherman
and other recreational users. Please see also response to Comment
43.8.
DEIS Response 43.8 Based on available information, the Project is not expected to have a
negative effect on tourism. A 2002 study conducted for the Scottish
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Renewables Forum and the British Wind Energy Association

(available at http://www.bwea.com/pdf/mori.pdf) investigated the
effect of wind farms on existing tourism at scenic areas. The
researchers surveyed 307 tourists in the Argyll region of Scotland,
noted for its scenic beauty and landscape, and concluded that "the
wind farms are not seen as having a detrimental effect on their visit
and would not deter tourists from visiting the area in the future."
Please see response to Comment 11.7 for more information on
property values. Section 3.8 of the SDEIS also provides further
discussion on scenic impacts.
DEIS Response 43.10 The effective capacity, or capacity factor, measures the productivity of
a power facility. It is equal to the actual amount of power produced
over time divided by the power that would have been produced if the
facility (in this case a turbine) operated at maximum output 100
percent of the time. Modern utility-scale wind turbines generally
operate 65 percent to 90 percent of the time, but not at full capacity
since they rely on wind as a "fuel" and commonly have an effective
capacity between 25 percent and 40 percent. For comparison,
conventional power plants have an effective capacity between 40
percent and 80 percent.
SDEIS Response 15.6 Section 3.11.3 of the SDEIS identifies that there will not be a
significant adverse impact on housing. In addition, to the studies
identified in Section 3.11.2.4 and discussed in Section 4.1.11.2, a
recent study (Hoen, 2009), concluded that:
the view of a nearby wind facility impacts sales prices in a significant
and consistent manner
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been broadly and measurably affected by the presence of those wind

facilities.
Although the analysis cannot dismiss the possibility that individual
homes have been or could be negatively impacted, the Berkeley Lab
research finds that if these impacts do exist in the sample of homes
analyzed, they are either too small and/or too infrequent to result in
any widespread, statistically observable effect.
SDEIS Response 17.3 No loss of fishing revenues is anticipated as wind energy projects
typically attract tourists rather than discourage them.
SDEIS Response 18.3 There is no sufficient data to suggest that wind farms detract from the
value of property. In 2003, the Renewable Energy Policy Project
(REPP) conducted a study of over 25,000 records of property sales and
found no statistical evidence to suggest that wind farms have negative
effects on property values. Another quantitative study was conducted
in 2006 of property values surrounding the Fenner Wind Farm in
Madison County, NY (Hoen, 2006). The 2006 Hoen study showed
that there is no statistically significant relationship between proximity
to, or visibility of, the wind farm, and the sale price of homes in the
area. [Hoen has made some presentations of the interim findings of his
new study, which should be used here if we can find them]. A number
of wind energy projects are in operation in New York; the result
suggested by the commenter has not arisen in the jurisdictions that
host those projects.
In addition another study in 2009 (Hoen, 2009) shows that:
the view of a nearby wind facility impacts sales prices in a significant
and consistent manner
been broadly and measurably affected by the presence of those wind
facilities.
SDEIS Response 20.1 The Jefferson County Industrial Development Authority is currently
working on a uniform tax exempt policy for wind power projects in
Jefferson County.
SDEIS Response 20.4 The Socioeconomics section of the SDEIS was developed from the
results of statistically-based studies and reports, as referenced and
indicated in that section.
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SDEIS Response 25.15 In addition, to the studies identified in Section 3.11.2.4 and discussed
in Section 4.1.11.2, a recent study (Hoen, 2009), concluded that:
the view of a nearby wind facility impacts sales prices in a
significant and consistent manner
been broadly and measurably affected by the presence of those
wind facilities.
Although the analysis cannot dismiss the possibility that individual
homes have been or could be negatively impacted, the Berkeley Lab
research finds that if these impacts do exist in the sample of homes
analyzed, they are either too small and/or too infrequent to result in
any widespread, statistically observable effect. See also response to
Comment 18.3
SDEIS Response 25.65 It is not true that federal tax incentives encourage frequent project ales.
To the contrary, the major federal incentives, the Production Tax
Credit and the Investment Tax Credit typically require initial holding
periods in the 5 -10 year range. Also, please see the response to
comment --.
SDEIS Response 38.1 Comment noted. Please see response to Comment 15.6
information demonstrating a link between wind turbines and a
decrease in tourism.
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SDEIS Response 63.2 The first comment is beyond the scope of this EIS. There is not
expected to be a negative impact to tourism from the project.
TELECOMMUNICATIONS
SDEIS Response 4.15 Wind turbines can potentially interfere with communication systems
that use electromagnetic waves as the transmission medium, such as
television, radio or microwave links. Effects depend on the turbine
design (size), location and blade motion. Potential disruption of
electromagnetic signals, occur when the turbine or it components
either block or reflect an electromagnetic signal. Blockage is caused
by the physical presence of the turbines between the television station
and the reception points. Reflection of the a signal results in ghosting
which is caused by multipath interference when a broadcast signal
reflects off of the turbine or its components and arrives at a television
receiver delayed in time from the signal that arrives un-reflected.
Microwave transmissions: Careful turbine positioning during project
design has enabled the avoidance of any microwave pathways.
Comsearch identified three (3) microwave paths that intersect the
Project Area. None of these paths were identified to have a potential
conflict with any of the planned turbine locations; therefore the Project
would not impact microwave communication systems.
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Television: The FCC mandated switch of analog television signals to

digital signals would eliminate turbine-related interference problems
as digital signals are not subject to interference from intervening
structures (NWCC, 2005); therefore the Project have no impacts to
television transmissions.
AM/FM/SW radio: The Federal Communications Commission (FCC)
requires that studies be conducted to determine if a proposed
development will affect existing AM radio broadcast stations within
0.6 mile of a non-directional broadcast station and/or within 1.9 miles
of a directional broadcast station. All proposed Project wind turbines
are located greater than 1.5 miles from a non-directional AM broadcast
station and/or 4.5 miles from a directional AM broadcast station. The
NTIA did not identify Project-related concerns related to signal
blockage for IRAC radio frequency transmissions. The Project will no
interfere with existing AM radio transmissions.
Cell phones: Cellular radio is designed to operate in a mobile
environment, and cell phone reception is not affected by line-of-sight
disruptions, as a result it is comparatively insensitive to EMI effects
from wind turbines. There is no documented evidence that wind
turbines or towers interfere with cellular phone service or coverage. In
areas of the United States with very large numbers of turbines and high
densities of turbines problems have not been reported with cell phone
service. In addition, cell phone antennae are being installed on the
same towers as wind turbine generators in some European countries.
Radar: The FCC determined the following: the nearest public airport
is 13.27 nautical miles southwest of the Project center point and the
Project will not impact airport operation; the Project will have no
impact on Minimum Vectoring Altitude on En-Route Low Altitude
Airways; the Project is outside military operations areas or restricted
areas; the Project is unlikely to impact Air Defense or Homeland
Security radars; and no impact to Weather Surveillance Radar -1988
Doppler weather radar operations.
GPS and LORAN: Wind turbines have the potential to reduce GPS
and LORAN signals at the site however, they would not prevent the
use of these units at the site. A 1984 University of Michigan study
indicated that the effect on a LORAN receiver is not significant
beyond 750 feet.
SDEIS Response 10.1 The Comsearch analysis of off-air television reception was completed
in 2006 and was updated with another study in 2009. While, the FCC
mandated switch of analog television signals to digital signals would
not totally eliminate turbine-related interference problems, the Project
should have minimal impacts to television transmissions as digital
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signals are less susceptible to interference from intervening structures.

Please see Appendix C-16.
SDEIS Response 25.26 The FCC’s mandated transition all off-air television broadcasts from
analog signals to digital signals by January 1, 2009 would largely
eliminate turbine related interference problems as digital signals are
less subject to interference from intervening structures (NWCC, 2005).
Since the Project will enter operation after 2009, it will have minimal
impact on existing off-air television stations. No mitigation measures
should be necessary.
analog signals to digital signals by January 1, 2009 would largely
eliminate turbine related interference problems as digital signals are
less subject to interference from intervening structures (NWCC, 2005).
Since the Project will enter operation after 2009, it will have minimal
impact on existing off-air television stations. No mitigation measures
should be necessary. Handling of complaints regarding interference
with television reception will addressed through the complaint
resolution protocol established in the Complaint Process Plan
(provided in Appendix M of the SDEIS). Potential remedies include:
x Re-orientation of existing aerials to an alternative transmitter
x Supply of directional aerials to mildly affected properties
x Switch to supply of cable or satellite television.
SLW will assist in defraying the initial cost of the selected remedy
e.g., labor cost to re-orient existing aerials to an alternative transmitter,
cost of directional aerials or activation fee for switch to supply of cable
or satellite television. Any monthly fees will be the responsibility of
the party selecting this option.
analog signals to digital signals by January 1, 2009 would eliminate
turbine related interference problems as digital signals are not subject
to interference from intervening structures (NWCC, 2005). Since the
Project will enter operation after 2009, it will not impact existing off-
air television stations. The Project will have no impact on microwave
communication systems. The Project will not impact existing AM
radio transmissions. Any concerns over post-construction signal
quality will be handled through the complaint resolution process.
SDEIS Response 73.72 The project will have no impact on microwave communication
systems. The project will not impact FM or AM radio transmissions.
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The FCC’s mandated transition all off-air television broadcasts from

analog signals to digital signals by January 1, 2009 would eliminate
turbine related interference problems as digital signals are not subject
to interference from intervening structures (NWCC, 2005). Since the
Project will enter operation after 2009, it will not impact existing off-
air television stations. No mitigation measures will be necessary.
TRAFFIC AND TRANSPORTATION

DEIS Response 4.26 Primary and secondary construction transportation routes have been
designed to reduce traffic impacts to Route 12E. Only a short potion of
Route 12E (between Favret Road and Deerlick Road) will be used
during construction. Please see Appendix C-5 of the FEIS.
DEIS Response 4.27 Visual simulations of the Project from the Route 12E, the Sea Way
Trail, were completed from the following locations; Millen Bay,
Poplar Tree Bay and County Road 8. These simulations are included in
Appendix I of the SDEIS.
DEIS Response 4.28 Please see Appendix C-5 of the FEIS.
DEIS Response 4.29 Please see Appendix C-5 of the FEIS.
DEIS Response 21.4 This comment has been addressed in Section 3.4 of the SDEIS. In
addition, a Route Evaluation Study has been completed and is included
DEIS Response 43.2 A strategy for road restoration has been included in Section 3.4.3 of
the SDEIS. Basically this strategy includes the following: the
Applicant will repair damage done to roads affected by construction
within the approved primary route, at no expense to the towns, county,
or state. Prior to construction the specific terms of road use and
reconstruction will be negotiated and agreed upon in a Road
Agreement's) between the Applicant and road owner's). Prior to
construction, the Applicant will video document the existing roadways
to verify the pre-construction roadway conditions. Upon completion of
the construction activities, the Applicant will return all roadways to
their preconstruction conditions, at a minimum, and video-document
restored conditions. More information on road improvements and
transportation issues can be found in Appendix C-5 of the FEIS.
DEIS Response 45.2 These comments have been addressed in Section 3.4 of the SDEIS. In
addition, a Route Evaluation Study has been completed and is included
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SDEIS Response 3.9 The Project will work with the Town, its Highway Department, and
the NYSDOT to develop a detailed Transportation Plan prior to
construction. The Plan will specify descriptions of these items listed.
A route evaluation study has been completed and is included in
Appendix C-5.
SDEIS Response 3.10 Please see response to Comment 3.9. Financial assurances will be
established in Site Plan Review as required.
SDEIS Response 25.10 An initial Transportation Study has been included as Appendix C-5 to
the FEIS.
SDEIS Response 25.12 Impacts to local roads are expected to last the duration of construction,
6 to 9 months. Monetary security in the form of a bond, letter of credit
or other acceptable surety will be provided to the Town to ensure that
after impacts to roadways occur, roadways may be repaired / the roads
may be rebuilt to pre-use conditions. A road use agreement between
St. Lawrence and the Town will set forth the terms of the security.
UTILITIES AND COMMUNITY SERVICES

DEIS Response 39.1 The impacts of the Project on the transmission system were analyzed
by the NYISO in the System Reliability Impact Study for the Project,
and in the annual transmission reliability assessment for the 2008
Class Year.
SDEIS Response 4.2 All existing utility services will be identified in construction and
operation areas. Construction and operation plans will be designed to
prevent an interference or interruption to existing utility services. SLW
will join Dig Safely New York UFPO program prior to the start of
construction to identify any potential underground facilities. Potential
impacts to underground facilities that may be affected by road
widening will be addressed in the Transportation Study Plan (see
Appendix C-5).
SDEIS Response 4.4 Above-ground poles will include pole-marking for safe and efficient
identification.
SDEIS Response 4.13 Acciona requires all work is performed to prudently design, engineer,
test, operate and maintain equipment safely, efficiently and
economically in accordance with the requirements of applicable law,
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the National Electric Safety Code, the National Electric Code, the
North American Electric Reliability Council’s standards and
procedures and any applicable equipment vendor manuals and
specifications. The design, location and construction controls to avoid
interference with existing utility transmission and distribution systems
will be detailed in the site plan review. The detailed locations and
specific design separations of the proposed facilities from existing
electric, gas, and communications infrastructure will also be detailed
in the site plan review.
SDEIS Response 4.18 There are currently no plans for sharing above ground facilities with
other utilities.
SDEIS Response 4.20 A Complaint Resolution Plan was submitted in the SDEIS, Appendix
M. The revised Plan is located in Appendix C-11 of this document.
SDEIS Response 54.7 First, the Cape Vincent Town Supervisor will ask if any member of the
Cape Vincent Town Board would like to volunteer to be Complaint
Resolution Board Town Officer. If no member of the Cape Vincent
Town Board volunteers, the Cape Vincent Town Supervisor will
appoint a Town of Cape Vincent representative to the Complaint
Resolution Board.
VISUAL RESOURCES
DEIS Response 1.13b A survey of historic properties eligible for listing on the National
Register of Historic Places that are located within the 5-mile visual
impact study area and that are within the project’s Area of Potential
Effects was completed and the report for the survey submitted to the
New York State Historic Preservation Office (NYSHPO). This survey
included identifying properties that are eligible for the National
Register, but are not yet listed. The information collected from this
survey was presented in the SDEIS in Appendix H.
DEIS Response 1.14 The one-mile and five-mile surveys were completed and included in
Appendix H of the SDEIS.
DEIS Response 1.15 Mitigation measures for any anticipated adverse effects to historic
properties that are listed on or eligible for listing on the National
Register of Historic Places were described in the SDEIS and are
proposed to include screening, restoration of the Cape Vincent Fire
Hall clock tower, burying the electric lines at the Tibbett's Lighthouse,
painting historic buildings at Tibbett's Point, and restoration of the
Market Street Cemetery and two vaults at the Market Street Cemetery.
SLW has been working with the Towns of Cape Vincent and Lyme to
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develop the list of projects, and will share a proposal with NYSHPO as
soon as the proposed Visual Mitigation Plan is complete.
14.
DEIS Response 4.39 Visual simulations of the proposed transmission line are included in
Appendix K of the SDEIS.
DEIS Response 4.43 Please see Appendix I of the SDEIS.
DEIS Response 4.44 Please see Appendix I of the SDEIS.
DEIS Response 7.6 The photo simulations are accurate. They were prepared by an
experienced consultant in accordance with accepted methods.
Appendices I and K of the SDEIS contain additional simulations not
included in the DEIS
DEIS Response 8.1 Visibility of the overhead transmission lines is consistent with other
overhead lines located throughout the Towns. For specific illustration
of the transmission line, please see Appendix K of the SDEIS. The
Ashland Flats Wildlife Management Area will not be significantly
disrupted. In fact, the transmission line will be co-located with an
already-existing railroad bed that is currently abandoned and under
easement with another utility, a waterline. Land values are not
expected to devalued, as evidenced by the 2009 study performed by
the National Renewable Energy Lab. Please see response to comment
11-7 for more information on the study.
DEIS Response 12.8 Updated photo simulations are provided as Appendix I in the SDEIS.
DEIS Response 12.9 Public notice of the DEIS and SDEIS were provided as required by
SEQRA. In addition, media coverage of the Project has been
extensive.
DEIS Response 12.11 A Final Shadow Flicker Assessment for the revised project is provided
DEIS Response 14.16 Shadow flicker frequency is related to the wind turbine’s rotor blade
speed and the number of blades on the rotor. From a health standpoint,
such low frequencies are harmless. For comparison, strobe lights used
in discotheques have frequencies which range from about 3 Hertz (Hz)
to 10 Hz (1 Hz = 1 flash per second). As a result, public concerns that
flickering light from wind turbines can have negative health effects,
such as triggering seizures in people with epilepsy are unfounded.
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DEIS Response 21.10 The project layout has been designed to avoid or minimize the effects
of shadow flicker on residences and unavoidable impacts resulting
from shadow flicker will be mitigated on an individual receptor basis.
All impacts must be satisfactorily addressed prior to the Planning
Board issuing site plan approval.
DEIS Response 23.2 The Project layout complies with setback criteria established the Town
of Cape Vincent Planning Board.
DEIS Response 23.3 The 5-mile radius utilized in the assessment was specified by
NYSHPO.
DEIS Response 38.6 The representation that SLW utilized in assessing visual impacts is
consistent with other wind and development projects in NYS and
accepted standards for conducting such assessments.
DEIS Response 60.1 SLW has evaluated visual impacts in a manner consistent with OPRHP
recommendations, NYSDEC guidance, and accepted standards in the
field. In addition, although all visual impacts cannot be completely
mitigated, SLW will provide screening to certain sites, and offset
impacts in ways as described in response to comment 38-9.
DEIS Response 78.2 Please see SDEIS response to Comments 19.2, 19.3, 20.8, and 25.23.
DEIS Response 97.2 SLW arrive at negotiated settlements for residences adversely affected
by shadow flicker.
DEIS Response 99.7 Additional noise and visual impact analyses were set forth in the
SDEIS and are also set forth in Section 2.2.3 of the FEIS.
DEIS Response 107.1 Please see SDEIS response to Comment 25.63.
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DEIS Response 111.8 Comments noted. Please see response to comment 38.6.
DEIS Response 112.5 Please see Appendix H and I of the SDEIS.
DEIS Response 112.6 Please see Appendix H and I of the SDEIS.
DEIS Response 112.8 Please see Section 2.2.4 of the FEIS.
Town of Cape Vincent Planning Board. Supplementary shadow
flicker assessments were performed by SLW, and were included in the
SDEIS.
DEIS Response 113.2b Comment noted. SLW has taken great measures to avoid and keep
tree/brush removal to an absolute minimum.
DEIS Response 113.7 Additional information on visual impacts was included in the SDEIS
in Section 3.8 and a multitude of photo simulations were included in
Appendices I and K. In addition, a study of the transmission line
visibility was included in Appendix K. These, together with
information in the DEIS, constitute an adequate assessment of visual
impacts.
DEIS Response 113.12a Please see response to Comment 83.2.
SDEIS Response 4.8 Visual impacts to the Seaway Trail-Cape Vincent Bicycle Look trail
are identical in nature to the assessment that was developed and set
forth in the SDEIS for the Project. Visual impact simulations were, in
fact, performed from 4 different vantage points along the Seaway
Trail, and illustrated in the SDEIS. Snapshots from the Cape Vincent
Boat Launch and the Seaway Trail near Millen Bay are located in
Appendix K, Figures 2b and 4b, respectively. In addition, SLW
provided panoramic simulations from the Seaway Trail near Poplar
Tree Bay and County Route 8. Those panoramic series are located in
Appendix K of the SDEIS, Figures 5b-f and 6b-g, respectively.
Wolfe Island, which was commissioned after the submittal of the SLW
SDEIS is a dominant feature on the landscape upon the approach to the
Village of Cape Vincent, and when looking toward the St. Lawrence
River from the Seaway Trail and State Parks When a north-traveling
bicyclist would look to the left along the shore of the St. Lawrence
River on the Seaway Trail, he/she would see the Wolfe Island project;
when looking to the right, would see the St. Lawrence project as it
appears in the simulations. The impact of the St. Lawrence Wind
Farm on park patrons of Cedar Point, Burnham Point, and Long Point
would be comparable, to the current impact of the Wolfe Island
EcoPower Centre wind project. However, the Wolfe Island EcoPower
Centre project has 86 turbines, while the St. Lawrence Wind project
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only has 53 turbines. The management of all three state parks has not
reported a dramatic drop in camping registration due to "adverse visual
impacts" of the Wolfe Island EcoPower Centre. Please see Appendix
C-17.
SDEIS Response 7.2 The impact of the St. Lawrence Wind Farm on park patrons of Cedar
Point, Burnham Point, and Long Point would be comparable to the
current impact of the Wolfe Island EcoPower Centre wind project.
However, the Wolfe Island EcoPower Centre project has 86 turbines,
while the St. Lawrence Wind project only has 53 turbines. The
management of all three state parks has not reported a dramatic drop in
camping registration due to "adverse visual impacts" of the Wolfe
Island EcoPower Centre. In fact, 2009 attendance records from all
three parks show an increase in camping. Please see Appendix C-17.
SDEIS Response 7.3 It is believed the comments are referring to Table 3-25, the Visual
Resource Visibility Summary. According to Table 3-25, the “Actual
View Likely Based on Field Confirmation of Existing Line-of-Sight”
for Cedar Point State Park (Map ID 59.2) will be “substantially
screened by local structures or vegetation.” The photo simulation in
Figure A14b does not show Cedar Point State Park. Within the
campsite area of Cedar Point State Park, all turbines of the Project will
indeed be "substantially screened by local vegetation.” Trees, 30 feet
and taller, line the perimeter of the Cedar Point State Park.
SDEIS Response 7.4 The United States Department of Transportation Federal Aviation
Administration (FAA) requires red flashing aviation obstruction
lighting be placed atop the nacelle of many project turbines to assure
safe flight navigation in the vicinity of the Project. Only 34 illuminated
turbines will be necessary for the current fifty-three turbine project
(see Exhibit 3.8.4). The impact to park patrons would be comparable
to the current nighttime horizon provided by the Wolfe Island
EcoPower Centre wind project. Twenty-four of the Wolfe Island
project’s eighty six turbines are illuminated at night.
SDEIS Response 7.6 The United States Department of Transportation Federal Aviation
Administration (FAA) requires red flashing aviation obstruction
lighting be placed atop the nacelle of many project turbines to assure
safe flight navigation in the vicinity of the Project. SLW must comply
with the FAA minimum requirements. No additional lighting will be
present at the wind farm atop nacelles. In addition, SLW will use the
minimum of lighting at the O&M Building and Substation and adhere
to recommendations that no upward lighting be used. SLW will direct
lighting at these facilities downward and use the minimum necessary
to adhere to safety standards.
SDEIS Response 7.7 Wind turbines can cause a flickering effect when the rotating turbine
blades cast shadows that move rapidly across the ground and nearby
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structures. This can cause a disturbance within structures when the

repeating pattern of light and shadow falls across the windows of
buildings; particularly when occupants are trying to read or watch
television. The effect, known as shadow flicker, is most conspicuous
when windows face a rotating wind turbine and when the sun is low in
the sky (e.g., shortly after sunrise or shortly before sunset).
While the study of shadow flicker is a relatively new discipline,
evidence from operational turbines suggests that the intensity of
shadow flicker is only an issue at short distances. It is generally
accepted that shadow flicker will have no affect on properties at a
distance further than ten (10) turbine rotor diameters from the turbine
(approximately 2,700 feet for this Project).
Shadow flicker will only occur when certain conditions coincide:
x Daylight hours (sunrise to sunset) -shadow flicker does not occur
at night;
x Sunshine -flicker will not occur on overcast days when daylight is
not sufficiently bright to cast shadows;
x Receptor is within ten (10) rotor diameters of the turbine -beyond
this distance a person should not perceive a wind turbine to be
chopping through sunlight, but rather as an object with the sun
behind it. 2
x Windows face the turbine -turbine shadows can only enter a
structure through un-shaded windows; and
x Turbine is rotating -no flicker will occur when the turbine is shut
down.
Shadow-flicker analysis was conducted using WindPRO 2.4 Basis
software (WindPro), and associated shadow module, a widely accepted
modeling software package developed specifically for the design and
evaluation of wind power projects. Variables used for shadow
calculations include:
x Sunshine probabilities (percentage of time from sunrise to sunset
with sunshine). The WindPro model calculates shadow frequency
based on monthly sunshine probabilities. The following sunshine
probabilities were used for this analysis and are based on historic
meteorological data for Syracuse, NY, approximately 70 miles
south of the Project site.
x Operational Time/Rotor Orientation -The WindPro model assumes
there will be no sh+J103adow flicker during calm winds (when the
blades are not turning). Moreover, the orientation of the rotor (e.g.,
determined by wind direction) affects the size of a shadow cast
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area. To more accurately calculate the amount of time a shadow

will be over a specific location (based on rotor orientation), the
WindPro model considers typical wind direction. The operational
time (hours per year [hrs/yr]) of wind direction is based on
meteorological data collected by the National Oceanographic and
Atmospheric Administration (NOAA) National Buoy Data Center
at the Galloo Island, NY monitoring station (approximately 15
miles southwest of the Village of Cape Vincent)
Shadow flicker analysis has been undertaken for the 53-turbine layout
using a turbine rotor 82 meters (m) (269 feet) in diameter and 80 m
(262.5 feet) hub height. The analysis has been completed for distances
of up to 820 m (2,700 feet) from each turbine location (ten times the
rotor diameter of the proposed turbines). This analysis also includes
the effect of topography on shadow area. The shadow flicker model
incorporates the same digital elevation model (DEM) of the study area
used for viewshed analysis (see section 3.1.1 of the Visual Resource
Assessment).
Using these variables, WindPro was used to calculate the theoretical
number of hours per year the shadow of a rotor would fall at any given
location within the 2,700-foot turbine radius. This calculation includes
the cumulative sum of shadow hours for all turbines and is accurate to
a 10-meter grid cell resolution.
Impacts to campers will be in the early morning hours and shortly
before the sun sets. Impacts, based on a <10-hour-per-year estimate
are very minor, as flicker may only be experienced when the sun is
shining during those hours and the Park is only open part of the year
(mid-May to Labor Day). Day-use visitors are not expected to be
impacted.
According to March 04, 2010 correspondence with Saratoga
Associates: “Data from the Canadian Weather Service for Kingston,
ON showed Kingston is slightly less sunny than Syracuse, by a couple
of percentage points in certain months. Syracuse was the closest US
NWS met data available. The US NWS does not maintain sunshine
probability data for Watertown. Using this data would reduce shadow
hours marginally (possibly 1-3 hours per year for the most impacted
receptors)
SDEIS Response 15.4 No residences will be impacted by shadow flicker more than 30 hours
per year. Shadow flicker is not expected to create an adverse impact on
nearby residences therefore no mitigation is needed. The shadow
flicker study indicates that the commenter’s property will be
potentially impacted by shadow flicker for only 18.1 hours per year.
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SDEIS Response 19.2 Since May 28, 2008, SLW has reduced the number of turbines from 96
to 51, reducing the visual impact of the project. The SDEIS
establishes a basis for review of the revised project and proposes
potential mitigation for visual impacts. SLW has been working with
the Towns of Cape Vincent and Lyme (see Correspondence –
Appendix A) to gain support for specific projects they would be
interested in having performed. SLW has submitted a draft of the
projects to be included in the Plan to SHPO and has gotten a positive
response from that agency (see Correspondence – Appendix A). SLW
will continue to keep ACOE and SHPO involved in the dialogue and
presentation of a final Visual Mitigation Plan.
SDEIS Response 21.1 Please see responses to Comments 19.1 through 19.3 and 20.15. There
have been multiple opportunities for public comment and input, and
there will be additional opportunities as the Project review process
moves forward.
SDEIS Response 22.1 Please see responses to Comments 19.1 through 19.3 and 20.15.
SDEIS Response 25.23 Vegetative screening will be used to mitigate shadow flicker in the
event a residence is impacted more than 30 hours per year.
SDEIS Response 25.63 SLWF provided a visual impact assessment consistent with industry
standards. The type of assessment conducted by SLW has been
accepted as adequate in numerous previous review projects for wind
energy facilities in New York and elsewhere.
SDEIS Response 25.71 Those seven locations were simulated, as required by the Planning
Board. They were located in Appendix I to the SDEIS based on the
revised project layout.
SDEIS Response 72.1 No turbines have been proposed in the River or Lake Districts in the
Town of Cape Vincent.
SDEIS Response 73.39 Many factors are considered in selecting potential sites for wind power
projects including; population density, environmental concerns,
historical concerns, cultural concerns, community concerns assess to
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existing infrastructure, land availability, wind resource, access and

construct-ability. All of theses factors were considered when the
proposed project site was selected. Further, the siting process has been
iterative, with the number of turbines and project layout changed
several times in response to application of these multiple factors.
SDEIS Response 73.59 The FAA requires red flashing lights on top of tall structures. SLW is
proposing the lowest number of red lights as is possible. The
commenter did not describe what specific concerns she has in order to
fully address this comment.
WATER RESOURCES
DEIS Response 1.3 The SDEIS included the submittal of the St. Lawrence Wind Farm
Project (Project) Wetland Delineation Report (Appendix C).
Following the submittal of the DEIS, and the commencement of the
final design phase of the Project, the Project team pro-actively
approached the avoidance of permanent and temporary wetland
impacts. In order to identify opportunities to minimize wetland
impacts, the Project developed a dynamic field and design review
process involving wetland scientists, the Project management team,
and the design team to identify wetland resources in conjunction with
turbine siting criteria, access road layout, underground cable
connection and design criteria, and construction opportunities and
constraints. The layout of the wind farm, and specifically the
avoidance of wetland impacts, is a function of several siting factors
that balance the optimal location of each wind turbine and the need to
access these turbine sites for construction and operational
maintenance. These factors include:
x maximize wind speed and power generation;
x minimize tree clearing, wetland impacts, and the acquisition of
land (the Project proposes to lease the land needed for the Project
facilities);
x maintain the current use of the land (agricultural) and minimize the
loss of agricultural fields; i.e. connect the turbine sites with an
efficient and practical network of as few permanent unpaved roads
as possible;
x co-locate electric cables in the access road corridor that inter-
connect the turbines to the wind farm electric substation where
practical; and
x co-locate the electric transmission line that would connect the
Wind Farm to the electric grid within existing infrastructure right-
of-way.
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These siting factors inherently created a large Project Study Area

consisting of over 9,000 acres of farmland in which to identify and
evaluate siting alternatives that avoid wetland resources. TRC and
SLW, LLC developed a Project wetland field delineation program that
combined a comprehensive and dynamic alternatives siting analysis
along a “linear” or corridor (approximately 250 feet wide) Project
layout so that wetland field delineations supported the effort to avoid
wetland impacts.
DEIS Response 1.4 Table 5-1 of the Joint Wetland Permit Application summarizes
proposed temporary and permanent wetland impacts for the Project.
The proposed fill in wetlands for a project of this magnitude is
minimal. None of the proposed turbine sites involve permanent or
temporary fill, and no state wetlands will be temporarily or
permanently filled. Unavoidable wetland areas to be filled include
narrow previously disturbed wetlands that are currently associated
with farming activity and involve permanent road crossings that are
required to access and maintain the turbines (Please see Figure 2 and
Figure 3 in SDEIS Appendix C). Proposed temporary wetland impacts
include bed and backfill construction for the installation of the
underground electric cable that will connect the turbines to the electric
grid.
The economic, social, and alternative energy needs analysis of the St.
Lawrence Wind Farm were analyzed in detail in Section 3-11 of the
SDEIS.
Even though most wetlands in the Project area have been avoided, and
there will be minimal fill and an inconsequential loss of wetland
function and values involved with the Project construction, project
sponsors propose to counter the effect of the proposed fill areas with
mitigation that compensates permanent wetland fill, and increases
wetland area and wetland functions. Project developers propose to
replace lost wetland with the creation, (by excavating land not
previously occupied by a wetland) of “in-kind” emergent wetland
marsh. The goal of the compensatory wetland will be to increase the
functional values of the lost wetland. In consultation with the
NYSDEC and the Army Corps of Engineers, Acciona will implement
a Wetland Mitigation Plan that encompasses: definitive mitigation
goals, practical replacement ratios and construction specifications;
suitable topographic and hydrologic conditions that ensure the
persistent long-term survival of the compensatory wetland; and,
responsible monitoring with measurable success criteria (a minimum
of five years) consistent with the New York Department of
Conservation’s “Guidelines on Compensatory Mitigation”.
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DEIS Response 1.5 Temporary and permanent wetland impacts were described in Section
3.2.3.2 of the SDEIS. Mitigation measures to each were discussed in
Section 3.2.3.3 of the SDEIS.
DEIS Response 1.13a A Stormwater Pollution Prevention Plan has been prepared for the
Project. The Plan, which has been reviewed by NYSDEC, is located
DEIS Response 2.17 All wetlands, streams and water bodies potentially affected by the
Project have been delineated, mapped and characterized in the
Wetland Delineation Report [Appendix C of the SDEIS]. The Project
will not directly alter perennial streams or water bodies. Relevant
information concerning biotic and water quality data was presented in
the SDEIS. There are no Class AA or A (drinking water source)
streams in the Project area. All the streams and intermittent streams
are designated as Class C and D waters. The Project proposes to
temporarily affect only three “low” quality intermittent streams. These
intermittent streams are in sub-watersheds located in active
agricultural fields that do not support fish populations, or have unique
or diverse biological characteristics. The physical, biotic, and water
quality characteristics of these intermittent streams have been
summarized in data sheets provided in the Wetlands Delineation
Report. Table 5-1 of the SDEIS summarizes the proposed stream and
wetland temporary and permanent impacts of the Project. The specific
Project impacts from construction and proposed mitigation have been
addressed in the Project’s Joint New York State & U.S. Army Corps of
Engineers Application for Permit.
DEIS Response 2.18 Please see responses to Comment 1.4 and Comment 2.17.
DEIS Response 2.19 Please see response to Comment 1-4.
DEIS Response 2.20 Under the proposed layout, no turbines are located in or near water
bodies, or in wetland areas.
14.
DEIS Response 12.1 Please see the mitigation measures described in the Residential Well
Plan in Appendix C-6 of the FEIS.
DEIS Response 19.6 Wetlands have been field-delineated and the Project layout revised to
avoid or minimize impacts to wetlands. SLW will receive permit
authorization from the USACE.
DEIS Response 19.7 Potential impacts to groundwater and surface water resources are
further addressed in Sections 3.2.1 and 3.2.2 of the SDEIS. Regarding
karst topography, see response to Comment 1.12. In addition, the
Project has developed a draft Stormwater Pollution Prevention Plan
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(SWPPP) that has addressed erosion control issues during

construction/post-construction.
DEIS Response 21.3 SLW has committed to completing a geotechnical investigation and
has prepared a SWPPP (Appendix C-8 of the FEIS).
DEIS Response 21.5 SLW has prepared a draft Soil Erosion and control plan, and a draft
SWPPP, which may be found in Appendix C-8 of the FEIS.
DEIS Response 24.1 To avoid or minimize impacts to agricultural areas SLW has
committed to implementing NY Department of Agriculture and
Markets revised Guidelines for Agricultural Mitigation for Windpower
Projects. These include construction, restoration and monitoring
recommendations and guidelines. Similarly, wetlands have been
avoided to the extent practicable, and unavoidable wetland impacts
will require permit authorization from the USACE. Authorized
activities must comply with all permit conditions including any
restoration or monitoring requirements.
DEIS Response 61.2 Potential impacts to groundwater and surface water resources were
addressed in Sections 3.2.1 and 3.2.2 of the SDEIS. Regarding karst
topography, Please see response to Comment 1.12.
DEIS Response 81.2 Location of turbines is based on a number of considerations, including
erosion and runoff control. To ensure protection of these important
resources, SLW has prepared a draft SWPPP in Appendix C-8 of the
FEIS. This draft has been reviewed by NYSDEC and will be finalized
once the Project is permitted, and pre-construction engineering studies
have been performed.
DEIS Response 112.9 Please see Appendix C of the SDEIS.
DEIS Response 112.12 Storm Water Pollution Prevention Plan (SWPPP) is included in
Appendix C-8 of the FEIS. Section 2.6 of the SDEIS details soil
erosion control plans.
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SDEIS Response 1.6 T3 is not located in a wetland. Temporary impacts were proposed for
the work area around T3; however, SLW has worked with the USACE
to and has proposed to move T3 approximately 30 feet and to adjust
the work area around T3 so as not to impact wetlands around T3.
There will be a small permanent wetland impact due to construction of
an access road leading to T3. Swamp mats will be used during
construction to further reduce temporary and permanent impacts.
Please see Section 2.2.1 for a complete description of the area around
T3 and how the Project proposes to align work areas to reduce these
impacts.
SDEIS Response 1.7 The project has avoided and minimized impacts to the maximum
extent practicable in its most current design. The project site is
roughly 7000 acres. For a project of this size, wetland impacts of 0.34
acres constitute minimal impacts. Mitigation has been proposed to
compensate for all wetlands impacted, including forested wetland
impacts. Forested wetlands, like the commenter states, are considered
permanent impacts. SLW will create a forested wetland area around
the compensatory wetland mitigation area to mitigate those impacts.
Please see Section 2.2.1 for a conceptual layout of the compensatory
wetland mitigation area.
SDEIS Response 2.20 Please see revised wetland section of FEIS.
SDEIS Response 2.21 The comment is unfounded, based on the scope of work to be
performed at the site. The Project proposes: 1) placement of turbine
foundations, 2) construction of road crossings over wetlands or
streams, and 3) road improvements at intersections. The short-term
and long-term effects of these facilities will be minor and will have
little effect on surrounding land use, or the existing highway or farm
drainage system of road- side swales:
x The Project area will remain in agricultural use and there will not
be a significant increase in runoff discharge or drainage patterns
anywhere in the Project area. Due to the level Project area and it’s
location in managed agricultural fields, minor road drainage swales
have been designed to convey runoff from temporary and
permanent road surfaces and prevent runoff from collecting in
adjacent fields. These proposed swales in most locations have
been designed to be extensions or improvements to the existing
drainage swales that have been constructed by local
farmers/landowners, or the local Highway Department.
x Changes to existing drainage patterns will be minimal, and in some
cases will represent an improvement in that, drainage will not
produce ponding, and some existing obstructions in the existing
drainage system will be removed. The existing drainage swales in
several locations are extensions of wetlands delineated in the
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Project areas and will remain so following Project construction. In

some locations, existing wetland swales must be unavoidably
crossed at very few locations. The Project has demonstrated
appropriate avoidance and minimization of these wetland drainage
areas in its Joint (wetland) Application, and proposes best
management practices, including appropriate drainage culvert
capacity design and the use of NYSDEC storm water runoff
erosion and sedimentation prevention design standards.
x In addition, although unavoidable wetland impacts are primarily
confined to these wetland swales, the Project proposes
compensatory wetland mitigation for these minor wetland fill
areas.
x Finally, the Project anticipates receiving a general permit from the
Army Corps of Engineers – Regulatory Branch and from the
NYSDEC Wetlands Program for minor effects on wetlands, and
anticipates a SPDES Storm Water Discharge Permit for
Construction Activity from the NY-DEC-Division of Water.
SDEIS Response 3.2 During the pre-construction process, the Project will detail plans for
crossing the Chaumont River. No ROW maintenance will adversely
affect the coastal resources of this river body. Herbicides will not be
used near the crossing of the Chaumont River.
Typical erosion control BMPs that we have used on other wind
projects include silt fences, swales, erosion logs, and erosion blankets,
however, the civil design and construction of the area near the coastal
zone will incorporate specific BMPs as appropriate. Herbicides are
not typically used on our projects and impacts on coastal resources
will certainly be considered. The clearing of the area in the
transmission line right of way near the coastal area can be limited to
tall trees only. Low growing foliage such as bushes, grasses, and
scrub brush can remain so that erosion impacts are minimized. The
preliminary design of the transmission line incorporates poles that are
spaced at least 70 ft away from the edge of the river.
SDEIS Response 3.5 SLW has committed to completing successful wetland mitigation. The
wetland mitigation plan includes efforts in post-construction years to
monitor the wetland restoration and mitigation areas to ensure the
success of SLW's obligation, and is described fully in the project's
USACE Wetland Application, which was submitted to USACE in
April 2009. Copies of the application are available on the project's
website at www.stlawrencewind.com. The USACE will monitor the
wetland mitigation plan.
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“3.1 states: Consistency review is not required so long as the Project

continues to qualify under USACE Nationwide Permits 12 and 14.”
SDEIS Response 11.12 A Wetland Mitigation Plan is included in the Joint Wetland Permit
application filed with the USACE and NYSDEC. This document may
also be found in the Cape Vincent and Lyme Libraries or on our
website: www.stlawrencewind.com. The application is a public
document which is incorporated into this FEIS by reference.
SDEIS Response 16.3 A well survey has been completed. The well survey describes under
what conditions St. Lawrence Wind will provide potable water to a
resident. Please see Appendix C-6.
SDEIS Response 17.7 A well survey has been completed. Should problems occur in well
within 500 feet of proposed blasting zones, the well survey provides
steps to provide citizens with potable water. Please see Appendix C-6.
SDEIS Response 17.8 The Application to the NYSDEC for an Article 24 Freshwater Wetland
Permit and Section 401 Water Quality Certification is included as part
of the Joint Application to the USACE and NYSDEC for wetlands and
water permits. The application is incorporated into this FEIS by
reference, and can be viewed at the Cape Vincent or Lyme Library, or
on SLW’s website: www.stlawrencewind.com.
SDEIS Response 17.10 Wetland field studies were performed and reported in the SDEIS in
Appendix C. Included in the FEIS is the scope for a Transmission
Line Engineering Study (Appendix C-7) and Residential Well study
(Appendix C-6), SLW has committed to a geotechnical/karst survey
study, as described in the SDEIS from pages 3-17 to 3-20. This will
occur prior to Site Plan Review of the Project.
SDEIS Response 17.16 Pre-construction biotic/water quality data did not need to be obtained
because the potential impacts to surface waters from the Project are so
small. Minimal impacts to wetlands (less than 1/2 acre) will be
attributable to the project. A draft SWPPP, found in Appendix C-8,
describes measures that the Project will undergo to eliminate/minimize
erosion and water contamination.
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SDEIS Response 36.1 A well survey has been completed. The well survey describes under
what conditions St. Lawrence Wind will provide potable water to a
resident. Please see Appendix C-6.
SDEIS Response 54.10 SLW will perform well testing within 500’ of each turbine. Appendix
C-6 describes the Residential Well Monitoring Plan that SLW will
undertake to ensure protection of these important resources.
SDEIS Response 73.60 Waters will be protected during construction, as required by federal,
state, and local law. As required, SLW will adhere to a Stormwater
Pollution Prevention Plan to minimize sediment and erosion control
(see Appendix C-8) and compensatory wetland mitigation to mitigate
on a 2:1 ratio for filled wetlands.
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5.0 LIST OF PREPARERS

This Final Environmental Impact Statement has been prepared pursuant to the State
Environmental Quality Review Act (6 NYCRR 617) with input from the following list of
preparers.
Tetra Tech EC, Inc. Acciona Energy North America Corporation

1000 The American Road 165 Jordan Road
Morris Plains, New Jersey 07950 Troy, NY 12180
Richard Delahunty Blayne Gunderman
Senior Scientist and Project Manager Environmental Manager, Eastern USA
(973) 630-8402 (518) 588-4672
Joseph Fischl Tim Conboy
Senior Ecologist and SEQR Technical Lead Project Development Manager
(973) 630-8385 (518) 796-3380
Western EcoSystems Technology, Inc. Saratoga Associates, Inc.

2003 Central Avenue 443 Broadway
Cheyenne, Wyoming 82001 Saratoga Springs, New York 12866
David Young Matt Allen, RLA
(307) 634-1756 Associate Principal
(518) 587-2550
TRC Environmental Corporation Hessler Associates, Inc.

Boott Mills South 3862 Clifton Manor Place, Suite B
116 John Street Haymarket, Virginia 20169 USA
Lowell, MA 01852 David M. Hessler, P.E., INCE
Steven P. Damiano Principal Consultant
(978) 970-5600 (703) 753-1602
Nixon Peabody, LLP

677 Broadway
10th Floor
Albany, NY 12207
Richard M. Cogen
Partner
(518) 427-2665
5-1
003959
6.0 REFERENCES
Amick, Hal and Michael Gendreau. 2000. Construction Vibrations and Their Impact on Vibration-
Sensitive Facilities. ASCE Construction Congress 6.
Colby, W. D. et al. December 2009. Wind Turbine Sound and Health Effects: An Expert Review Panel.
British Epilepsy Association. 2010 Photosensitive epilepsy. March 2010.

http://www.epilepsy.org.uk/info/photosensitive. Access March 2010.
ERCOT System Planning. 2006. Analysis of Transmission Alternatives for Competitive Renewable
Energy Zones in Texas.
http://www.Ercot.com/news/presentations/2006/ATTCH_A_CREZ_Analysis_Report.pdf. Accessed
March 2010.
GE Energy Consulting. 2005. The Effects of Integrating Wind Power on Transmission System Planning,
Reliability, and Operations, Report on Phase 2: System Performance Evaluation. March 4, 2005.
Hoen, B., R. Wiser, P. Cappers, M. Thayer, and G. Sethi. 2009. The Impact of Wind Power Projects on
Residential Property Values in the United States: A Multi-Site Hedonic Analysis. Ernest Orlando
Lawrence, Berkeley National Laboratory, Environmental Energy, Technologies Division.
First Wind. Environmental Benefits. http://www.kaheawa.com/kwp/environmental.cfm. Accessed

March, 2010.
National Agriculture Imagery Program (NAIP) 2001 U.S. Department of Agriculture, Farm Service
Agency.
New York State Department of Environmental Conservation (NYSDEC). 2001. Assessing and
Mitigating Noise Impacts. Division of Environmental Permits. Issuance Date: October 6, 2000,
Revised: February 2, 2001
Tetra Tech EC, Inc. January 2007. Draft Environmental Impact Statement Proposed St. Lawrence Wind
Energy Project, Towns of Cape Vincent & Lyme, Jefferson County, New York.
Tetra Tech EC, Inc. January 2009. Supplemental Draft Environmental Impact Statement Proposed St.
Lawrence Wind Energy Project, Towns of Cape Vincent & Lyme, Jefferson County, New York.
Town of Cape Vincent Zoning Law, 1989. Zoning Law: Amended in 1991, 1993, and 1998. Amended in
2006 to Recognize Wind Power Facilities.
Town of Lyme, 1989. Town of Lyme Zoning Ordinance. Portions amended in 1997, 1993, and 1989.
TRC. 2010. St. Lawrence Windpower, LLC, Proposed St. Lawrence Wind Farm (SLW), Joint (Wetlands)
Permit Application, ACOE File No. 2009-00590, Final Application Addendum.
U.S. Department of Energy. 2008. 20% Wind Energy by 2030: Increasing Wind Energy’s Contribution to
U.S. Electricity Supply, DOE/GO-102008-2567 • July 2008. Accessed from
http://www.20percentwind.org/20percent_wind_energy_report_05-11-08_wk.pdf
6-1
003960
Table 2-1
1
Approximate Area of Vegetation Disturbance
Sub-Station/ Collector Construction

Access Roads Turbine Met Towers
Habitat/Land Use O&M Lines Areas Total
Permanent Impacts
Developed, Open Space 0.06 0 0 - 0 - 0.06
Developed, Low Intensity 0.41 0 0.26 - 0 - 0.67
Deciduous Forest 0.7 0.02 0 - 0 - 0.72
Scrub-Shrub 0.63 0 0 - 0 - 0.63
Grassland 0.93 0.02 0 - 0 - 0.95
Pasture/Hay 17.43 0.51 10.98 - 0 - 28.92
Crops 9.74 0.27 0.28 - 0 - 10.29
2
Forested Wetlands 0.19 0 0 - 0 - 0.19
Total 30.17 0.82 11.52 0 0 0 42.51
Temporary Impacts
Developed, Open Space 0.17 0 - 0.37 - 0.18 0.72
Developed, Low Intensity 1.02 0 - 0.79 - 0.13 1.94
Deciduous Forest 1.61 1.89 - 1.37 - 0.04 4.91
Scrub-Shrub 1.38 1.11 - 0.62 - 0.26 3.37
Grassland 2.18 2.3 - 1.22 - 0 5.7
Pasture/Hay 40.17 51.9 - 29.55 - 5.25 126.87
Crops 22.55 24.65 - 15.91 - 8.28 71.39
2
Forested Wetlands 0.42 0.68 - 0.05 - 0 1.15
Total 69.5 82.53 - 49.88 - 14.14 216.05
1
Data were obtained from the US Geological Survey National Land Cover Data (NLCD). This data set provides standardized land
use and land cover data acquired by remote sensing techniques (Landsat Thematic Mapper Satellite) including the use of
conventional aerial photography. These data represent a generalized land cover classification.
2
Wetlands were field delineated and results provide a more accurate determination of impacts for these covers types which include a
total of 0.31 acre of permanent impacts and 1.14 acres of temporary impacts to forested, scrub-shrub and emergent wetlands.
2-6
003961
Table 2-2
Wind Speed
6 m/s 7 m/s 8 m/s 9 m/s 10 m/s
Table 2-3
Octave Band Center

31.5 63 125 250 500 1k 2k 4k 8k dBA
Frequency (Hz)
Estimated Lw
107 104.3 103.8 102.8 100.4 96.8 90.2 82.8 72.7 101.7
(dB re 1 pW)
2-12
003962
Table 2-2
Wind Speed
6 m/s 7 m/s 8 m/s 9 m/s 10 m/s
Table 2-3
Octave Band Center

31.5 63 125 250 500 1k 2k 4k 8k dBA
Frequency (Hz)
Estimated Lw
107 104.3 103.8 102.8 100.4 96.8 90.2 82.8 72.7 101.7
(dB re 1 pW)
2-12
003963
Table 2-4
Affiliate Channel
Table 2-5
CBC - - 32 Kingston, ON 23.7 312.0

FAA
NTIA
Over-the Air TV
2-26
003964
Table 2-4
Affiliate Channel
Table 2-5
CBC - - 32 Kingston, ON 23.7 312.0

FAA
NTIA
Over-the Air TV
2-26
003965
Table 2-6
Potential Impacts Associated with Roadway Improvements
Participating Property
Existing Sign Impacts
ROW Impacts to Non-

Intersection Quadrant
Utility Pole Impacts
Impacts to Existing
Curve/Intersection
Culvert/ Drainage
Trees/Vegetation
Overhead Signal
Road Condition
Overhead Wire
Impacted by Route
Improvement
Clearance
Clearance
Widening
Structure
Owners
Intersections
1) Route 104/Route 104B
2) Route 180/Route 3/County Rd 66 Ɣ
3) Route 180/Route 12F Northeast Ɣ Ɣ Ɣ Ɣ
Southeast Ɣ Ɣ Ɣ Ɣ
4) Route 12F/I-81 Exit 46 NB Ramp Northwest Ɣ Ɣ Ɣ
Northeast Ɣ Ɣ Ɣ
5) Route 342/I-81 Exit 48 NB Ramp Southeast Ɣ Ɣ Ɣ
6) Route 12/Route 342 Northeast Ɣ Ɣ Ɣ Ɣ
7) Route 12/County Rd 9 Southeast Ɣ Ɣ Ɣ
8) County Rd 9/McKeever Rd Southwest Ɣ Ɣ Ɣ
9a) County Rd 8/McKeever Rd NB Southeast Ɣ Ɣ
9b) County Rd 8/McKeever Rd SB Southeast Ɣ Ɣ
10) County Rd 8/Mason Rd Northeast Ɣ
Southeast Ɣ Ɣ Ɣ
Intersections
11) Mason Rd/Gosier Rd Northwest Ɣ Ɣ Ɣ
12) Favret Rd/Mason Rd Southwest Ɣ Ɣ Ɣ
13a) Favret Rd/Hell St NB Northeast Ɣ Ɣ Ɣ
13b) Favret Rd/Hell St SB Southeast Ɣ Ɣ
14) Hell St/Constance Rd Northwest Ɣ Ɣ Ɣ Ɣ Ɣ
15) Favret Rd/Wilson Rd Southeast Ɣ Ɣ Ɣ
16) Route 12E/Favret Rd Northeast Ɣ Ɣ
17) Route 12E/Deerlick Rd Southeast Ɣ Ɣ Ɣ
Segments
Constance Road Ɣ
Wilson Road Ɣ
NY Route 12
at NY Route 180 Ɣ
at County Road 179 Ɣ
at County Road 4 Ɣ
Note: Selected quadrant represents the least impacts based on a review of the participating property owners
and existing intersection constraints.
2-29
003966
3.0 COMMENT MATRIX

Comments received throughout the SEQR process for the Saint Lawrence Windpower Project
area summarized in Tables 3-1 and 3-2. Summaries of DEIS comments are provided in Table 3-
1 and SDEIS comments are provided Table 3-2. Comments were generally provided in letters to
the Planning Board; however, numerous oral comments were received during the Public
Hearings held for both the DEIS and SDEIS. Transcripts of the DEIS and SDEIS Public
Hearings are provided in Appendix D and copies of all written comments received are provided
in Appendix E in their entirety.
3-1
003967
Table 3-1
Results of the 2006 bat survey and Avian and Bat Study Plan
need to be included in the SDEIS to support conclusions
Tomasik, Steven for stated in the DEIS; SDEIS should also include discussion of
1 1 NYSDEC
Jack Nasca mitigation measures that might be implemented if adverse
impacts are identified in the bat fatality monitoring program
(adaptive management strategy)
DEC does not agree that a more expanded cumulative
analysis is not warranted because "bird collisions with wind
projects represent a very small portion of all bird collisions
Tomasik, Steven for
1 2 NYSDEC with man-made objects," or that the other two proposed wind
Jack Nasca
projects in the region are "speculative". Using existing
available information, the SDEIS should provide a fuller
discussion of cumulative impacts.
SDEIS should include wetland delineation reports for any
areas that would be impacted by project construction; SDEIS
Tomasik, Steven for should discuss wetland avoidance and impact minimization
1 3 NYSDEC
Jack Nasca and proposed techniques to be used to minimize temporary
wetland impacts; feasibility study should be included to make
recommendations in regard to alternatives
If unavoidable wetland impacts result from project
construction, the SDEIS must discuss the overriding
economic and social needs for the project that outweigh the
Tomasik, Steven for
1 4 NYSDEC environmental costs of impacts on wetlands, describe
Jack Nasca
compensatory mitigation being considered, and how the
proposed mitigation will conform to DEC wetland mitigation
guidelines
Tomasik, Steven for The distinction between "temporary" and "permanent"
1 5 NYSDEC
Jack Nasca wetland impact needs to be clarified in the SDEIS
Tomasik, Steven for
1 6 NYSDEC SDEIS should include an Invasive Species Control Plan
Jack Nasca
Section 2.6.4. SDEIS needs to include a description of
Tomasik, Steven for specific processes that will be implemented to ensure that
1 7 NYSDEC
Jack Nasca concrete is handled properly during construction to limit
impacts to surface waters, wetlands and underground waters
3-2
003968
Table 3-1
Section 2.7 and 2.8. Environmental impacts associated with
major turbine repair or replacement, including recurrence of
"temporary" wetland impacts associated with access road re-
widening, not adequately discussed; SDEIS should include a
Tomasik, Steven for
1 9 NYSDEC project-wide long-term environmental management plan, a
Jack Nasca
contingency plan, and assessment and mitigation of
environmental impacts during the decommissioning process;
Environmental management plan should include an adaptive
management plan
Section 3.2.3.3 does not adequately describe the range of
Tomasik, Steven for
1 10 NYSDEC mitigation measures to be considered if project construction
Jack Nasca
results in unavoidable wetland impacts.
DEC recommends that a Blanding's turtle habitat and nest
Tomasik, Steven for site survey be included as part of wetland delineation
1 11 NYSDEC
Jack Nasca activities conducted in the project area. If appropriate habitat
is found, a trapping and tracking survey would be warranted.
DEC recommends that a comprehensive survey of karst
features be conducted in the project development area; DEC
Tomasik, Steven for
1 12 NYSDEC recommends that a plan be prepared that specifies
Jack Nasca
procedures for conducting detailed subsurface investigations
at locations that may interface with limestone/karst features.
Section 3.7.2. Survey to inventory architectural cultural
resources within one mile of the project is not included in the
Tomasik, Steven for
1 14 NYSDEC DEIS; furthermore, the survey's one-mile study area is
Jack Nasca
inadequate; DEC visual policy establishes a recommended
five-mile study area for visual impacts.
DEC recommends that the visual setting of each affected
significant resource in the project area and five-mile visual
impact area, including newly identified significant historic
Tomasik, Steven for resources, be analyzed, and where feasible at specific
1 15 NYSDEC
Jack Nasca impacted resources, direct mitigation options such as
screening or selective turbine re-location should be applied.
Offsets should be employed if these types of mitigation
would be uneconomic or only partially effective. Direct
3-3
003969
Table 3-1
mitigation and offsets need to be fully discussed in the
SDEIS. Mitigation for visual impacts should be developed in
concert with a mitigation strategy for impacts identified
according to the cultural resources assessment.
SDEIS needs to consider a cumulative assessment of visual
Tomasik, Steven for
1 16 NYSDEC impacts of this project and the two other wind power projects
Jack Nasca
proposed in the general area.
SDEIS should discuss the status and results of any historic
Tomasik, Steven for preservation studies undertaken; correspondence with
1 17 NYSDEC
Jack Nasca OPRHP detailing that agency's rationale for making an
impact/effect determination should be included in the SDEIS
Tomasik, Steven for Archeological studies should be completed prior to, and
1 18 NYSDEC
Jack Nasca incorporated in, the SDEIS
The SDEIS should describe a compliance and monitoring
Tomasik, Steven for
1 19 NYSDEC program to include planning, training, pre-construction
Jack Nasca
coordination, and construction/restoration inspection
DEC may require that the Stormwater Pollution Prevention
Tomasik, Steven for Plan prepared for the project to comply with the SPDES
1 13a NYSDEC
Jack Nasca Stormwater General Permit for Construction Activities be
reviewed by DEC staff prior to implementation
Appendix C. The Visual Impact Assessment (VIA) does not
include consideration of properties identified in the project
Tomasik, Steven for Cultural Resources Survey for this project which are not
1 13b NYSDEC
Jack Nasca currently inventoried, but which may be determined to be
National Register Eligible (Doesn't include results from 5-mile
study).
Section 2.3. No data provided to support statement that the
2 1 USFWS project will improve air quality by offsetting emissions
Sullivan
produced at fossil fuel burning power plants
Section 2.3. The DEIS indicates that the project will reduce
sulfur dioxide, nitrogen oxide, and other pollutants; however,
2 2 USFWS wind energy projects do not deliver the environmental
Sullivan
benefits typically described by project sponsors. Almost no
sulfur dioxide or nitrogen oxide would be eliminated from the
3-4
003970
Table 3-1
operation of wind energy projects.
It is not specified whether will be one or two meteorological
towers, nor is it mentioned what type of structure will be
Stilwell, David and Tim constructed; USFWS recommends that no guy wires be used
2 3 USFWS
Sullivan on the towers as they have been known to be flight hazards
for wildlife; monopole or self-supporting towers should be
installed
USFWS recommends that the siting of wind turbines avoid
Stilwell, David and Tim forested areas and structures instead by placed along the
2 4 USFWS
Sullivan edges of forests or be eliminated to limit habitat
fragmentation
Stilwell, David and Tim Section 2.5. USFWS found little data to support the need for
2 5 USFWS
Sullivan the project size
Section 2.5. DEIS does not indicate the locations of the best
2 6 USFWS wind resource; therefore they cannot determine what options
Sullivan
the project sponsor has to move turbine locations
Section 2.5. Data should identify areas where birds and bats
2 7 USFWS are concentrated, and thus, provide data to support alternate
Sullivan
turbine locations
Section 2.6. Since birds are likely to occur throughout the
Stilwell, David and Tim project site during the construction period, the USFWS
2 8 USFWS
Sullivan questions how impacts to breeding birds will be avoided
(stated in Table 1-1, Sheet 3 of 8).
Section 2.6. USFWS suggests that applicant reduce the final
2 9 USFWS proposed width of access roads to 16 feet, consistent with
Sullivan
access road width for other wind projects in the State.
Section 2.6. USFWS recommends that the project sponsor
Stilwell, David and Tim design the project so that more project facilities are
2 10 USFWS
Sullivan collocated. Currently only 3.4 miles of the 44 miles of buried
interconnect cable would be collocated along access roads.
Section 2.6. The project sponsor should reduce impacts to
Stilwell, David and Tim habitat as much as possible. Vegetation is proposed to be
2 11 USFWS
Sullivan cleared to a width of 25 feet where underground cable will be
buried but the actual cable trench would only be 1 to 3 feet
3-5
003971
Table 3-1
wide.
Section 2.6. Directional drilling should be used to cross all
2 12 USFWS perennial streams and wetlands to reduce the potential for
Sullivan
water quality impacts.
Section 2.6. The proposed route of the overhead
transmission line has not been determined, information vital
Stilwell, David and Tim to determine the potential impacts to wildlife. The
2 13 USFWS
Sullivan transmission line should be routed around forests to protect
existing habitat value, reduce fragmentation, and maintain
interior core areas.
Section 3.0. USFWS recommends that no turbines are sited
2 14 USFWS within peat muck areas as these soils may support rare and
Sullivan
irreplaceable habitat.
Stilwell, David and Tim Section 3.0. Karst features may provide unknown
2 15 USFWS
Sullivan hibernacula for bats and should be avoided.
Section 3.0. DEIS should specifically state that alvar
2 16 USFWS landscapes, located at Chaumont Barrens and Three Mile
Sullivan
Creek Barrens, will not be impacted by the project.
Section 3.2. The report should include biotic and water
2 17 USFWS quality data along with a discussion of potential impacts from
Sullivan
project construction.
Section 3.2. Project sponsor should identify which water
bodies will be crossed; the current condition of each; whether
they are perennial, intermittent, or ephemeral; and the exact
amount of temporary, permanent, direct, and indirect impact
Stilwell, David and Tim to each. This should include an analysis of impacts to water
2 18 USFWS
Sullivan quality, habitat conditions, and aquatic life. Mitigation
measures to compensate for lost or degraded habitat should
be discussed. Permanent stream crossings should consist of
bridges or bottomless culverts. In disturbed areas, stream
banks should be seeded and planted to prevent erosion.
A field delineation of wetlands should be completed and then
2 19 USFWS project design adjusted so that impacts are avoided and
Sullivan
minimized to the greatest extent practicable. The DEIS
3-6
003972
Table 3-1
should be revised with information on wetland extent; size;
physical characteristics; community type, function, and value;
and potential direct and indirect impacts to each.
Turbines should be located away from wetlands and water
2 20 USFWS bodies to avoid changing the character and function of these
Sullivan
features for wildlife.
DEIS does not identify if the wind project will impact the
efforts to establish St. Lawrence Wetland and Grassland
Management District (SLWGMD) nor does it mention if the
proposed project is compatible with the purpose of the
2 21 USFWS SLWGMD. This information should be provided to the
Sullivan
USFWS for review. Since waterfowl and grassland birds
may collide with turbines, and because the purpose of the
SLWGMD is to increase production of avian populations in
these areas, the two projects may not be compatible.
DEIS should provide the methodologies used to determine
Stilwell, David and Tim natural resource impacts. Habitat types in the project area
2 22 USFWS
Sullivan should be field checked so that impact assessments are
accurate.
No discussion of reptiles and amphibians potentially found in
the project area is included in the document. Nor is there
2 23 USFWS any discussion of potential impacts to these species. The
Sullivan
New York State Amphibian and Reptile Atlas (NYSDEC)
should be consulted.
The discussion of affected mammals is inadequate, as no
survey data or existing information sources were provided.
The Lead Agency should require the project sponsor to
Stilwell, David and Tim include this information in a revised report. The statement
2 24 USFWS
Sullivan that "no threatened or endangered mammals, or their critical
habitat, are located within the project area" should be
removed as insufficient studies have been conducted to
determine the presence of listed bats.
Stilwell, David and Tim Section 3.3.3. The fact that the Indiana bat is a State- and
2 25 USFWS
Sullivan Federally-listed endangered species should be clarified.
3-7
003973
Table 3-1
The statement that Indiana bats have not been recorded in
Stilwell, David and Tim the project area is misleading. Results from the acoustic
2 26 USFWS
Sullivan monitoring have not been presented and no mist-netting has
occurred within the proposed project area.
The distances to Indiana bat locations are incorrect. Multiple
Indiana bat spring/summer roosts have been documented
2 27 USFWS within 10 miles of the project area. The Glen Park
Sullivan
hibernaculum is approximately documented 17 miles
southeast of the project area.
Further analyses regarding potential impacts to bats from the
proposed project are needed. There is nothing to support
the claim that "Predicting bat fatality impact is difficult based
2 28 USFWS on available knowledge of bat interactions with wind facilities
Sullivan
but is expected that impacts to bats at the Saint Lawrence
Wind Energy Project would be similar to other regional wind
projects"
The USFWS does not agree that Section 3.3.7 provides an
adequate assessment of potential impacts to the Indiana bat.
Stilwell, David and Tim Large numbers of bats have been killed by wind turbines in
2 29 USFWS
Sullivan the East and the potential cumulative impact on populations
could be significant. Should the proposed project be
constructed, a bat fatality monitoring program is necessary.
Section 3.3.4 DEIS does not disclose that Derby Hill has
among the highest number of raptors observed during spring
migration in the Northeast. Also, the text does not
Stilwell, David and Tim adequately address the fact that large numbers of raptor
2 30 USFWS
Sullivan species, such as bald eagles, golden eagles, northern
harriers, and peregrine falcons move along the Lake Ontario
shoreline toward the project area. An adequate assessment
of risk to these species should be provided.
Section 3.3.4. It is unclear how the project sponsor can
2 31 USFWS claim that the project design minimizes impacts to migrating
Sullivan
birds when avian migration data is not yet available.
2 32 USFWS Stilwell, David and Tim Section 3.3.5. Project-specific breeding bird data should be
3-8
003974
Table 3-1
Sullivan included in a revised report. This should include information
on the potential impacts to grassland nesting birds endemic
to the region. Sponsor should evaluate project compatibility
with Service' efforts to increase productivity of grassland and
waterbirds in the area.
Section 3.3.6. There are a large number of wintering raptors
Stilwell, David and Tim other than bald eagles in the region. This information should
2 33 USFWS
Sullivan be considered by the project sponsor in siting the project
features.
Section 3.3.6. The project sponsor should review the
Stilwell, David and Tim Service's "Interim Guidelines to Avoid and Minimize Wildlife
2 34 USFWS
Sullivan Impacts from Wind Turbines" (Guidelines) (USFWS 2003)
during design of the project.
Section 3.3.6. A risk assessment that includes information
on bird abundance and distribution over multiple seasons
and years, avian avoidance behavior of turbines, weather
data, and information on migration, breeding, wintering, and
2 35 USFWS stopover habitat should be included in the environmental
Sullivan
documents. Insufficient data were collected at the project
site to determine use of the project airspace by flying animals
to conduct a risk assessment and predict wildlife mortality for
this project.
A post-construction monitoring protocol should be provided
to the NYSDEC and USFWS for review. If turbines are
Stilwell, David and Tim located within blocks of grassland habitat, turbines should
2 36 USFWS
Sullivan not have a cut-in speed of less than 6 meters per second
and operation should be curtailed between July 15 and
September 15 for 5 hours after sunset.
A construction environmental monitoring program should be
Stilwell, David and Tim implemented, which includes a training component for
2 37 USFWS
Sullivan workers on how to identify and handle injured or dead
wildlife.
Stilwell, David and Tim Section 3.3.7. Copy of the current draft protocols from the
2 38 USFWS
Sullivan recently issued Draft Revised Indiana Bat Recovery Plan for
3-9
003975
Table 3-1
information on this species and mist-netting procedures
enclosed.
The FEIS should address the potential effects of the action
on the Indiana bat and bald eagle in far greater detail than
2 39 USFWS the DEIS. Additionally, the Corps or applicant should
Sullivan
prepare a Biological Assessment (BA) for the proposed
project.
Section 3.3.7. Adverse impacts to Blanding’s turtle are
unclear. The turtles use upland areas for many activities
2 40 USFWS including basking and nesting. Further discussion with the
Sullivan
NYSDEC is necessary to determine the potential for impacts
to Blanding's turtles.
Section 3.3.7. The statement "Based on the wintering bald
eagle's use of the St. Lawrence River, the Project is not
expected to have an adverse affect on eagle foraging or
substantially increase the risk of eagle foraging or
substantially increase the risk of eagle collisions with
2 41 USFWS turbines" is confusing and unsubstantiated. Section should
Sullivan
address eagle nesting, wintering, and migration occurrences
and behaviors, and link those to potential effects to the eagle
from turbine construction and operation. Increased potential
for collision during adverse weather conditions should also
be discussed.
Section 3.3.7. The statement "Although dispersal of the
Indiana bat is in the range of the proposed Project, impacts
are considered unlikely as Indiana bats typically fly low to the
2 42 USFWS ground, below the rotor sweep are" is unsubstantiated at this
Sullivan
time. Mist-netting should be done performed. Potential
impacts due to construction and operation of the proposed
project will need to be analyzed in much greater detail.
Section 4.0. The DEIS should provide a general description
Stilwell, David and Tim of where the other 2 proposed wind energy projects are
2 43 USFWS
Sullivan located in the region; the assumption should be made that
these projects will be constructed; more discussion should be
3-10
003976
Table 3-1
provided on the potential effects on wildlife, particularly avian
and bat species.
Section 7.0. Wind data were not provided for the project
Stilwell, David and Tim area; therefore, alternative turbine locations could not be
2 44 USFWS
Sullivan determined. The project design, including project size,
should reflect efforts to avoid and minimize impacts.
State of New York
Section 2.6.5. The minimum burial depth in agricultural
Department of
3 1 Brower, Matthew areas should be 48 inches for all methods, unless bedrock is
Agriculture and
encountered at less than 48 inches.
Markets
The Department recommends that the 34.5 kV lines be
buried in agricultural fields. If lines must be installed
State of New York
overhead, they should be located outside field boundaries
Department of
3 2 Brower, Matthew wherever possible. When these lines cross farmland,
Agriculture and
spanning distances should be no less than 400 feet. Line
Markets
location and pole placements should be reviewed with the
Dept. prior to final design.
State of New York
Department of Recently revised "Guidelines for Agricultural Mitigation for
3 3 Brower, Matthew
Agriculture and Windpower Projects" is enclosed
Markets
The DEIS does not include in sufficient detail the specific
State of New York
project components necessary for project operation; specific
knowledge of the proposed turbine sizes, make and model is
Service
appropriate for consideration in a DEIS.
Project components not described in the DEIS include:
communications equipment associated with turbine field
operations, typically including SCADA communication cables
State of New York from each turbine to substations and the O&M facilities;
4 2 Department of Public Davis, Andrew substation communication equipment to downstream electric
Service transmission substations; the 9-mile long overhead line,
substation equipment for low-voltage step-up to transmission
voltage and transmission interconnection facilities at the
NMPC Lyme Substation; and any downstream improvements
3-11
003977
Table 3-1
to the NMPC transmission system to accommodate the
electrical output of the project. All subsequent analyses of
project impacts should specifically address the size, location,
and nature of impacts associated with those project
components.
Added information to the project website subsequent to
State of New York issuance of the DEIS has not been adequately noticed or
4 3 Department of Public Davis, Andrew formally issued to involved agencies or to the public.
Service Documents should be circulated with notice of the
appropriate comment period.
Section 2.5.2. The town should consider the size and scale
of the proposed turbines in establishing appropriate setback
State of New York
distances from adjacent properties; a buffer of 75 feet from
adjacent property lines would likely represent the smallest
Service
setback yet specified for any major wind turbine siting project
in NY.
Section 2.5.2. Increased setback distances from the St.
Lawrence River and Lake Ontario, the Seaway Trail Scenic
Byway, historic properties listed or eligible for the State and
State of New York National Register of Historic Places, designated Coastal
4 5 Department of Public Davis, Andrew Zone areas including Significant Coastal Fish and Wildlife
Service Habitats and Local Waterfront Revitalization areas, and
designated Wildlife Management Areas should be seriously
considered and addressed in detail as project planning and
environmental review proceeds.
Section 2.6.3. The Guidelines for Agricultural Mitigation
included in the DEIS are outdated; and the application of
State of New York
agricultural protection and mitigation measures will be
required for implementation in Agricultural Districts by any
Service
Certificate of Public Convenience and Necessity issued by
the PSC.
State of New York Section 2.6.5. Disturbance specifications and impact
4 7 Department of Public Davis, Andrew characterizations would probably significantly under
Service represent impacts and installation methodologies where soil
3-12
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Table 3-1
is limited. Burial depth for cables is likely to encounter
bedrock at many areas; bedrock cutting and additional steps
would be necessary for installation at the recommended
depths in agricultural lands. SDEIS should include a careful
analysis of soils characteristics and limitations, based on field
surveys of soils cover depth for proposed facilities sites.
Where soils depth or wetness limitations influence
consideration of overhead, rather than underground
gathering line placement, those locations should be identified
and analyzed for related effects on land use, visibility , and
co-location with other utility equipment such as overhead
electric lines and telephone cables.
Section 2.6.7. The location of the Project substation is within
or directly adjacent to the Warren Wilson House Historic
District, which warrants consideration of alternative locations
to avoid any adverse effect on the Historic District.
State of New York
Additional information should be provided including a site
plan and profile drawings of the arrangement and types of
Service
equipment proposed for the substation, depiction of its
appearance and the relation to the defining characteristics of
the Historic District. Alternative locations should be and
results reported in a Supplemental DEIS.
Section 2.6.8. The DEIS provides limited information
regarding the proposed overhead transmission line. The
location of facilities should be specified, and alternatives,
including consideration of the costs and benefits of
State of New York
underground location for all or part of the line should be
addressed. Consideration of underground placement should
Service
address the crossing of the Chaumont River, any regulated
wetlands or Wildlife Management Areas, Important Bird
Areas, locations visible from the Seaway Trail Scenic Byway,
Historic Districts, and other locations as appropriate.
State of New York If the abandoned railroad grade from Cape Vincent through
4 10 Davis, Andrew
Department of Public Lyme to near the Chaumont River, analysis of the line and of
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Table 3-1
Service ROW location should address: clearing of forest and shrub
cover; relation of the line location to existing water main
within the RR grade; access limitations where bridge
crossings are insufficient or no longer exist.
Transmission facility information which should be provided
into the SDEIS includes: facility design, including structure
types, height and width; expected electromagnetic and
electric field levels at facility centerline, ROW edge and
State of New York
nearest residence; assessment of clearing needs and
vegetation management specifications; relation of facility
Service
location to other overhead and underground utilities and
other existing infrastructure; ROW access improvement
needs and limitations, such as for stream or wetland crossing
locations.
Section 3.1. SDEIS should include an overlay of the project
facilities on a map of floodplain locations; and analysis of
State of New York floodplain limitations on facility location, design and
4 12 Department of Public Davis, Andrew mitigation needs should be provided. Appropriate design
Service criteria should be specified to assure conformance with
floodplain regulations and any requirements of local or
federal floodplain insurance programs.
Discussion of streams, rivers and lakes, wetlands and
State of New York ecological resources does not include any consideration of
4 13 Department of Public Davis, Andrew several Coastal Zone Significant Fish and Wildlife Habitats
Service within the general project area, and downstream from much
of the proposed project area.
SDEIS should include detailed consideration of: the French
Creek Marsh, St. Lawrence River Shoreline Bays, Wilson
Bay and Marsh, and the avian and waterfowl habitats
State of New York
supported by other Coastal Zone Significant Habitats
including Fox Island - Grenadier Island Shoals, Carlton
Service
island, Point Peninsula, and Point Peninsula Marsh. Habitat
impairment tests should be completed for each of the
Significant areas in the project vicinity.
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Table 3-1
State of New York
A Coastal Zone Consistency Analysis should be included in
the SDEIS
Service
State of New York The Avian and Bat Studies Interim Report (May 2007) should
4 16 Department of Public Davis, Andrew be included in the SDEIS and circulated to involved agencies
Service with appropriate notice to involved agencies and the public.
A single fall season of field observation is not a sufficient
State of New York basis for drawing conclusions regarding impacts, average
4 17 Department of Public Davis, Andrew population characteristics or usage of the project area from
Service birds and bats. Additional seasons of data should be
collected, analyzed, and reported in the SDEIS.
State of New York Characterizations of avian and bat impact should also note
4 18 Department of Public Davis, Andrew recent information reported from other NYS locations,
Service including the Maple Ridge project in Lewis County.
Consideration of the use of the area by migratory species
should include the broader area including Wildlife
State of New York Management Areas and the Coastal Zone Significant
4 19 Department of Public Davis, Andrew Habitats. Study locations were focused on the northerly -
Service westerly portions of the project area, while there are large
areas of wetlands and grassland habitats along the easterly
side of the project area.
Mitigation measures should be replaced with responsible
consideration of mitigation based on results of on-going field
State of New York studies. A commitment to adopting adaptive management
4 20 Department of Public Davis, Andrew principles and detailed plans for facility operation and
Service management, including measures to avoid significant
adverse impacts on bird and bat populations and habitats
should be specified.
The statements that "131 birds known to breed in the Project
area" and "total number of birds varies between 104 and
State of New York
117" should be clarified to reflect the numbers of bird species
encountered. If only 131 individual birds were counted in
Service
surveys of the Project area, then the studies should be
started over during periods when there are actually breeding
3-15
003981
Table 3-1
or migratory populations present.
Survey results reported to date do not address over-
wintering species presence or use patterns even though the
State of New York
DEIS states that "survey results will identify specific species
that winter at the site and their use patterns of the site" and
Service
the project will "minimize impacts to wintering roosting and
foraging birds."
State of New York
The May 2007 Interim Report does not provide page 29 for
review.
Service
The discussion of threatened and endangered species and
Areas of Critical Concern dismisses any potential adverse
impacts, despite the surveys for the listed species not having
State of New York been completed, and despite the preliminary description of
4 24 Department of Public Davis, Andrew the project components and facility locations. More detailed
Service consideration of the endangered Indiana Bat, the
endangered short-eared owls, and other rare, threatened
and endangered species is warranted than in the cursory
discussion in the DEIS.
Recent management activities at the Ashland Flats Wildlife
State of New York
Management Area, including habitat manipulation and
clearing of forest cover for grassland species management,
Service
should be reported and considered in detail.
Section 3.4. Discussion of transportation and traffic impacts
State of New York should be expanded to specifically address the potential to
4 26 Department of Public Davis, Andrew adversely affect traffic on Route 12E, the Seaway Trail
Service designated Scenic Byway and tourism route. Safety
concerns warrant additional consideration.
Section 3.4. Effects of the appearance of the project
State of New York facilities from the Route 12E Seaway Trail Scenic Byway
4 27 Department of Public Davis, Andrew should be considered as a potential effect of facility
Service operations on traffic. Turbines will have the potential to
distract drivers' attention from safe vehicle operation.
4 28 State of New York Davis, Andrew Section 3.4. Consultation with NYSDOT regarding facility
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003982
Table 3-1
Department of Public construction routing and equipment delivery, and facility
Service operational considerations is recommended, and specific
traffic controls and mitigation planning options should be
reported in the SDEIS
Section 3.4. Discussion of potential impacts to local roads
State of New York
should also include potential grading to reduce high spots to
accommodate the extremely long delivery trailers (e.g.,
Service
approach to the proposed substation along Swamp Road)
Section 3.5. The discussion of project area land use does
not acknowledge the significant areas with the project area
towns which are wetland or habitat reserves. These areas
State of New York
should be addressed as natural areas with significance at
local, regional and statewide scales, as acknowledged in the
Service
designations as Wildlife Management Areas, NYS-regulated
wetlands, and Coastal Zone Significant Fish and Wildlife
Habitats.
Section 3.5. The discussion of the Coastal Management
Program is not a complete consideration of the
responsibilities on New York State agencies in consideration
of actions affecting the designated State Coastal Zone.
Responsibilities of the State Agency include consideration of
State of New York
direct effects on coastal resources and potential indirect
effects on resources such as visual effects on coastal areas
Service
and impacts on historic resources located within the coastal
zone; or effects of construction on coastal resources, such as
sedimentation and erosion from a project site on vulnerable
significant habitat locations downstream from the
construction site.
Section 3.5. The DEIS does not include a Coastal Zone
Consistency evaluation. Within this, discussion of the Scenic
State of New York
Quality Policies should address visual effect of the project on
viewpoints within the Coastal Zone; Recreation policies
Service
discussion should address effects of the project on coastal
zone recreational areas and parks, cultural, historic and
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003983
Table 3-1
architectural resources; potential project effects on
Significant Coastal Zone Fish and Wildlife Habitats should be
addressed.
The SDEIS should include a complete Coastal Zone
State of New York
Consistency Review, and should document address the full
range of Coastal Policies as listed in 19 NYCRR Section
Service
600.5
Section 3.7. The discussion of Cultural Resources does not
indicate that the project proposes to site turbines, gathering
lines and the gathering and step-up substation within and
State of New York
within close proximity of Historic Properties listed on the
National Register of Historic Places (i.e., Warren Wilson
Service
House and N. Cocaigne House). Potential direct project
impacts on Historic Properties and District locations should
be conveyed explicitly in the DEIS
The project area of potential effect (APE) should be
State of New York expanded to address the proposed substation
4 35 Department of Public Davis, Andrew interconnection in the town of Lyme, and the route of the
Service proposed 115 kV transmission line from the Cape Vincent
substation to the Lyme substation.
The analysis of project visibility from historic resources
State of New York
should be coordinated with the project visual assessment,
since the tall wind turbines, substations, and overhead will be
Service
prominent visual intrusions into the project area.
Supplemental surveys should include all component
State of New York resources and landscapes within listed, eligible or potentially
4 37 Department of Public Davis, Andrew eligible historic properties or districts, as appropriate, to
Service demonstrate the extent of impacts of the project on those
resources.
Phase 1A and 1B reports should be provided to involved
State of New York
agencies when available, for review and comment. Posting
reports on the project website should not be relied on for
Service
purposes of service on involved agencies.
4 39 State of New York Davis, Andrew The APE should include the viewshed of the proposed
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003984
Table 3-1
Department of Public overhead transmission line and substation facilities.
Service
Section 3.8 and Appendix C. The discussion of Visual
Resources and Community Character does not adequately
address the scale and scope of potential project impacts on
State of New York
the project area, the affected local community, or several
resources of regional or statewide significance. Additional
Service
studies are appropriate to more fully address the potential
project visibility and visual impact on important resource
locations
Section 3.8 and Appendix C. Cumulative assessment of the
project on the Seaway Trail Scenic Byway should be
developed, by a sequential representation of several
viewpoints with direct views toward the project area, as
would be experienced by touring visitors traveling along the
Route 12E corridor. The VIA does include representations
from 3 or 4 locations along the Scenic Byway, but the
State of New York presentation does not provide an orientation to the various
4 41 Department of Public Davis, Andrew points, and does not provide consideration of the various
Service cultural, historic, recreational, and scenic resources which
cumulatively comprise the setting and experience of traveling
along the Seaway Trail. The analysis of impacts should
consider corridor management principles and guidelines for
the Seaway Trail, and provide additional consideration to
minimizing the project impacts due to the close proximity of
many of the proposed turbines to this scenic resource of
statewide significance.
Section 3.8 and Appendix C. The DEIS does not address in
State of New York
a comprehensive manner the relation of the Seaway Trail
Scenic Byway to the landscape and the various resources
Service
which contribute to the corridor adjacent to the Trail.
State of New York Section 3.8 and Appendix C. The VIA does not address in a
4 43 Department of Public Davis, Andrew meaningful way the potential project visibility from the
Service designated Coastal Zone areas, such as from within the St.
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003985
Table 3-1
Lawrence River, or from Lake Ontario. Additional
simulations should be presented which represent project
view simulations from both middle-ground and fore-ground
distances from the Coastal Zone water surface, representing
views across locations with both developed and undeveloped
shorelines, to represent the nature of views experienced by
recreational boaters. Demonstration of the consistency of
the proposed project with relevant Coastal Zone Policies for
scenic and visual resources should be provided in a SDEIS.
Section 3.8 and Appendix C. Wider field of view simulations
should be used; viewpoints represented in the VIA are
limited to less than what is experienced at many locations in
State of New York the project landscape. Additional viewpoint and simulation
4 44 Department of Public Davis, Andrew views should be created from locations such as the vicinity of
Service the Thousand Islands High School oriented southerly from
County Route 9. The current photograph is taken from a
topographically inferior position, which limits views of
background distance zone turbine positions.
The discussion of project impact mitigation should consider
project alternative layout and project arrangement, which
State of New York would remove turbines from the most prominent locations
4 45 Department of Public Davis, Andrew near the Coastal Zone areas, the Seaway Trail Scenic
Service Byway, Historic Properties listed or eligible for listing on the
State or National Register of Historic Places, and other
resources of scenic and aesthetic importance to the State.
Section 3.13. The document should include discussion and
details of security measures including limitations on access
State of New York to electrical equipment and substations, including
4 46 Department of Public Davis, Andrew specifications for station fencing and access gates; any
Service proposed security lighting at substation locations measures
to mark underground facility locations and participate in the
Dig Safely New York facilities protection system.
State of New York Section 4.0. The discussion of Cumulative and Growth
4 47 Davis, Andrew
Department of Public Inducing Impacts should address the proposed Wolfe Island
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003986
Table 3-1
Service Wind Project. Additional information, including the
Environmental Overview Report and additional details should
be reviewed and assessed in a cumulative impact
assessment, especially addressing visual resources and
potential for "visual saturation" of the regional coastal
landscape, and cumulative effects on significant habitats,
migratory wildlife and rare, threatened or endangered
species populations.
Cumulative assessment of the combined impacts of the St.
State of New York Lawrence Windpower and the BP Alternatives project should
4 48 Department of Public Davis, Andrew be addressed. Visual impacts, wildlife habitat effects,
Service construction impacts, traffic impacts, and historic resource
impacts should be addressed in a meaningful way.
The range of Coastal Zone resources should be carefully
considered in identifying cumulative project impacts.
State of New York
Coordinated planning for electrical output and
interconnecting facilities should be required to avoid multiple
Service
or duplicative facilities, and repeated construction impacts of
multiple transmission and substation facilities.
Section 7.0. The Alternatives analysis should be significantly
expanded to address project alternatives, including
State of New York
alternative electrical interconnection facilities, alternative
project arrangement and increased separation and setback
Service
from the broad range of significant resources within the study
area.
Section 7.0 The alternatives analysis should address routing
alternatives for the 115 kV transmission line, including facility
State of New York routes within or adjacent to the abandoned railroad ROW;
4 51 Department of Public Davis, Andrew and alternative designs including underground placement of
Service the 115 kV line especially near sensitive resources such as
Wildlife Management Areas, the Chaumont River, and
locations within view of the Seaway Trail Scenic Byway.
State of New York The Alternatives Analysis and the DEIS in general should
4 52 Davis, Andrew
Department of Public convey the essential nature of the project area as containing
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003987
Table 3-1
Service a concentration of inter-related natural and cultural resources
which should be considered cumulatively, rather than
singularly by topic heading.
The Alternatives Analysis should be expanded to present
State of New York detailed assessments and mitigation opportunities resulting
4 53 Department of Public Davis, Andrew from a project design and layout, which increases setback
Service distances from the multiple sensitive resources in and
surrounding the project layout.
The developer should be required to give serious
consideration to a range of alternative facility arrangements
to enable the advancing of a project design that is
State of New York responsive to the many significant resources of State interest
4 54 Department of Public Davis, Andrew in the project area. This should address a reduced project
Service footprint; increased setbacks from shoreline areas, the
Seaway Trail, visual and cultural resources, Significant
Coastal Fish and Wildlife Habitats, WMA and Important Bird
Areas; and remove facilities from NRHP listed properties.
DEC recommends that mitigation measures be discussed,
including plans to provide for adequate control of stormwater
runoff near any identified karst features. The SDEIS should
describe procedures for conducting detailed subsurface
5 1 NYSDEC Nasca, Jack investigations at turbine site locations. The range of actions
to be taken if karst features are identified should be
specified, including further investigation, turbine re-location,
determination of the effects of blasting, or engineering
construction controls.
DEC recommends that a detailed construction plan be
developed to incorporate stringent containment of
5 2 NYSDEC Nasca, Jack construction-related runoff (e.g., installation of silt/stormwater
fencing to prevent surface runoff from entering uncontrolled
into karst inlets, etc...)
DEC recommends that the SDEIS discuss the role of an
5 3 NYSDEC Nasca, Jack environmental monitor, qualified to work in a karst
environment, related to pre-construction surveys and
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Table 3-1
construction activities that involve excavation to bedrock or
are located in proximity to an identified karst feature.
Figure 3 should be updated to include both the spring and
fall radar sampling points
The dates on which no sampling occurred should be
included in the text, along with the reason.
Flight direction, movements, as well as distance of each bird
from the observer should be provided on a map and
table/graph for all birds, including those seen outside of an
800 meter radius from the observation point.
6 4 NYSDEC Gary, Brianna Headings for Table 1 seem to be missing or misaligned.
Information in Table 2 should be broken down by season
(spring 2006, 2007, and fall 2006). Combining the
6 5 NYSDEC Gary, Brianna percentages of birds flying within and below the rotor swept
area among all seasons could mask times of the year when
birds may be at greater risk.
The overall raptor passage rate at the St. Lawrence site is
generally lower than established hawk watches in New York,
particularly in the spring. However, when comparing this
proposed wind development site to others in the state, the
6 6 NYSDEC Gary, Brianna number of birds per observer hours reported is the highest of
15 spring reports and the second highest of 18 fall reports. It
should also be noted that despite these greater passage
rates, the raptor migration surveys at this project were
conducted with fewer hours of effort than at many other sites.
Based on a comparison of multiple reports from across the
state, the potential for raptor-turbine collisions at the
proposed St. Lawrence wind project may be higher than at
6 7 NYSDEC Gary, Brianna other proposed wind projects in New York. A post-
construction mortality monitoring plan will help determine
impacts to raptors and mitigation measures appropriate to
the level of impact.
No BBS points were located in the southern portion of the
project area where approximately 20 of the 96 turbines are
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Table 3-1
proposed.
Survey points also appear to be lacking in the northern
portion of the project area near some larger patches of
forest, and 13 proposed turbines. Conducting surveys in
these areas would provide a baseline estimate of what
forest-dependant species may be using the project area prior
to construction. A post-construction BBS would then provide
information on whether fragmentation has a negative effect
on breeding forest birds.
Surveys were conducted slightly later in the year than is
typical for BBS, and may have missed or had lower numbers
6 10 NYSDEC Gary, Brianna of some species that would have been more readily detected
during the peak of breeding season (e.g., Henslowe’s
sparrows, upland sandpipers, and short-eared owls)
The sponsor should keep in mind that the proposed project
area lies entirely within the FWS St. Lawrence Wetland
Management District Focus Area of the St. Lawrence Valley
Wetland and Grassland Management District. The NYS
6 11 NYSDEC Gary, Brianna Grassland Bird Landowner Incentive Program has also
received a number of applications from western Jefferson
County. The presence of these programs in the same area
as the project emphasizes the importance of grassland and
wetland habitat in the region.
The dates that each driving and static survey took place, the
times surveys were actually conducted, the weather
conditions during the surveys, and the number and species
of birds seen at each observation point and along driving
6 12 NYSDEC Gary, Brianna routes should be included in the report. Two state-
threatened bald eagles, 36 state-threatened northern
harriers, and 120 rough-legged hawks are reported, but it
cannot be determined from the tables provided when, where
or under what conditions these birds were seen.
Although no state-endangered short-eared owls were
observed by West, Inc. during the nine days of survey
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003990
Table 3-1
between November 5, 2006 and March 1, 2007, this species
is known to winter in the area of the proposed project in fairly
large numbers. Surveys conducted on 57 days between July
13, 2006 and March 31, 2007 found 69 owls at 5 roost sites
on 9 survey days between November and March within and
around the project area. DEC staff has also captured and
radio tagged 2 individual owls during winter 2006-2007 and
tracked their movements around the Cape Vincent area.
For the Indiana bat habitat surveys, raptor migration surveys
focusing on golden eagles, and wintering raptor surveys
targeting short-eared owls, rough-legged hawks, northern
harriers, and eagles: a scope of each work plan should be
6 14 NYSDEC Gary, Brianna submitted for review, and consultation should be made with
DEC and USFWS prior to the start of these surveys, or as
soon as possible if fall studies have already commenced, to
determine appropriate methods, duration, and intensity of
survey effort for fall and winter 2007-2008.
A revised report containing the requested information that is
lacking in the current report should be submitted to the DEC
and USFWS as soon as possible. A work plan for monitoring
post-construction mortality and displacement should be
developed prior to the construction of any turbines, and will
be a condition of any permit issued by DEC.
Township of Cape Comments regarding the importance of setbacks and safety
Vincent Engineer as it relates to ice throw
Concern over placement of the overhead transmission line.
What is the immediate vulnerability to the waterline and the
Township of Cape
7 2 Carr, Paul, Ph.D., P.E. impact on long-term maintenance if the OH was to be put in
Vincent Engineer
proximity to the Development Authority of the North Country
Right-of-Way for the waterline, the old RR bed?
If the transmission line is to follow the RR bed, what
Township of Cape
7 3 Carr, Paul, Ph.D., P.E. environmental issues arise as it passes through the Ashland
Vincent Engineer
Game Management area?
7 4 Township of Cape Carr, Paul, Ph.D., P.E. Have the Villages of Chaumont, Dexter, Brownville, and Glen
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Table 3-1
Vincent Engineer Park agreed to have a 115 KV or possibly a 345 KV
overhead power line straddling their single source for a vital
community service?
As the line approaches the Village of Chaumont, has there
Township of Cape been a proper notification of those effected residents?
Vincent Engineer Comment expresses concern about the opportunity for
residents to comment on OH route.
Photos in the Visual Impact Study are misleading and
Township of Cape
7 6 Carr, Paul, Ph.D., P.E. visually inaccurate representations of post-project conditions
Vincent Engineer
because of perspective.
Sound level analysis is inadequate and potentially
misleading. The ambient sound level in the community is not
45 dBA as used in the analysis, but closer to 30 as
Township of Cape measured by the commenter. If one were to use 45 dBA as
Vincent Engineer the ambient noise and allow a "non-interfering" increase of
5dBA from the Project, the noise increase would actually be
"objectionable" bordering on "intolerable" according to DEC
policy.
Concern for high visibility of the OH lines; disruption of the
Ashland Flats Wildlife Management Area; and devaluation of
8 1 Harris, Michael
land values for properties which will be visually impacted by
the project.
The Stone Building Appreciation Society supports the intent
in the Cape Vincent Zoning Law to protect historic properties
Stone Building
9 1 Uhlig, Robert and locations while allowing development and agrees with
Appreciation Society
the letter by D. Timothy J. Abel of the Jefferson County
Historical Society on this subject matter.
The nocturnal radar study was only available for public
10 1 Old Bird, Inc. Evans, William R. review 2 weeks before the public comment period on the
DEIS was over. The comment period should be extended.
The project turbines are proposed to be up to 425 feet high
but bird migration information is only provided for heights
under 410 ft above ground level. Bird/bat migration altitude
information should be provided at 25-m resolution up to 200
3-26
003992
Table 3-1
m above ground level.
Nightly data on passage rate below turbine height is not
presented. Providing a seasonal average for targets below
125 m is not helpful for assessing flying animal impact. Were
observations concentrated in certain months when the main
bat migration was occurring? Data should be presented in
tabular format with actual figures. West Inc. should follow
the format of Woodlot Alternatives in presenting their radar
data.
The Project would be located 800 m from the St. Lawrence
River and the radar study site was apparently only about 500
m from the shoreline, outside the wind project area. The
radar site would ideally be located 1500 m from the
shoreline, as previously stated by the consultant. Placement
of the radar unit 1 km closer leads to the fact that about one
third of the radar detection area was located over the St.
Lawrence River and less than half of their radar coverage
was over the proposed wind project site (based on West's
method of determining passage rate in the horizontal mode)
Comparing horizontal radar data from the West radar study
to those of other New York radar studies is problematic b/c
no radar studies in inland NYS includes such a large over-
water proportion in their sampling region. Based on his own
10 5 Old Bird, Inc. Evans, William R. research, there is a strong likelihood that more small
songbird migration in the fall occurs inland along the St.
Lawrence River than over the water. This would especially
be true on evenings when winds are below 10 mph or if
winds were from the east.
West's data suggests that the St. Lawrence plays a role in
channeling nocturnal migration but their analysis does not
10 6 Old Bird, Inc. Evans, William R. provide information on the details of this channeling. Is it
occurring across the whole St. Lawrence Valley? Only at low
altitudes?
10 7 Old Bird, Inc. Evans, William R. Radar data from over the St. Lawrence River, its shoreline,
3-27
003993
Table 3-1
and inland areas of coverage are summed together to
produce a single passage rate for the whole radar survey
area. Thus, the question of migration corridor along the
south shore of the St. Lawrence is not addressed as was
suggested it would be in the Study Plan.
It would be useful to a 500 m representation of flying target
density as one moves away from the St. Lawrence River up
to 2.0 km from the River. Also, how do these migration
density dynamics vary with weather?
Concurrent use of image intensifier methodology can be
10 9 Old Bird, Inc. Evans, William R. used to help understand the proportion of bats and birds in
the flying animal mix revealed by the radar.
11 1 LeTendre, Gerard Multiple concerns regarding birds
11 2 LeTendre, Gerard Multiple concerns regarding bats
11 3 LeTendre, Gerard Concern regarding the exact numbers and sizes of turbines
Threatened and endangered species such as Blanding's
turtle should be identified, quantified, and protected.
Wetland studies have not been presented; wetlands should
be avoided during and after construction.
Towers and blades should be painted to not attract birds and
bats
Sellers should be compensated for declining property values
associated with the St. Lawrence Wind Farm
Multiple concerns regarding placement of turbines in
11 8 LeTendre, Gerard proximity to Cape Vincent and in proximity to non-
participating landowners
11 9 LeTendre, Gerard All transmission lines should be underground
11 9 LeTendre, Gerard Concern for sound levels
Request for mitigation measures in the event that
12 1 Falcon, Mary construction problems are encountered when blasting and
agricultural runoff enters local wells and streams.
Bird and bat studies are incomplete and should be extended
12 2 Falcon, Mary
for at least the same number of years as the wind studies.
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Table 3-1
Clarification needed on what a bat fatality monitoring
12 3 Falcon, Mary
program will involve
Multiple concerns regarding comment periods for
12 4 Falcon, Mary
supplemental reports
It is believed that the old railway outside the Village of Cape
Vincent traverses an Indian burial ground. Has approval
12 5 Falcon, Mary
been sought from the Native American Tribes to dig in this
area?
12 6 Falcon, Mary All transmission lines should be underground
12 7 Falcon, Mary Will the Project augment local electricity supply?
Visual Impact photos should include photo simulations from
12 8 Falcon, Mary
the St. Lawrence River.
The Project will be visible from Wolfe Island as well as from
12 9 Falcon, Mary the Lake and River. Have residents of Wolfe Island been
contacted?
The alternatives analysis is misleading. All alternatives have
12 10 Falcon, Mary
not been explored.
12 11 Falcon, Mary Flicker supplemental is based on erroneous data
Concerns about the effects of noise on health. Further
13 1 Falcon, Spencer, MD studies on noise should be performed and short and long-
term health effect studies should be conducted
14 1 Chase, Hester Will forests be protected from being clear-cut?
USDA soil maps show Cape Vincent as very low construction
14 2 Chase, Hester
possibility. Why will turbine towers be different?
Question about compatibility of Project and Town's
14 3 Chase, Hester
Comprehensive Plan.
Does the DEC intend to change laws or guidelines to make it
14 4 Chase, Hester
possible for the towers to be built?
Question about impacts to bridges, buildings, roads, Indian
14 5 Chase, Hester
sites, rock walls, and historic places.
14 6 Chase, Hester Question about ice throw, setbacks, and Highway Dept. input
Questions regarding noise, noise studies and mitigation for
14 7 Chase, Hester
noise
3-29
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Table 3-1
14 8 Chase, Hester Concern regarding profits to participating wind companies
14 9 Chase, Hester Question regarding efficiency of turbines and alternatives
14 10 Chase, Hester Concerns about diligence of bird / bat studies
14 11 Chase, Hester Concern about the identification of Indiana Bats
14 12 Chase, Hester Source of concrete and gravel for roads
14 13 Chase, Hester Question regarding worker crew lodging
Concern about effect of Project on Important Bird Habitat on
14 14 Chase, Hester
Pleasant Valley Road.
Concern about landowner rights (Refers to BP Cape Vincent
14 15 Chase, Hester
Wind Power Project)
14 16 Chase, Hester Concern about shadow flicker on health
14 17 Chase, Hester Questions regarding decommissioning
Gaudette, Richard and Letter opposed to wind farm citing safety, visual impacts, and
15 1
Jan environmental impacts
Petras, Leigh and Request to move transmission lines through Chaumont
16 1
James several miles to the north to avoid visual impact
Concerns regarding shortcomings of DEIS and proposed
mitigation measures
Copy of letter submitted to the NYS Historic Preservation
Office regarding potential effects of Project on historic
preservation properties and the Historic District; copy of
response from the NYS Historic Preservation Office.
Save the River and
Caddick, Jennifer and A thorough review of the collective impacts of wind
Aaron Vogel development projects in the region should be performed
Trust
Save the River and
19 2 1000 Islands Land Comment on importance of pre-construction studies
Aaron Vogel
Trust
Concern that the SEQR process has not been followed to its
Save the River and fullest extent. DEIS fails to show what the significant
19 3 1000 Islands Land adverse environmental impacts might be and does not
Aaron Vogel
Trust contain information necessary to evaluate project
alternatives
3-30
003996
Table 3-1
Save the River and
Caddick, Jennifer and Comment on importance of agency involvement in decision
Aaron Vogel making processes.
Trust
Save the River and
19 5 1000 Islands Land The DEIS must include studies of at least 3 years in duration
Aaron Vogel
Trust
Save the River and
19 6 1000 Islands Land The DEIS does not address wetland impacts
Aaron Vogel
Trust
Save the River and Post-construction impacts of storm water run off from new
19 7 1000 Islands Land roads and other turbine maintenance facilities must be
Aaron Vogel
Trust examined.
Save the River and
19 8 1000 Islands Land A cost-benefit analysis of the project must be considered
Aaron Vogel
Trust
20 1 Merchant, Jerry Letter opposing wind farm
Avian and Bat Study Plan is only a protocol for undertaking a
Menter, Rudin and one year avian and bat impact study in the future; a 3-year
Trivelpiece, P.C. preconstruction study should be conducted; other
comments/concerns
Menter, Rudin and Wetlands have not been delineated; impacts to wetlands
Trivelpiece, P.C. have not been assessed
Menter, Rudin and A geotechnical investigation and SWPPP should be part of
Trivelpiece, P.C. the DEIS
A transportation and traffic plan should be created as an
appendix of the DEIS to address the traffic-related impacts to
Menter, Rudin and
21 4 Fucillo, Thomas J. the Town of Cape Vincent resulting from the array of heavy
Trivelpiece, P.C.
vehicles that will deliver turbine components to the Project
site.
A sediment and erosion control plan and a Project
Menter, Rudin and Stormwater Pollution Prevention Plan should be developed
Trivelpiece, P.C. to ensure that impacts associated with construction area
properly mitigated.
3-31
003997
Table 3-1
SLW should be directed by the Planning Board to utilize the
Menter, Rudin and Ranking Protocol (USFWS guidelines - enclosed) to
Trivelpiece, P.C. determine whether the proposed site is appropriate for
development of a wind energy facility.
Cumulative impacts of SLW and proposed wind projects in
Menter, Rudin and
21 7 Fucillo, Thomas J. close proximity should be addressed: community character,
Trivelpiece, P.C.
wildlife, connection to the existing power grid.
Menter, Rudin and
21 8 Fucillo, Thomas J. Comments/concerns about the Sound Level Report
Trivelpiece, P.C.
Menter, Rudin and
21 9 Fucillo, Thomas J. Comments/concerns about the Visual Resource Survey
Trivelpiece, P.C.
Menter, Rudin and The DEIS does not identify any mechanism to avoid or
Trivelpiece, P.C. mitigate for shadow flicker.
Menter, Rudin and The DEIS fails to properly assess the environmental impacts
Trivelpiece, P.C. of constructing the substation and power lines.
The DEIS should be modified to determine what portions of
Menter, Rudin and the electrical interconnection line will be aboveground, what
Trivelpiece, P.C. portions will be belowground, and assess the impacts of
such aboveground installation.
Financial assurances should be secured to fund the
Menter, Rudin and decommissioning of the Project in the event that the
Trivelpiece, P.C. Applicant is no longer financially viable or refuses to properly
remove the facilities.
Menter, Rudin and Enclosure: USFWS Service Interim Guidance on Avoiding
Trivelpiece, P.C. and Minimizing Wildlife Impacts from Wind Turbines
The DEIS does not adequately reference the Town's
Menter, Rudin and
22 1 Fucillo, Thomas J. Comprehensive Plan, or the fact that this Project appears to
Trivelpiece, P.C.
directly conflict it.
The DEIS should contain a meaningful discussion of
Menter, Rudin and
22 2 Fucillo, Thomas J. alternatives, not just the conclusory assertions that it
Trivelpiece, P.C.
presently contains.
23 1 Faulknham, R. Dennis The DEIS did not include a Shadow Impact Assessment
23 2 Faulknham, R. Dennis Large segment of the Project will be highly visible from many
3-32
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Table 3-1
parts of Cape Vincent. Request for one mile setbacks to
reduce visual impacts.
Given the scale of the Project, it is likely that visual impacts
may extend far beyond the 5-mile APE
The DEIS does not discuss how long following completion of
site restoration the contractor will stay to evaluate areas
24 1 Faulknham, R. Dennis disturbed during construction and assure that agricultural
and wetland functions and values are restored and
maintained over the long term.
Public road improvement wetland study must be included in
the EIS
Wetlands analysis in DEIS should be refined to apply full
range of potential impact criteria to proposed construction
24 3 Faulknham, R. Dennis activity in determination of total area of permanent impact;
not just those areas proposed for permanent placement of
fill.
Ambient decibel levels used in the DEIS are higher than
25 1 Jury, Charles
observed
26 1 Vail, Alan Question about the "no action" alternative
Question about impact of Project on town and village
26 2 Vail, Alan
budgets
Comment on financial assurances for payment, performance
and maintenance bonding. If the project is not bonded,
26 3 Vail, Alan neither the towns nor the leaseholders have a guarantee that
promise will be kept, construction, completed, payments
made, maintenance done, and dismantling completed.
Most DEISs include results of a Job and Economic
Development Impact Model. None was referenced in DEIS
26 4 Vail, Alan
so it appears that the Socioeconomic Section was based on
Assumptions
Comment on direct financial benefit for town/village power
26 5 Vail, Alan
users
26 6 Vail, Alan The Decommissioning Plan needs to be completed
3-33
003999
Table 3-1
26 7 Vail, Alan Comment on the alternative of downsizing the Project
Concern for residents' needs and wants conflicting with
27 1 Gormel, Thomas
Project
28 1 Gormel, Thomas
maintenance
29 1 Gormel, Thomas Multiple questions regarding bird and bat studies
30 1 Gormel, Thomas Concern regarding setbacks
Concerns regarding mitigation of views from historic
31 1 Gormel, Thomas
properties
Concerns about the overall cost of the Project and how that
32 1 Gormel, Thomas
will affect town and village budgets
Multiple questions regarding archeological studies and Indian
33 1 Gormel, Joyce
burial grounds.
Questions regarding impact of Project on herons and other
34 1 Gormel, Joyce
recreationally viewed avian species
Multiple concerns regarding effect of Project on community
35 1 Gormel, Joyce
tax base and income
Multiple questions regarding effect of Project on fishing and
revenues from fishing: recreational fishing important part of
the allure of the town and fisherman support local
businesses. Who compensates local businesses if wind farm
36 1 Gormel, Joyce development results in a loss of revenue? Construction
would occur during fishing season and could represent an
access conflict. How will change in revue be measured if
fisherman and recreation boaters go elsewhere after the
towers are constructed?
Questions regarding road maintenance and cost of road
37 1 Gormel, Joyce
maintenance
maintenance
38 2 Zovistoski, Mary Concern for safety of children
3-34
004000
Table 3-1
38 4 Zovistoski, Mary The assumptions used to complete the DEIS are not listed
Comments requesting more detail on layout of substation,
O&M facility, and construction staging area.
Comment regarding representation of the Project's area of
38 6 Zovistoski, Mary impact as an alternative to GIS maps, line of sight cross
sections, and photo simulations.
38 7 Zovistoski, Mary Multiple comments regarding alternatives
38 8 Zovistoski, Mary Comment regarding decommissioning
38 9 Zovistoski, Mary Mitigation strategies pertaining to visual impacts are limited
The DEIS states that in agricultural areas, electrical cables
39 3 Hirschey, Urban C. will be buried at a possible depth of 48 inches; however, the
NYSDAM states a minimum burial depth of 48 inches.
What are the "other" subcomponents of the wind farm not
listed in the Executive Summary?
Concern for effect of Project on Fort Drum soldiers and
families. Projected increase in rental costs, based on a
surge in construction workers and the Fort Drum buildup will
place soldiers and their families at a financial disadvantage.
40 4 Hirschey, Urban C. Concern for safety of children
Comments regarding layout of substation, O&M facility, and
construction staging area
A real-time, 3-D computerized simulation of the project's area
of impact should be prepared to assess visual impacts
instead of GIS maps, line of sight cross sections, and photo
simulations.
3-35
004001
Table 3-1
40 7 Hirschey, Urban C. Multiple comments regarding alternatives
40 8 Hirschey, Urban C. Comment regarding decommissioning
40 9 Hirschey, Urban C. Mitigation strategies pertaining to visual impacts are limited
Comment regarding necessity of environmental monitor in
areas where karst features may occur
The DEIS needs to state that the maximum megawatt
capacity of this project is 136 megawatts, and that if turbines
larger than 1.5 megawatts are used, the number of turbines
will be reduced accordingly.
Photos in the Visual Impact Study are misleading because of
41 2 Hirschey, Urban C. turbine positioning and inaccurate representations of turbine
size
The viewshed analysis range should be enlarged to 10 miles
since land is relatively flat and there are many clear days
No field surveys regarding migratory birds, bats, and other
species were included in the DEIS. No information regarding
the location of flight corridors was depicted on the study
maps.
Section 3.4.3 should include an appropriate strategy for road
restoration
Section 3.5.1.2 and 3.5.1.5 should discuss the
43 3 Hirschey, Urban C. Comprehensive Plan adopted by the town and how the
project will fit into the goals set forth in the plan.
In evaluating if turbines prevent future development, Section
3.5.2.3 should discuss examples of future residential
development within 5 miles of turbines in comparison to
similar areas where they were not constructed.
Page 3-50 should include turbine accidents statistics along
43 5 Hirschey, Urban C. with the required emergency services used to respond.
Towns should be reimbursed for these services.
Page 3-62 should include performance of a balloon study on
a calm day
43 7 Hirschey, Urban C. Multiple comments regarding ambient noise and noise
3-36
004002
Table 3-1
increases due to turbines
Section 3.11.1.1 should discuss the effect of the project on
43 8 Hirschey, Urban C. property values in this area of high scenic value and tourism
potential.
Receptors of shadow flicker should be notified and
compensated
Section 6.0 should discuss the predicted effective capacity of
the project compared to the nameplate capacity.
Comments regarding declining property values as a result of
wind projects. Enclosure not attached.
Questions regarding medical issues, safety issues, and a fire
45 1 Boss, Mark
prevention and control plan
45 2 Boss, Mark Questions regarding road modifications and layout
45 3 Boss, Mark
45 4 Boss, Mark
Bracket, Mr. and Mrs. Letter expressing concern that EIS and other studies may be
46 1
Montgomery biased
Audubon New York requests that the DEIS perform
47 1 Audubon New York Liner, Jillian M. adequate pre-construction surveys to determine bird usage
and assess potential risk.
Comments regarding importance of historic properties and
suggestions for setbacks
48 2 Bragdon, Brooks Enclosure: Correspondence from NYS OPRHP
Enclosure: Letter to Editor from Brooks Bragdon regarding
49 1 Bragdon, Brooks turbine setbacks. Enclosure of SLW visual simulation not
attached.
Gregory, Maureen
50 1 Multiple comments regarding historic properties
Wiley
50 2 Gregory, Maureen Multiple questions regarding planting trees as mitigation for
3-37
004003
Table 3-1
Wiley visual impact
Gregory, Maureen
51 1 Multiple questions about archeological studies.
Wiley
Multiple questions about financial benefits and effect of
Project on Town and Village budgets (What is overall
estimated cost of project? What is estimated cost per
Gregory, Maureen
52 1 kilowatt/hour for first year, first five years, first ten years?
Wiley
How will residents other than lease-holders benefit? How will
the town’s budget be affected in one year, five years, ten
years?)
Gregory, Maureen Questions regarding impact of Project on herons and other
53 1
Wiley recreationally viewed avian species
Gregory, Maureen Multiple concerns regarding existing and new roads and road
54 1
Wiley maintenance
Gregory, Maureen Questions regarding road maintenance and cost of road
55 1
Wiley maintenance
Gregory, Maureen
56 1 Multiple questions regarding bird and bat studies
Wiley
Gregory, Maureen Multiple questions regarding effect of Project on fishing and
57 1
Wiley revenues from fishing
Gregory, Maureen Concern for residents' needs and wants conflicting with
58 1
Wiley Project
Gregory, Maureen Multiple concerns regarding effect of Project on community
59 1
Wiley tax base and income
Multiple comments and recommendations regarding
60 1 Doull, Melodee
representation and mitigation of viewshed
Comments and concerns about underlying geologic material
61 1 Macura, Daniel
and resulting impacts
Comments and concerns about effect of Project on
61 2 Macura, Daniel
groundwater
Moehs, Charles, MD, Concerns about "wind power syndrome" and
62 1
MPH recommendations on how to avoid this
63 1 Duehkind, Winnie Is it possible to set up some sort of screen to project birds
3-38
004004
Table 3-1
and bats?
64 1 Walker, Tom and Mabel Concern about adequacy of studies for wildlife
Comment on assessment of land as industrial as opposed to
64 2 Walker, Tom and Mabel
agricultural
The DEIS fails to evaluate impacts on Federal and State
65 1 Brown, Thomas listed threatened and endangered species, including the
Indiana Bat, the Short Eared Owl, and the Black Tern.
The DEIS should include an assessment to determine if
65 2 Brown, Thomas ozone levels would increase due to the collective effect of
the multiple proposed wind farms in this general area
Concern about declining property values and suggestion of
property stabilization program
Section 3.13.1.2 on possibility of ice shed is misleading
because of selective quoting
Crossby, William and
68 1 Comment on the importance of performing thorough studies
Barbara
Jefferson County Comments on the importance of reviewing all historical
69 1 Historical Society, Abel, Timothy J., PhD resource inventory and assessment research prior to making
Watertown, NY a final decision on the Project.
70 1 LaPlante, J.O Urging of pre-construction bird and wildlife studies
Article: Watertown Enclosure: Article: "Study says wind power fatal to birds and
70 2
Daily Times bats" from the Watertown Daily Times 5/31/2007
Article: Los Angeles Enclosure: Article: "Wind power planning called for" from the
70 3
Times Los Angeles Times
Article: Watertown Daily Enclosure: Article: "Blades a draw for bats, birds" from the
70 4
Times Times Washington
Article: Source Enclosure: Article: "Wind farms, Study sees need for more
70 5
Unknown guidance"
Concern regarding public input and the addressing of
comments
Multiple comments regarding historic sites, viewshed
analysis, and mitigation for visual impacts
72 1 Hludzenski, Kathryn A. Question regarding turbine stability in underlying geologic
3-39
004005
Table 3-1
substrate
73 1 Freislich, Michele L. Concerns about health effects from Project
Letter expressing concern about town relationships and
74 1 Simpson, Carol
asking Town Planning Board to slow down decision-making
Section 2.2 What is the third alternative procedural pathway
75 1 Gormel, Joyce
available to the Lead Agency?
75 2 Gormel, Joyce
Section 3.12.1.1 and 3.13.1.1 are both titled "Microwave
75 3 Gormel, Joyce Analysis". Which section needs to address this topic and
what is missing from the other section?
75 4 Gormel, Joyce Section 3.13.2.4 Multiple questions regarding fire hazards
Section 1.6 and 2-9 contain the same table titled "Permits
75 5 Gormel, Joyce and Approvals for the St. Lawrence Wind Energy Project"
with different verbiage. Which is correct?
Request for more detailed information on PILOT payment
75 6 Gormel, Joyce
intentions
75 7 Gormel, Joyce Request for more detailed information on decommissioning
Request for more detailed information on bird and bat
75 8 Gormel, Joyce
studies
Multiple comments and recommendations regarding safety
76 1 Pundt, Art plans, emergency services training, and additional potential
hazards
The DEIS lacks detail on decommissioning and should be
77 1 Gormel, Thomas
modified to reflect a more formal plan
Concerns with DEIS claim that only a portion of the study
78 1 Levy, Ann E. area will have visibility of wind turbines within the five mile
radius
78 2 Levy, Ann E. Concerns with effectiveness of mitigation for visual impact
There is no mention of the Dodge Bay Cemetery in the
79 1 Boss, Sarah F. Historical Architecture Resource Investigation section of the
DEIS
79 2 Boss, Sarah F. As the zoning law does not permit structures more than 35
3-40
004006
Table 3-1
feet high, the wind towers do not qualify in the Township
79 3 Boss, Sarah F. The deadline for public input should be extended
Concern that wind power does not eliminate pollutants and
79 4 Boss, Sarah F.
greenhouse gases during the production of electricity
79 5 Boss, Sarah F. Transmission line locations have not been specified
79 6 Boss, Sarah F. Potential impacts to wetlands have not been provided
Potential impacts to karst topography have not been
79 7 Boss, Sarah F.
provided
Potential impacts to avian and bat species have not been
79 8 Boss, Sarah F.
provided
The model and megawatt of the windmills still need to be
79 9 Boss, Sarah F.
determined
The DEIS needs to specify who will be responsible for road
79 11 Boss, Sarah F. improvements and reconstruction necessitated by
construction vehicles
79 12 Boss, Sarah F. Concern for turbine blades crossing property lines
Urging of an analysis of impacts to property values and the
region's economy
Concern that turbines are located too close to the Thousand
Islands Junior/Senior High School; concern for ice throw
Questions regarding how the Project will affect ducks and
80 1 Brown, Thomas
geese and how these impacts will be assessed
Inquiry as to when supplemental bird and bat studies will be
80 2 Brown, Thomas
available
Pressly & Associates,
81 1 Pressly, Nicholas Wetland impacts were not avoided to the extent practicable
Inc., Cherry Valley, NY
Pressly & Associates, Construction sites should be placed far enough away from
Inc., Cherry Valley, NY potential receptors to reduce effects of storm water runoff
Pressly & Associates, A field survey of existing wetlands and associated biota
Inc., Cherry Valley, NY should be included in the DEIS
81 4 Pressly & Associates, Pressly, Nicholas Potential long-term impacts resulting from increased surface
3-41
004007
Table 3-1
Inc., Cherry Valley, NY flow due to road construction should be evaluated. This
should include impacts to wildlife resulting from increased
volume, turbidity, and chemicals used for road deicing or
dust suppression.
It is likely that groundwater will be impacted by direct
Pressly & Associates, infiltration of turbid water and dissolved concrete into the
Inc., Cherry Valley, NY bedrock aquifer. Potential impacts to groundwater should be
evaluated in the DEIS.
81 6 Curriculum Vitae Enclosure: CV of Nicholas Pressly
82 1 Cuda, Kenneth Request for removal of Turbine #22
Concerns expressed over proximity of Project to the Cape
Vincent Historic District
The Project does not accommodate the stated purposes of
the Cape Vincent Zoning Law
Cape Vincent Zoning
83 3 Enclosure: Page 1 of the Cape Vincent Zoning Law
Law
Bouchard, Gerry and Will the wind companies be held responsible for correcting
84 1
Michelle any interference with TV and radio reception?
85 1 Cuda, Kenneth Request for greater setbacks from the St. Lawrence River
Letter from Brooks Bragdon to the NY State Dept of Parks
addressing impacts to the St Lawrence River, Historic
District, and NR Listed properties; and requesting increased
setbacks and smaller turbines
Proposal for the formation of a review board to evaluate
Project
Article: Pylon cancer fears put £7bn blight on house prices
(5/1/2006)(1st page only)
Article: Leukemia risk 70pc higher for children close to power
lines 6/8/2005)
Internet Article: Daily-
90 1 Article: An ill wind…wind farms as a blight on the landscape
John.com
91 1 Gormel, Joyce Multiple concerns about PILOT payments
92 1 Moehs, Charles, MD, Discussion of Wind Turbine Syndrome and request for
3-42
004008
Table 3-1
MPH increased setbacks from the Thousand Island Junior/Senior
High School
Concern that the number and placement of turbines will
93 1 Brown, Thomas transform the landscape into an industrial complex. Request
for fewer turbines and greater setbacks from the shore.
Letter to Editor: Letter to Editor: Noisy turbines disrupt sleep, devalue
94 1
Watertown Daily Times property
Multiple questions and comments regarding cumulative
95 1 Gormel, Thomas impacts of wind projects on wildlife, resources, migratory
birds, and transmission of electricity to the national grid.
A website has been created whereby all comments can be
96 1 Levy, Ann E.
aired objectively (www.stlawrencewind.org)
Comment on the term "appropriate" in the Executive
Summary when referring to buffers from property lines
97 1 Gormel, Thomas
nearby residences, roads, and other nearby visually sensitive
areas.
97 2 Gormel, Thomas Mitigation for visual impacts needs to be more specific
The DEIS is incomplete; the public hearing and comment
Wind Power Ethics period should be stayed until sufficient information has been
Group developed to provide for a legitimate public review and
comment. Enclosure: not attached
99 1 Wiley, Karen Concerns about suffering summer tourism
Concern regarding the potential density of turbines in the
99 2 Wiley, Karen
region
99 3 Wiley, Karen Concern for declining property values
Concern that East End Park will not be as attractive with
99 4 Wiley, Karen
visible wind towers; effect on hunters and snowmobilers
99 5 Wiley, Karen Concern regarding objectivity of studies performed
Does St. Lawrence Wind Power have a good safety record
99 6 Wiley, Karen
regarding the construction and operation of towers.
Urging of town officials to do research regarding the impact
99 7 Wiley, Karen
of noise and light from the towers on residents and wildlife.
100 1 Graf, David General comments.
3-43
004009
Table 3-1
General questions about the size of the Project, visual
101 1 Callery, Judith Anne impacts, tax implications, impacts to avian species, ice
throws, TV reception interference, property values, and noise
Concern for tourism, visual impacts; call for zoning laws
102 1 Kemmis, Richard J. specific to wind turbines and increased setback from the St.
Lawrence River
103 1 Brown, Thomas Objection to the St. Lawrence Wind Farm DEIS
Brown, Thomas; R. Letter to the NYSDEC and USFWS expressing concerns
Dennis Faulknham, regarding the lack of bird and bat studies in the DEIS,
104 1
Gerard LeTendre, and impacts to migrating birds, and calling for 3-year long studies
Clifford Schneider for assessing impacts on bird and bat resources.
Haskins, Janet and
105 1 Concern for ill health effects from Project
James
The NYSDEC's Assessing and Mitigation Noise Impacts
(AMNI, 2001) should not be quoted as a standard; there is
no current statewide standard to govern and guide wind farm
development in New York State.
Article: Utica Observer Enclosure: Article: Wind Turbines could force family to leave
106 2
Dispatch Fairfield home (Utica Observer Dispatch - March 8, 2007)
Pre- and post-construction photographic simulations are
107 1 Brooks, Colin
deceptive due to perspective.
The only people who stand to benefit from the construction of
107 2 Brooks, Colin wind turbines are those who are leasing their land to the
company
There is a conflict of interest between members of the board
107 3 Brooks, Colin and St. Lawrence Windpower LLC; some individuals have a
financial/personal interest in the development of the Project
Objection to the size, shadow effect, flicker effect and noise
108 1 Bragdon, Brooks of the turbines; call for setbacks to protect the character of
the community. Listed enclosures not attached.
Multiple comments on inadequacy of specific avian studies.
109 1 Smith, Gerald
Please refer to comment letter.
110 1 Docteur, David H. Multiple questions on effect of Project on short and long term
3-44
004010
Table 3-1
human health
110 2 Docteur, David H. How do sweeping shadows affect fish?
Enclosure: e-mail concerning a press release about Vibro-
110 3 E-mail
Acoustic Disease,
To comply with Cape Vincent's wind turbine noise guideline,
a greater setback distance is needed. A setback of 3,457
feet would recognize the importance of night-time
background levels, include the 5 dBA above background
guideline, and use the same method as AES-Acciona uses
to calculate wind turbine noise spread loss. It would also
give non-participating landowners leverage in negotiating
with AES-Acciona.
Post-operational background noise surveys should be
performed to ensure that AES-Acciona conforms to their own
predictions and that their wind turbines comply with the
Planning Board's noise guideline.
AES-Acciona should be required to shut down wind turbines
111 3 Schneider, Clifford P. when winds at ground level diminish to turbine cut-in speeds
(e.g., 5 m/s)
The Planning and Town Boards should be more concerned
with individual property loss of non-participants than tower
removal costs. Bonding should provide these residents with
protection from property loss.
111 5 Schneider, Clifford P. Forty-one questions regarding sound level report
111 6 Schneider, Clifford P. Eleven questions regarding the flicker assessment
111 7 Schneider, Clifford P. Twenty-four questions regarding avian studies
111 8 Schneider, Clifford P. Twelve questions regarding the Visual Assessment Report
Enclosure: Response letter from Jack Nasca to Clifford
111 9 Letter: NYSDEC.
Schneider regarding comments dated 3/12/2007
The project definition should include an evaluation of the
Bernier, Carr, and
Cape Vincent Planning bedrock geology, as well as in the EIS. The level of detail
112 1 Associates (Dimmick,
Board needs to be commensurate with the stage of environmental
Kris)
review. This analysis should also identify potential impacts
3-45
004011
Table 3-1
and mitigating measures that will be implemented during the
site and foundation design. Remote sensing might also be
helpful.
The planning board requires that SLW redo the map showing
tower locations to conform to the following criteria: A. No
tower is to be closer than 1,000 feet to a non-participating
property line; B. No tower is to be closer than 1,250 feet to a
112 2 non-participating residence; C. No tower is to be closer than
Board Members
750 feet to a participating residence; D. No tower is to be
closer than 1,500 feet to the Village of Cape Vincent line.
The new map is to be submitted to the Planning Board and
to all of the locations where the DEIS is located.
SLW will respond to all comments submitted by the N.Y.
State DEC, USFWS, NY Public Service Commission, NY Ag
Cape Vincent Planning Planning Board and Markets, and NW State Historic Preservation Office that
112 3
Board Members have been submitted during the public comment period
ending 6/15/2007. SLW will submit a copy of this
correspondence to the Planning Board.
SLW is to indicate on their new map that location of the
transmission lines inside and outside of the project area.
The map will need to show whether the lines are above
ground or below ground. If below ground, the depths of the
lines will need to be indicated. The map will need to show
line capacity, size of lines, height of lines, material of lines,
and any other pertinent specifics. The map will also have to
Cape Vincent Planning Planning Board show the specifics of any towers and the tower placement.
112 4
Board Members This new map will also have to be submitted to the Planning
Board and to all of the locations where the DEIS is located.
There is to be only one transmission line leaving the wind
turbine project from the Town of Cape Vincent. Therefore,
SLW is to communicate with BP to the effect that both
companies must work together on the transmission line.
SLW is to send this correspondence to BP via certified return
receipt mail. A copy of the SLW letter, certified receipt, and
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any response by BP are to be submitted to the Planning
Board.
A revised visual impact study will need to be done based on
the new project map. This revised visual impact study is to
include at least 2 locations from the waters of Lake Ontario
inland and 3 locations from the waters of the St. Lawrence
112 5 river inland. There is to be an additional location taken from
Board Members
the water in the vicinity of the Tibbets Point Lighthouse
focusing downriver. Another such location is to be taken
from the Cedar Point State Park area while on the water
looking back toward the Tibbets Point Lighthouse.
Cape Vincent Planning Planning Board Further explanation of the visual study methodology will need
112 6
Board Members to be submitted to substantiate the study.
Background ambient sound levels will need to be done to
accurately measure the entire project and the Village of
Cape Vincent. The background ambient sound
measurements submitted need to be located so as to include
112 7 commercial and pleasure watercraft on the river as well.
Board Members
These background ambient sound levels are to include
measurements taken both during daytime and nighttime
hours. Study methodology will need to be submitted to
substantiate the study.
Cape Vincent Planning Planning Board A revised shadow flicker study map is toe be prepared using
112 8
Board Members the new project map and submitted accordingly.
Cape Vincent Planning Planning Board Wetland delineation studies need to be done and wetland
112 9
Board Members locations shown on the project map.
SLW will need to meet with the Cape Vincent Fire Dept. and
112 10 work out an emergency fire and ambulance response plan.
Board Members
This will need to be submitted accordingly.
Cape Vincent Planning Planning Board A traffic/transportation plan will need to be created and
112 11
Board Members submitted accordingly.
A stormwater pollution prevention plan and soil erosion
112 12 control plan will need to be prepared for the appropriate
Board Members
agency approval as part of the site plan review approval
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process. All necessary permits will need to be in place prior
to any construction.
Enough distance to avoid shadow flicker affecting people
113 1 Boss, Sally
with migraines.
113 2a Byrne, John Requesting that the night-time lighting be mitigated
Requesting the avoidance of excessive trees and shrubbery
113 2b Byrne, John
removal.
113 3 Docteur, David Minimize shadow flicker, 3,000 setback for noise.
Wind Power Ethics Public comment period after environmental studies are
Group complete?
113 5 Falcon, Mary Contingency plans for water run-off problems from project.
What are the cumulative impacts of all of these projects on
the residents of our community? How will all proposed wind
projects in the area impact migratory birds? How SLW does
113 6 Gormel, Thomas
proposes to mitigate the cumulative impact of all of these
projects on the transmission of electricity to the National
Grid.
113 7 Hambrose, Harold Inaccurate visual analysis of the area.
Questions: is the removal of turbines only to be paid at the
end of their useful life, clear definition of "useful life", who
113 8 Hambrose, Johanna
determines “useful life", removal of underground collection
system, damage to visual beauty of area.
113 9 Hanson, Rollin V Setbacks needed to protect character, history of area.
113 10 Henchy, Harold Do not overlook quality of life.
113 11 Hirschey, Sally
zone.
113 12a Hirschey, Urban C.
zone, outdated, suggests 5 mile setback from lake and river.
113 12b Hirschey, Urban C. Accuracy of the project efficiency needed.
Who provides compensation for loss of property value,
113 13 Hludzenski, Ed damage to water table? Who is liable for property, personal
damage from ice throw, study on infrasound needed.
113 14 Hludzenski, Ed Leukemia possible near power lines.
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Decommissioning of turbines at no cost to town, absolutely
113 15a Metzger, Don
no advertising.
113 15b Metzger, Don Requesting that the night-time lighting be minimized.
Restoring damage from installation process, and repairs at
113 16a Reinhart, Marianna
no cost to town
Where will the O&M building be placed in relation to town
113 16b Reinhart, Marianna
and turbines?
Three year Avian / Bat study, unknown credentials of visual
113 17a Schneider, Clifford P. analyst, use accurate noise instruments for measuring
sound.
Night-time noise studies needed, more description of
113 17b Schneider, Clifford P.
character of noise needed
113 18 Simpson, Carol Relocate turbines to accommodate the wildlife in the area.
Siting of turbines must be done in an environmentally
113 19 Nasca, Jack
sensitive fashion.
1
Source 113 represents oral comments received during March 24, 2007 Public Hearing.
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The USFWS has reviewed the SDEIS and may provide further comments
1 1 USFWS Stilwell, David pursuant to the MBTA, BGEPA, CWA, or the Fish and Wildlife Coordination
Act, as applicable. Further consultation pursuant to the ESA is warranted
and is ongoing.
The additional data gathered by the project sponsor has answered some of
1 2 USFWS Stilwell, David our questions and concerns. However, we believe that insufficient
information still exists to predict potential impacts to wildlife.
Our previous comments on the project's ability to reduce greenhouse gases
1 3 USFWS Stilwell, David were not adequately addressed. We requested data which shows that the
project will offset emissions produced at fossil fuel burning plants, but none
was provided.
According to the SDEIS, there will be five meteorological towers eventually
located in the project area and all will by guyed for support. As stated
1 4 USFWS Stilwell, David before, we recommend that no guy wires should be used on the towers as
they have been known to be flight hazards for wildlife. Instead, monopole or
self-supporting towers should be installed.
Transmission line overhead crossing of the Chaumont River should be
accomplished using directional drilling under the river to limit impacts to
wildlife using the river corridor. Also, we commend the project sponsor for
1 5 USFWS Stilwell, David minimizing habitat impacts by choosing a route that primarily follows an
abandoned railroad and water line right-of-way. We recommend that tree
clearing along the ROW to reduce risk of damage to OH lines be kept to a
minimum amount necessary.
Based on wetland delineation report, it appears Turbine 3 is in wetland W-
1 6 USFWS Stilwell, David 22; however, the permanent impact associated with this area is listed as a
road impact on Table 3-6. Determine if this is an error. We recommend that
no turbines be placed in wetlands.
We recommend project design should be reviewed to eliminate clearing of
1 7 USFWS Stilwell, David 0.34 acres of forested wetland, if feasible. While compensatory mitigation
plans have not been finalized, project sponsor is not proposing mitigation
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for clearing of forested wetlands. We consider that this impact is
permanent, and accordingly, mitigation should be provided.
The SDEIS, p3-47, indicates that breeding bats are not highly susceptible
to mortality from wind turbines. We caution that insufficient data has been
collected at wind energy projects in the eastern US to draw conclusions
1 8 USFWS Stilwell, David about the effects of turbines on local populations. However, it is true that
most bat fatalities have been found during the fall migratory period,
primarily because that is when turbine areas have been searched for
carcasses.
The SDEIS mentions White Nose Syndrome (WNS) as an affliction killing
bats but does not include a discussion of the cumulative effects of WNS
and other sources of mortality on bats, such as wind turbines. While the text
acknowledges that little brown bats have been most affected by WNS, it
1 9 USFWS Stilwell, David does not mention that this species was also among the most killed at
nearby Maple Ridge wind project last year. Since little brown bats are the
most numerous species of bat found in the project area, the text should
provide an analysis of what the long term implications of the project are for
this species.
Adaptive management should be listed as a method for monitoring and
mitigating impacts to bats (and birds). Specifically, the project sponsor
should commit to adjusting project operations, such as adjusting turbine
1 10 USFWS Stilwell, David cut-in speeds during low wind periods to reduce bat fatalities. This is the
period when most bats are killed as documented by recent research (Arnett
2005). A study at the Meyersdale wind project in PA recently determined
that bat mortality can be reduced by more than half if the cut-in speeds are
adjusted (Arnett 2009).
The project area, as noted in the DEIS on p3-22, is within a concentrated
migratory pathway, has attractive stopover habitat, and has unusually high
1 11 USFWS Stilwell, David concentrations of birds and, therefore risk for collision may be higher than
at other projects. The proximity to wetlands, Lake Ontario, and St.
Lawrence River attract waterfowl, waterbirds, and shorebirds to the area
during the breeding and migratory periods (Northern Ecological Associates,
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1994). We find that insufficient data were collected at the project site to
determine the spatial and temporal use of the project airspace by flying
animals and to adequately conduct a risk assessment and predict wildlife
mortality for this project. One year of surveys is not enough and we
recommend another year of study data to adequately determine avian use
in project area and the associated risk from project operation.
The SDEIS has documented the presence of bald eagles and golden
eagles in the project area. The bald eagle was removed from the Federal
endangered list and is no longer protected under the ESA; bald eagles
1 12 USFWS Stilwell, David remain on the NYS list as a threatened species and are also protected by
the federal MBTA and BGEPA. The USFWS is currently finalizing
regulations related to eagle take. We suggest the project sponsors review
that information when available. We may make additional recommendations
regarding these species.
The USFWS is currently coordinating with project team and USACE
regarding effects of the project on the federally-listed Indiana bat. The
project sponsor is preparing a Biological Assessment and we reserve the
1 13 USFWS Stilwell, David right to provide additional comments on the Federally-listed species until
the receipt of a complete BA. We will follow the consultation process (CFR
Part 402) for next steps (Biological Opinion, determination of effects,
recommendations and necessary conservation measures, etc).
In summary, we find that the SDEIS provides some of the information we
requested previously, but other data are missing. We maintain our view that
the report does not contain adequate information regarding potential
impacts of the project on wildlife, and additional environmental review is
necessary. Significant data is lacking for migrating, breeding, and wintering
1 14 USFWS Stilwell, David birds, as well as bats. Importantly, more information is needed on State-
and Federally-listed species use of the project area and how the
construction and operation of the project will affect these species. The
USFWS typically recommends that these studies be conducted over 3
years of project operation and be conducted at all times of the year and
under varied weather conditions.
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Our previous recommendation to mitigate potential impacts to bats was not
included in the SDEIS. Again, we recommend turbines should not have a
cut-in speed of less than 6 meters per second, and operation should be
curtailed between July 15 and September 15 for 5 hours after sunset. Also,
1 15 USFWS Stilwell, David the project approval should be conditioned upon an adaptive management
plan to address wildlife mortality as a result of turbine operations. A
construction environmental monitoring program should be implemented for
this project. We suggest that the program include a training component for
workers on how to identify and handle injured or dead wildlife.
The SDEIS Section 2.4, page 2-4, states that the project is seeking an
easement from DEC to cross approximately 1.6 miles of the Ashland WMA
with the 115 kV transmission line. Use of the WMA for this purpose requires
authorization by the New York State Legislature and requires DEC
approval. The DEC is not aware of any pending legislative proposals to
2 1 NYSDEC Tomasik, Stephen provide this authorization. Because the timeframe for receipt of
authorization by the state legislature is not able to be determined, an
alternate route may be necessary for the project to move forward in a timely
manner, which may necessitate revision of SDEIS Section 7, Alternatives
Analysis. If the transmission line exceeds 10 miles, DPS approval would be
required.
Define the procedures proposed to cross the Chaumont River with the
overhead transmission line. The Chaumont River is a Navigable Body of
Water, as defined by 6 NYCRR Part 608. Workers/contractors in the river
2 2 NYSDEC Tomasik, Stephen could create a health and safety issue for the workers and the recreational
public. Appropriate measures to ensure the health and safety of the
workers/contractors and recreational public while crossing a navigable body
need to be addressed.
SDEIS Section 4 does not include discussion of the potential for use of the
proposed transmission line by the BP Cape Vincent Wind Power Project,
2 3 NYSDEC Tomasik, Stephen which would be located adjacent to the SLWF and would need to deliver
power to the same substation in the Town of Lyme. This analysis should be
provided.
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SDEIS Section 2.6.5, page 2-16, states that although not currently
anticipated, portions of the interconnect could be installed above-ground
when burial would not be economically feasible or could result in significant
2 4 NYSDEC Tomasik, Stephen environmental impacts. More clearly define what situations would meet
these criteria to provide rationale for change. This section includes typical
specifications for installation of underground collection lines. Provide specs
for OH lines also in order that potential impacts, particularly visual, can be
analyzed.
Section 3.1.3.3 includes an outline of proposed karst and geotechnical
investigations, and the role of the environmental monitor is included in
2 5 NYSDEC Tomasik, Stephen Section 3.1.3.4. While this largely conforms to the DEC's previous
recommendations in the June 15, 2007 letter, it is important that results be
made available to assess the adequacy of proposed mitigation measures
identified in Section 3.2.1.3.
A draft SWPPP should have been included in the SDEIS that provides
specifications for best management practices to control contaminants
based on results of the karst and geotechnical investigations. Specifically
lacking is any mention of controlled concrete washout areas at turbine
2 6 NYSDEC Tomasik, Stephen foundation sites, which is imported for preventing concrete slurry from
contaminating groundwater through karst features or surface waters and
wetlands. DEC may require that the SWPPP prepared for the SPDES
permit be reviewed by DEC staff prior to implementation to ensure that
plans for site characterization, project construction, and construction
monitoring have been included and adequately address these concerns.
DEC is concerned that the short-eared owl was not sampled in any of the
bird surveys conducted. In contrast to SDEIS Section 3.3.6.2, DEC has
documented a wild, although cyclic, distribution of the species within the
2 7 NYSDEC Tomasik, Stephen general project area during winter months (see attached maps). Additional
surveys of short-eared owl are recommended both pre-construction and
post-construction to be sure this species' distribution and abundance is
accurately documented. SDEIS should also include 1) short-eared own in
its list of bird species know to inhabit the area 2) short-eared owl in its
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wintering bird discussion and 3) short-eared owl listed in Table 1-1.
In reference to Appendix E, page 3, the site visit with the DEC staff
2 8 NYSDEC Tomasik, Stephen mentioned is not valid part of survey/study effort and was not only to
identify roosting locations. DEC requests that this characterization in the
report be corrected.
Based on the information in the SDEIS, it is difficult to predict that raptors
would not have a high risk for collision due to either low recorded numbers
or flight height outside of the rotor swept zone because 1) the numbers
recorded at the Project Area were higher than most other proposed wind
energy projects and 2) there is not enough information collected at the
2 9 NYSDEC Tomasik, Stephen Project Site regarding use by wintering or migrating raptors, especially
during fall migration to make such a conclusion. It is known that the Project
Area lies within one of the most important raptor wintering grounds in New
York State. A more thorough analysis of raptor migration within the Project
Area is needed to support the conclusions made in the SDEIS.
Mortality rates at other wind farms, such as Maple Ridge, should not be
2 10 NYSDEC Tomasik, Stephen used to predict SLWF numbers because avian use of the SLWF Project
Area is higher than all other sites.
SDEIS Section 2.4 states that the total of built project facilities will occupy a
land area of approximately 60 acres. The SDEIS also quantifies impact to
habitat loss by providing the acreage of grassland (41 acres) and second
growth forest (17 acres) that will be affected. However, calculating the total
of temporary and permanent impacts, 14.4 miles of access road
development at 39 feet mean width, 53 tower work spaces at 1.6 acres
2 11 NYSDEC Tomasik, Stephen each, the result is approximately 150 acres of disturbed land area, much of
which may represent existing wildlife habitat. Further discussion is needed
regarding plans for restoration of temporarily affect areas, including the
length of time for restoration (e.g. replaced forest canopy will require much
longer to replace than grassland). Also, any areas that will need to remain
as buffers (e.g., mowed areas along permanent roads) should be calculated
as permanent impacts if these activities represent restoration of viable
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wildlife habitat.
2 12 NYSDEC Tomasik, Stephen Revise Table 1-1 of the SDEIS to include consultation with the DEC
regarding T&E species, in addition to consultation with USFWS.
While it is recognized that project development and operation will result in
the perpetuation of some grassland habitat (that might otherwise be lost to
succession if farm were to cease) the direct loss of 150 acres of habitat, at
least on a temporary basis, combined with associated habitat loss due to
avoidance or displacement, at least relative to listed species, will need to be
2 13 NYSDEC Tomasik, Stephen minimized and perhaps mitigated. Pending further clarification and
consultation with DEC with regard to direct and indirect habitat loss due to
construction of this project, the presence of both state endangered and
threatened species utilizing the Project Area may require the issuance of an
Article 11 permit from DEC. The principal condition of this permit would be
to ensure that habitat take impacts, if not avoided, will be mitigated in such
a way as to achieve a "net conservation benefit."
The breeding bird survey conducted for the project according to USGS BBS
protocol are not sufficient; the BBS protocol is designed to estimate trend
data over the long-term, not to fully characterize bird species' occupancy of
2 14 NYSDEC Tomasik, Stephen an area. Due to the presence of significant grassland, endangered, and
threatened species know to be in the area, an additional breeding bird
survey should be conducted according to DEC's Guidelines for Conducting
Bird and Bat Studies at Commercial Wind Energy Facilities.
More complete data need to be obtained in order to support the conclusion
that construction and operation of the proposed Project will likely result in
2 15 NYSDEC Tomasik, Stephen minor, temporary impacts to breeding birds. The Project could contribute to
an increase in the fragmentation of habitat that may result in birds being
displaced from their nesting areas.
Conclusion: The SDEIS and its related additional information with regards
to pre-construction bird and bat studies substantially adds to what was
2 16 NYSDEC Tomasik, Stephen offered in the DEIS. However, several of the related studies, including the
Raptor Migration and Breeding Bird Surveys are still lacking in scope in
comparison to the most recent DEC guidelines for bird and bat pre-
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construction studies.
Conclusion: Another concern is that the SDEIS continually cites other
studies of wind projects or data from surveys that are not ecologically
2 17 NYSDEC Tomasik, Stephen similar or even related to the Project Area. The SLWF is located in a region
that has significant grassland bird, raptor, and waterfowl concentration
areas and should not be compared to other potential wind energy projects
that do not support the same natural resources.
DEC agrees that post-construction studies are very important and should
be included as part of the project's required mitigation measures. The
2 18 NYSDEC Tomasik, Stephen SDEIS should further state that based on the results of these studies,
adjustments to the Project's operational configuration and or time-table may
be necessary to affect avoidance or minimization of the take of birds or
bats, with listed species receiving the highest consideration.
In order to adequately assess the potential impacts to the Project Area's
threatened and endangered species, the Project needs to fully characterize
2 19 NYSDEC Tomasik, Stephen seasonal use of the area by these species. As submitted, the SDEIS is
inadequate to allow a thorough evaluation of the potential impacts to these
species.
Subsection 3.1.1.4, p3-13, states that a majority of the area is level and the
drainage pattern is generally in the direction of small streams and creeks
(e.g. Kent's Creek, Fox Creek, Shower Creek, Super Creek, Three Mile
Creek), which discharge directly into the St. Lawrence River. There are a
number of inaccuracies in this description: (1) Kent's Creek (aka Mud
Creek) flows directly into Mud Bay, which is an embayment of Lake Ontario
2 20 NYSDEC Tomasik, Stephen that is approximately 4 miles from the beginning of the St. Lawrence River;
(2) Fox Creek flows directly into Lake Ontario approximately 5.5 miles away
from the beginning of the St. Lawrence River; (3) Shower Creek and Super
Creek do not exist within the Project Area. Shaver Creek, Soper Creek, and
Three Mile Creek flow into Three Mile Bay which flows into Chaumont Bay
and then directly into Lake Ontario approximately 12.2 miles from the
beginning of the St. Lawrence River.
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Subsection 3.2.2, p3-23, stats that 36 mapped surface water bodies occur
within the Project layout. These include Scotch Brook, Chaumont River,
Kent's Creek, Shaver Creek, Three Mile Creek, Soper Creek and 30
unnamed tributaries. These surface waters are perennial and located within
the Saint Lawrence River Basin. There are a number of inaccuracies in this
description: (1) Scotch Brook is the only one from the listed streams on
page 3-23 that actually flows directly into the St. Lawrence River; (2) Kent's
Creek (aka Mud Creek) flows directly into Mud Bay, which is an embayment
of Lake Ontario that is approximately 4 miles from the beginning of the St.
Lawrence River; (3) Shaver Creek, Soper Creek, and Three Mile Creek flow
into Three Mile Bay which flows into Chaumont Bay and then directly into
Lake Ontario approximately 12.2 miles away from the beginning of the St.
Lawrence River.
It is difficult to assess this SDEIS with a highly inaccurate description of the

surface water geography as it relates to the Project Area.
Subsection 3.1.2 states that the proposed project, once built, could
potentially cause a minor alteration to existing drainage patterns (pages 3-
13 to 3-14). A detailed investigation designed to evaluation the potential for
2 21 NYSDEC Tomasik, Stephen long-term alterations to existing drainage patterns should be prepared,
noting that any alterations to the existing drainage patterns, even perceived
minor ones, could have serious effects on current land use patterns,
homes, and the environment.
The methods noted in the SDEIS to avoid impacts to Blanding's turtles
(Subsection 3.3.7) are insufficient to adequately protect Blanding's turtles,
particularly from loss of nesting habitat by turbines and mortality caused by
2 22 NYSDEC Tomasik, Stephen vehicles on roads constructed in nesting areas. Nesting areas are typically
found outside of wetlands. In addition, minimization of impacts to nesting
Blanding's turtles may need to include the restriction of construction
activities to outside of the nesting season.
2 23 NYSDEC Tomasik, Stephen SDEIS Section 2.6.10. DEC recommends that the environmental monitor
be empowered to order correction of acts that violate environmental
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regulations and permit requirements, and order the cessation of
construction activities until such corrective action has occurred. The monitor
should also provide regular reports to appropriate involved and interested
agencies, including DEC staff responsible for permitting and technical
review of agency permits. A staff of monitors should be available to provide
coverage at all times the construction activities occur; one monitor may not
be enough to cover extended hours. These provisions will be requirements
on any DEC permits that may be necessary for project construction.
As currently proposed, the project is not substantially located within the
boundaries of the New York State coastal zone. However, its proximate
location and the nature of the proposed activity suggest that coastal effects
3 1 NYSDOS Zappieri, Jeff may be likely. Should further authorization from other federal regulatory
agencies be required or should the USACE decide that the proposed
project would not meet the criteria for a permit issued under the NWP
program, DOS should be notified to determine if a consistency review is
necessary.
The proposed project incorporates transmission lines that traverse portions
of New York's Coastal Zone. Transmission line right-of-way maintenance
activities should not adversely affect any coastal resources. In part, this
3 2 NYSDOS Zappieri, Jeff may be accomplished through a reduced reliance on herbicides, the
establishment of buffer areas adjacent to the Chaumont River, and careful
use of best management practices designed to lessen stormwater impacts
both pre- and post-construction.
Section 2.8.1.4 states that at decommissioning, the transmission line poles
will be sawn flush with the ground unless the "appropriate governing
3 3 NYSDOS Zappieri, Jeff authority" determines that the environmental damage will outweigh the
benefits of removal. This "appropriate governing agency" should be
identified along with suspected environmental damage that would negate
the benefits of removal.
In the Section 2.8.3 discussion of decommissioning, it may be useful to
3 4 NYSDOS Zappieri, Jeff require a performance bond or dedicated fund to be established to ensure
the complete decommissioning of the project.
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Section 3.2.3.3 should include that all wetland mitigation should be located
within the same sub-watershed as the original disturbed wetland.
Additionally, specific parameters should be established that define what
3 5 NYSDOS Zappieri, Jeff would constitute a successfully established wetland and at what point
guaranteed remedial action would occur, should success parameters not be
met. It may be advantageous to guarantee proper wetland establishment
through bonding or other financial security mechanisms.
Curtailment between July and September should be considered to reduce
impacts to birds and bats. A recent study at the Casselman Wind Power
Project in Pennsylvania indicated that these impacts may be reduced by
3 6 NYSDOS Zappieri, Jeff raising the minimum "cut-in" wind speed necessary to begin turning the
wind turbine. An investigation into the viability of such a procedural shift
may indicate that the benefits derived warrant its implementation. Similarly,
this procedure may be useful to curtail potential effects on the proximate
Significant Coastal Fish and Wildlife Habitats.
Avian use may be affected at the seven Significant Coastal Fish and
Wildlife Habitats (SCFWH) located within 10 miles of the SLWF. Specific
pre-construction characterization of avian uses of the SCFWHs should be
3 7 NYSDOS Zappieri, Jeff required along with sufficient post construction monitoring to quantify any
potential effects. Appropriate provisions for operating procedure adaptation
should be included in the SDEIS if impacts at the SCFWHs become
evident. These and all other wildlife monitoring data should be presented to
all regulatory agencies and made available for public inspection.
Statements within the last paragraph of Section 3.3.7.2 appear to contradict
each other by stating that the project may cause abandonment of an
3 8 NYSDOS Zappieri, Jeff Indiana Bat maternal colony, effects will not be large enough to affect the
maternal colony, and that direct impacts may lead to the loss of the
maternal colony. This language should be clarified to indicate the
paragraph's true intent.
Section 3.4 states that several road closures may be necessary to enable
3 9 NYSDOS Zappieri, Jeff delivery of construction equipment and materials to the project site and that
some routes may necessitate road improvements. These routes should be
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planned to ensure that the public's access to the coast is not hindered.
Additionally, the potential may exist to improve the public's access to the
coast by ensuring that necessary road upgrades are constructed in a way
that would relieve traffic congestion or otherwise improve the public's travel
to and from the coast.
Section 3.4.3 discusses mitigation measures to repair highway
infrastructure that may be damaged during construction of the proposed
3 10 NYSDOS Zappieri, Jeff project. It may be advantageous to ensure that proper financial assurance
measures are in place to provide for adequate repair. Roads likely
susceptible to damage also likely provide the public access to the coast and
as such should be maintained in an appropriate fashion.
Section 3.5.1.3 discusses potentially applicable New York State coastal
policies. However, the analysis appears to consider only a small part of the
project's transmission line. Given the project's proximity to the coastal zone,
3 11 NYSDOS Zappieri, Jeff a full analysis of coastal policy should be included in the SDEIS that
considers the potential effects of the entire project on New York Coastal
Resources. Such an analysis should consider all applicable New York State
coastal policies and any applicable policies of the Village of Cape Vincent
Local Water Revitalization Plan.
3 12 NYSDOS Zappieri, Jeff Include the DOS on the distribution list for all future monitoring reports
regarding this proposed project.
The facilities proposed for the SLWF do not trigger Public Service
4 1 NYSDPS Davis, Andrew Commission jurisdiction (nameplate capacity above 80MW, 115 kV line
over 10 miles, or 125 kV over 1 mile).
The PSC encourages wind energy developers to adopt procedures and
practices to minimize conflicts and interruptions of utility services during
wind project construction and operations. The developer should coordinate
4 2 NYSDPS Davis, Andrew with local utility service providers to avoid construction interference of
electric, gas, cable, water, and telecommunications services providers. The
developer is encouraged to join Dig Safely New York UFPO program during
project development to identify proposed locations of underground facilities
in relation to other underground infrastructure and avoid inadvertent
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interruptions during excavation. Section 3.6.2.1 does not address
underground utility structures and equipment which may be affected by
road widening or access road construction. Widening roads at intersections
for temporary construction access by oversize vehicles has the potential to
affect buried infrastructure. Project planning and coordination with utilities
should address any underground facilities which may be encountered for
these improvements. Alternative design or access layout adjustments may
be necessary to avoid conflicts with infrastructure.
Discussion of transmission line construction at Section 3.6.2.1 is cursory.
Construction will involve repeated access for clearing, grading, and access
4 3 NYSDPS Davis, Andrew improvement, excavation, pole placement, installation of hardware and
conductors and conductor tensioning. Maintenance of transmission facilities
and vegetation along the right-of-way will require permanent and ongoing
periodic access to the length of the line.
Above-ground poles should be marked with owner identification information
and numbering of poles, pursuant to PSC regulations. DEIS Section 3.6.3
does not address pole marking requirements. Pole marking is important for
4 4 NYSDPS Davis, Andrew notification of the facility operators in event of damages to or emergency
responses involving downed or damaged service lines. Without appropriate
facility marking information, the likely perception in the community will be to
contact the local electric company if a pole is damaged in events such as
automobile accidents, or construction accidents or line encounters.
DPS staff notes that the use of the former railroad corridor for siting a 115
kV transmission line will require access for construction and facility O&M.
The old rail right-of-way includes washed out bridge and culvert crossings
at waterways, which preclude through-access, and which may make
4 5 NYSDPS Davis, Andrew construction access problematic. Access routes should be identified, and
constraints accounted for in project planning and permitting. In addition, the
co-location of electric transmission lines along the corridor of the existing
water lines may have the potential to result in induced voltages on the
water pipeline. Step and touch voltage levels should be estimated, and any
grounding necessary to avoid induced voltages which could induce an
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electric shock in someone touching an above-ground water line facility
(such as a hydrant) should be implemented.
Discussion of facility security at Section 3.13.3.2.7 should indicate that clear
4 6 NYSDPS Davis, Andrew zone around the project substation may need to be enlarged beyond the 10
feet cited, to preclude danger tree contact with station infrastructure and
perimeter fencing.
Attached are standard questions and information requests which DPS
poses to major wind project developers. Some of these items are
4 7 NYSDPS Davis, Andrew addressed in the discussion of impacts and mitigation as described in the
SDEIS; however there are additional details which may be relevant for
consideration of the SLWF.
Visual impacts discussion does not address the Seaway Trail-Cape Vincent
Bicycle Look trail (map attached), much of which is open land through
portions of the Project Area. An analysis of visual impacts to the trail,
including photo simulations, should be provided. Some consideration of
4 8 NYSDPS Davis, Andrew cumulative effects of wind energy on state parks and recreation facilities in
the Jefferson County area is warranted. The number of wind turbines which
will be visible from park locations should be noted for the Wolfe Island, St.
Lawrence, Cape Vincent, and Hounsfield Wind projects is like to be
significant. DPS notes that the Wolfe Island wind turbines are visible across
the low-relief areas of the region at distances exceeding 12 miles.
1. Provide a list of engineering codes, standards, guidelines, and practices
that the company intends to conform with when planning, designing,
4 9 NYSDPS Davis, Andrew constructing, operating and maintaining the wind turbines, electrical
collection system, substation, transmission line, interconnection, and
associated buildings and structures.
2. a) Provide a list of the permits, approvals, and permissions the company
will have to obtain to construct, operate, maintain, and retire the wind
4 10 NYSDPS Davis, Andrew turbines, electric collection system, substation, transmission line,
interconnection, and associated buildings and structures. b) Provide an
estimated schedule for the application and receipt of items in item "a"
4 11 NYSDPS Davis, Andrew 3. Provide a Quality Assurance and Control plan, including staffing
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positions and qualifications necessary, demonstrating how applicant will
monitor and assure conformance of facility installation with all applicable
design, engineering and installation standards and criteria as indicated in
question 1 above [Comment 4-9].
4. Provide a statement from a responsible company official that: a)
company and its contractors will conform to the requirements for protection
4 12 NYSDPS Davis, Andrew of underground facilities contained in Public Service Law §119-b, as
implemented by 16 NYCRR Part 753; b) company will comply with pole
numbering and marking requirements, as implemented by 16 NYCRR Part
217.
5. Provide plans and descriptions indicating design, location, and
construction controls to avoid interference with existing utility transmission
4 13 NYSDPS Davis, Andrew and distribution systems. Indicate detailed locations and specify design
separations of proposed facilities from existing electric, gas, and
communications infrastructure. Indicate measures to minimize interferences
where avoidances cannot be reasonably achieved.
6. Provide description and indicate details of plans to limit public access
4 14 NYSDPS Davis, Andrew and assure security at substations, collection points, wind energy facilities,
and aboveground components of electrical collection system.
7. Explain how the design and operation of the facility will avoid interference
4 15 NYSDPS Davis, Andrew with radio communications, including cell phones, AM/FM/SW radio,
television, radar, GPS and LORAN, and microwave transmissions.
8. Provide transmission facility design and construction plans, indicating
vegetation clearing and disposal specifications, structure locations, access
4 16 NYSDPS Davis, Andrew requirements, grading and access improvements, and environmental
control measures including storm water and erosion and control practices
and facilities.
9. Provide facility maintenance and management plans, procedures, and
criteria. Specifically, address the following topic:
4 17 NYSDPS Davis, Andrew a) turbine maintenance, safety inspections, and tower integrity;
b) electric transmission, gathering and interconnect line inspections,
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maintenance and repairs;
(i) vegetation clearance requirements;
(ii) vegetation management plans and procedures;
(iii) inspection and maintenance schedules;
(iv) notification and public relations for work in public right-of-way;
(v) minimization of interference with electric and communications
distribution plans.
c) vegetation management practices for switchyard and substation yards,
and for danger trees around stations; specifications for clearances;
inspection and treatment schedules; and environmental controls to avoid
off-site effects.
10. If the company will entertain proposals for sharing above ground
4 18 NYSDPS Davis, Andrew facilities with other utilities (communications, cable, phone, cell phone
relays, etc) provide criteria and procedures for review of proposals.
11. Provide emergency response plans, notification and coordination
procedures. Specify plans and procedures for addressing electric line
4 19 NYSDPS Davis, Andrew outages, specification of 24-hours per day storm and emergency response
situations. Include measures for communication and coordination with
operators of existing utility facilities, and residents of adjoining or affected
locations.
4 20 NYSDPS Davis, Andrew 12. Specify commitments for addressing public complaints, and procedures
for dispute resolution during facility construction and operation.
13. Specify commitments for end-of-life facility retirement and
4 21 NYSDPS Davis, Andrew decommissioning, with specific references to electrical gathering and
transmission system, interconnection and substation facilities.
14. Provide switchyard and substation design drawings and site plans,
indicating:
a) property lines and setbacks; access road location, width, and gradient;
4 22 NYSDPS Davis, Andrew site grading, cut and fill, drainage and environment controls; all proposed
improvements and equipment; fencing and gates; permanent erosion
control measures;
b) indicate any station lighting needs, and appropriate design criteria
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c) provide a statement indicating that any future lighting will be designed to
avoid off-site lighting effects (i.e., avoid up-light direction except for as-
necessary maintenance task-lighting; avoid drop-down optics to minimize
light trespass);
d) listing of all electrical equipment and specifications for substation and
switchyard facilities;
e) interconnection facility design plan and profile information.
4 23 NYSDPS Davis, Andrew 15. Provide a status report on equipment availability and expected delivery
dates for towers, turbines, transformers, and related major equipment.
16. a) Specify turbine design setback requirements for the following
structures: occupied structures (residences, businesses, and schools);
barns and unoccupied structures; electric transmission lines.
4 24 NYSDPS Davis, Andrew b) Explain the rationale for the setback distances for each type of structure
or facility.
c) Provide a detailed explanation as to why local setback provision from
transmission lines cannot be accommodated in facility layout.
17. Provide an analysis of the electrostatic and electromagnetic fields for
the proposed 115 kV electric transmission line. Include a cross-section
diagram and chart showing the results of the field strength analysis at
4 25 NYSDPS Davis, Andrew average annual and annual maximum conductor current flow (maximum
conductor rating). The cross-section diagram should demonstrate the
electrostatic and electromagnetic field strengths extending horizontally from
facility centerline to a distance of 300 feet.
We have received a request to evaluate properties for potential
historic/cultural significance. The initial request for resource evaluation was
received on October 9, 2007 and consisted of a single-volume report titled
Historic Architectural Survey (1-2 Mile APE) for the St. Lawrence Wind
5 1 NYSOPRHP Bonafide, John Project (October 2007, TRC). This document was supplemented by a
revised and expanded survey document that was received on January 23,
2008 titled Historic Architectural Survey for the St. Lawrence Wind Project
(January 2008 TRC). Our full assessment is attached to this letter as
Appendix A.
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Within the survey area, this agency has identified several key loci where
visual impacts should be carefully assessed. There areas encompass the
Cape Vincent village area, especially the National Register Listed individual
properties and historic district. Many of these resources may have a direct
visual connection to more than two-thirds of the proposed towers. In
addition, several of the individual rural agrarian properties will be in the view
5 2 NYSOPRHP Bonafide, John shed of a significant number of the proposed towers. Given the
unremarkable topography of this area the potential view shed/setting
impacts associated with these resources should be carefully assessed. All
resources where this office believes additional visual assessments should
be undertaken have been identified in Appendix A with an asterisk (*). We
would recommend that your agency seek to have appropriate visual
simulations generated to better understand the full extent of the potential
visual impacts associated with this project.
Although the full extent of potential impacts from the proposed undertaking
cannot be assessed absent simulations as part of a comprehensive visual
analysis, OPRHP believes that sufficient information does exist to
determine that under Section 14.09 1(c) of New York State Parks and
Recreation Law, the undertaking will have an Adverse Impact on cultural
5 3 NYSOPRHP Bonafide, John resources. The introduction of the sleek, ultra modern, approximately 425-
foot tall kinetic wind turbines (up to 96 proposed) throughout this scenic
landscape forever alters and changes the rural setting, which itself is a
significant element in much of the survey area and serves as the backdrop
for the architectural, cultural, and scenic tourism heritage of these
communities.
We would recommend that the applicant utilize the visual analysis as a tool
to aid in the exploration of feasible and prudent alternatives that avoid the
adverse impact(s). The assessment of potential impact avoidance options
5 4 NYSOPRHP Bonafide, John may include a reduction in turbine numbers and/or height, relocation of
turbine units, and various screening options. We would recommend that
only after an assessment of avoidance options has been established should
potential migration options be discussed. All consultation regarding
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avoidance options and potential later mitigation options should involve
those state/federal agencies directly associated with the permitting/approval
process for this project.
At this point in time we have concluded our evaluation of eligible resources
5 5 NYSOPRHP Bonafide, John and the potential impacts to those resources associated with this project.
Please be aware that we will be asking the project sponsor for GPS data
gathered as part of the survey.
Project design has been changed from 97 turbines to 53 and, consequently,
from 136 MW to 79.5 MW. As a result of the redesign, the project may no
longer require the Section 14.09 review of the NYS Public Service
6 1 NYSOPRHP Bonafide, John Commission. However, at this time, we do not know if other state and/or
federal agencies may be involved in this undertaking. Also, please note, our
comments related only to historic/cultural resources. Comments regarding
New York State parkland were submitted separately.
It is our understanding that the remaining 53 turbines are located on sites
previously identified in the original project information. As such, no
6 2 NYSOPRHP Bonafide, John additional topographic assessment or architectural survey was requested
by this office. The Alternatives Analysis and Visual Analysis provided in the
SDEIS would indicate that a number of the previously identified resources
would remain affected even with the turbine field selection.
As noted in the SDEIS, the reduction in the total number of turbines from 97
to 53 is a significant component in minimizing the impacts to historic
properties and is discussed in the sponsor's Alternatives Analysis. While
recognizing the significance of this redesign on the overall impact to the
6 3 NYSOPRHP Bonafide, John region's historic resources that surviving turbine field, nevertheless will
continue to have an adverse effect on historic properties. At this point in
time we encourage the Lead Agency, the project sponsor, and involved
state and/or federal lead agencies to continue to seek opportunities to
explore feasible and prudent alternatives that avoid, minimize, or to mitigate
the adverse impacts.
7 1 NYSOPRHP Lyons, Thomas I am writing on behalf of the State Parks office of the NYSOPRHP.
Comments on the cultural/historic impacts are provided separately by John
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Bonafide.
The visual impact analysis indicates the project will be visible from three
state parks: Cedar Point, Burnham Point, and Long Point. These three
facilities constitute an important component of the public recreational
amenities in the region and it is quite apparent that this project will have an
7 2 NYSOPRHP Lyons, Thomas adverse impact on these facilities. It is not possible to tell the location where
the line-of-sight confirmations were conducted. We request information on
the specific location, preferable GPS coordinates, for further review. Once
we receive this information, we may request additional photo simulations to
assist in determining potential impacts.
There seems to be an inconsistency in the SDEIS between the photo
simulation in Figure A14b and Table 3-27 which indicates that the "Actual
7 3 NYSOPRHP Lyons, Thomas View" from Cedar Point State Park will be "substantially screened by local
structures or vegetation." It would seem that this should be listed as
"Visibility indicated." Please clarify or provide further information.
7 4 NYSOPRHP Lyons, Thomas We also request further information on the impacts to park patrons of the
required FAA lighting to the nighttime horizon.
Based on the fall raptor migration rates exceeding those of Franklin
Mountain Hawk Watch and given the location of the project along the
northeastern edge of Lake Ontario, large numbers of birds may funnel
7 5 NYSOPRHP Lyons, Thomas through the Project Area during fall migration. State Parks recommends
that post-construction mortality surveys focus particularly on mortality
during migration. If significant mortality is observed, consideration should
be given to reducing operations during peak periods of migration.
State Parks endorses the SDEIS proposal to implement "the minimum FAA
safety lighting requirements." Also with regard to lighting, this agency
requests that the findings within the following two scientific documents be
7 6 NYSOPRHP Lyons, Thomas considered during the preparation of the FEIS: 1) USFWS 2003 Interim
Guidelines to Avoid and Minimize Wildlife Impacts from Wind Turbines.
Wind Turbine Siting Group, and 2) Longcore, Travis, Catherine Rich and
Sidney A. Gauthreaux Jr., 2008.
7 7 NYSOPRHP Lyons, Thomas The DEIS states that there will be shadow flicker less than 10 hrs/year at
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Burnham Point State Park. Please provide additional information on
impacts associated with shadow flicker including the basis for this estimate
as well as a focus on impacts to recreationists at the State Park.
Table 1-1 of the DEIS states, "The proposed project would generate noise
7 8 NYSOPRHP Lyons, Thomas during construction." State Parks seeks assurances that the project
applicant will confer with us on ways to minimize disruptions to park patrons
during construction.
In closing, State Parks acknowledges the importance of alternative and
7 9 NYSOPRHP Lyons, Thomas renewable energy sources for sustainability but we also recognize the
importance of this agency's mission to protect public resources that are so
important to the quality of the experience for our patrons.
WWNY's experience is that windmill farms can disrupt television signals
and municipalities should have a solid plan to make sure that free over-the-
air TV remains a valuable resource to all citizens now and in the future for
local news, weather, emergency broadcasts, as well as entertaining
programming.
WWNY has reviewed the sections which covered television reception within
the DEIS and SDEIS. We know St. Lawrence Wind Farm contracted
Comsearch for an analysis of the impact on off-air television reception, but
Corbin, James, could not find a date when this study was conducted. Some data is
FOX Program Director incorrect or dated (stations in operation, channel numbers, stations
10 1
Broadcasting and Director of FOX operating digitally, etc) and there are a few statements which we would
Broadcasting challenge based on our engineering knowledge and experience.
As of February 17, 2009 WWNY no longer broadcasts an analog signal. On
that date we also switched our digital broadcasts from UHF channel 35 to
VHF channel 7. It has been our experience that VHF frequencies are more
affected by turbines than UHF frequencies, and contrary to the conclusion
Comsearch makes, digital signals can be affected by intervening structures.
We suspect it relates the physical size of the radio wave-length of a
structure reflects or signal. Reflected signals produce a phenomenon called
multi-path which with may DTV sets or converter boxes makes the signal
appear weak or missing.
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We were pleased to read that if project operations impact existing television
coverage SLWF would address and resolve each individual problem. This
is encouraged since all viewers are important to us. It notes further that
mitigation actions could include adjusting existing antennae, upgrading
Corbin, James antenna, or providing cable or satellite systems to affected households. It
FOX Program Director needs to be noted that cable is not a viable action for many residents in our
10 2
Broadcasting and Director of FOX rural area and the Direct Broadcast Satellite services do not carry local
Broadcasting stations. Signal interference from windmills would not make a viewer
eligible for a distant-market Network feed from satellite and distant-market
feeds do not serve the viewer with local news or emergency broadcasts.
Distant Network feeds negatively affect WWNY's ability to serve and
contribute to the North Country.
Menter, Rudin, The SDEIS is not adequate and still fails to address the deficiencies
11 1 & Trivelpiece, Fucillo, Thomas discussed in my letters of June 13, 2007, June 14, 2007 and February 20,
P.C. 2008.
The SLWF is incompatible with the Village and Town of Cape Vincent Joint
Comprehensive Plan of 2004. The plan provides that "Area 8" where the
majority of the Project and much of the unrelated BP wind project will be
Menter, Rudin, sited, consists "mainly of rural residential and agriculture, with scattered
11 2 & Trivelpiece, Fucillo, Thomas commercial and a public school." The plan provides that "development that
P.C. has minimum impact on important resources such as scenic natural vistas,
working landscapes, and tourism assets" should be encouraged, and the
"location of towers...or utility facilities...[which] would have a negative
impact on scenic vistas and tourism assets" should be discouraged. Page
32.
Menter, Rudin, The visual impact analysis is not adequate. The 140 towers from the
11 3 & Trivelpiece, Fucillo, Thomas pending Cape Vincent are not included. The density of wind turbines in the
P.C. town will have a large impact that is not adequately addressed.
Menter, Rudin, The Applicant states that design alternatives for the portion of the
11 4 & Trivelpiece, Fucillo, Thomas transmission substation in the resort district will be evaluated to avoid or
P.C. minimize placement of this facility within this district. The evaluation of
design alternatives must take place as part of the impact statement
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process.
Menter, Rudin, The bird and bat studies in the SDEIS are not adequate. Further study is
11 5 & Trivelpiece, Fucillo, Thomas necessary in accordance with NYSDEC Guidelines (expanded study) and
P.C. USFWS 2003 Interim Guidelines.
Menter, Rudin, The raptor surveys are inadequate. The SDEIS downplays the presence of
11 6 & Trivelpiece, Fucillo, Thomas these species. At a minimum, additional seasons of data regarding the
P.C. presence and height of these species is needed before such presence can
be dismissed as "minimal" or outside the "zone of danger."
Menter, Rudin, The presence of the protected species of breeding birds (northern harrier,
11 7 & Trivelpiece, Fucillo, Thomas horned lark, grasshopper sparrow, and vesper sparrow) merits additional
P.C. seasons of study during the SEQR review of this Project.
The Indiana bat analysis in the SDEIS is inadequate. Further study is
required to determine the extent in which this site is used by the Indiana
Bats (as opposed to the two brief sampling events conducted by the
Menter, Rudin, Applicant) and to corroborate the Applicant's theory that the Glen Park
11 8 & Trivelpiece, Fucillo, Thomas cave-based ecology is dying off. Such analysis should not be part of a
P.C. vague future "collaborate process" but must be assessed in an
environmental impact statement. Such consultation and the development of
effective mitigation must occur during the SEQR process to render SEQR
meaningful.
Based upon the presence of multiple threatened and endangered species
of birds and bats and in the immediate vicinity of the site, much more study
is required to adequately assess the impact of the proposed facility on
those species. Such study must be performed prior to construction, as part
Menter, Rudin, of the environmental impact statement for this Project.
11 9 & Trivelpiece, Fucillo, Thomas
P.C. Such impacts must be assessed and mitigated during the SEQR process,
not after it has concluded. These are potential impacts that will likely require
a "taking" permit under both state and federal law, and therefore this is not
some theoretical or fanciful concern. There are many different species of
birds and bats which are lawfully protected and significantly more study is
required in an environmental impact statement to determine whether or not
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this site is feasible for this large industrial wind facility.
Menter, Rudin, SDEIS should adequately justify the need for overhead rather than buried
11 10 & Trivelpiece, Fucillo, Thomas power lines and discuss whether overhead lines will actually create more
P.C. impacts to birds than will be avoided in the wetlands.
Menter, Rudin, Coastal consistency - nowhere in the DEIS or SDEIS is there any
11 11 & Trivelpiece, Fucillo, Thomas demonstration that this facility (or any part of it) must be constructed in a
P.C. shorefront location.
Menter, Rudin, The SDEIS states that the Applicant will develop a wetland mitigation plan.
11 12 & Trivelpiece, Fucillo, Thomas Mitigation of impacts to resources such as wetlands is an important part of
P.C. the SEQR process and should be discussed within the SDEIS, not
developed after SEQR is completed.
Group of local citizens hired a noise consultant to evaluate Hessler's noise
analysis of the BP facility (attached to comment letter). Because the same
consultant conducted the analysis for SLWP, we assume the same flaws in
methodology.
(1) Test sites at the noisiest locations resulting in higher ambient noise
level. And the typical residence in Hessler's report is not a typical residence
but a construction trailer on a main road with a storage yard for trucks and
other heavy equipment
(2) Hessler significantly overstated background noise conditions during the
Menter, Rudin, summer by conducting a noise survey during a narrow time period when
11 13 & Trivelpiece, Fucillo, Thomas insect noise would have been at its peak
P.C. (3) Insect noise does not "mask" noise from wind turbines as contended by
Hessler because it is of a substantially higher frequency than wind turbine
sounds.
Schomer showed how a much more accurate ambient level for comparison
is 30 dB, which is much more typical of a rural community like Cape
Vincent.
Based upon the critical ramifications of establishing an erroneous ambient
sound level, it is incumbent upon the Town to more accurately determine
the background sound levels in this community. SLWF's elevated ambient
level of 37 db(A) is neither reasonable nor adequate to protect the citizens
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of Cape Vincent from objectionable noise. At a minimum, the Town should
have its own consultant assess background noise levels in Cape Vincent,
the results of which will be important to both pending projects.
Anticipated noise level of the operating facility is also suspect. The
Applicant's study relied upon modeling results obtained utilizing the
manufacturer's (the Applicant's) own sound data rather than actual sound
Menter, Rudin, level data obtained from operating wind farms. The Applicant should
11 14 & Trivelpiece, Fucillo, Thomas compare actual operational noise data from operating facilities with
P.C. manufacturer's data to determine if model results compare with actual
conditions at such facilities, and determine if whether the Applicant's
modeling assesses the frequency and duration of weather-generated
variation from "normal" expected sound levels at such facilities.
Menter, Rudin, The visual impact analysis of impacts to cultural/historic resources is
11 15 & Trivelpiece, Fucillo, Thomas inadequate because it does not consider the total impact of the additional
P.C. 140 proposed turbines for the adjacent Cape Vincent Wind Energy Project.
The SEQR process is meant to be an important tool for analyzing impacts
and mitigation, not a mere procedural impediment or bother. As with the
Menter, Rudin, DEIS, the Applicant relies too much on post-construction studies or future
11 16 & Trivelpiece, Fucillo, Thomas collaborative efforts with state and federal agencies to determine impacts or
P.C. develop necessary mitigation. As Lead Agency, the Planning Board must
ensure that such efforts are part of the SEQR process or that process has
no value whatsoever.
Since my comment letter dated May 22, 2007, I have received copies of the
following documents which are part of the Planning Board's record of this
action:
Menter, Rudin, 1. Memo to "File" from Kris Dimmick, the Town of Cape Vincent's consulting
12 1 & Trivelpiece, Fucillo, Thomas engineer dated 2/11/09 re Comments on January 2009 SDEIS (copy
P.C. attached).
2. 2/12/09 Letter from Todd Mathes, Town of Cape Vincent attorney, to
Richard Cogen, attorney for SLWF regarding the SDEIS completeness
review.
3. Email from Todd Mathes to various representatives of the Applicant
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dated 3/20/09 subject "Comments on St. Lawrence SDEIS" and
4. Letter of 3/23/09 from Todd Mathes to Richard Edsall regarding
completeness review of the SDEIS.
These documents support the conclusion that the SDEIS is inadequate, in

particularly regarding the sound analysis. It confirms that the Town's sound
consultant takes issue with portions of the sound analysis. Our FOIL
request to obtain a copy of these comments was denied and we reserve the
right to challenge that denial as a violation of New York's Freedom of
Information Law.
We request that you make the Tocci materials part of the SEQR record in
this action, require the Applicant to modify the SDEIS to make substantive
changes required by Mr. Dimmick (and apparently Mr. Tocci) and require
further analysis of noise impacts after appropriate background levels are
determined. There is no need to rush this important review to accommodate
the Applicant's construction schedule.
The WEST Inc study is likely flawed and did not adhere to the study work
plan. The SLWF is located proximal to one of the largest rivers in North
America and at the base of a large peninsula yet the studies provide little
evidence documenting the large concentrations of birds that would be
expected in this area. Flaws include:
- The study does not characterize avian/bat passage rates proximal to the
shoreline nor over inland areas, as planned in the study plan. Only a
13 1 Old Bird Inc. Evans, William passage rate summing up the whole radar-swept area is provided, most of
which is outside the wind project and another determination of passage rate
from a thin slice of atmosphere from the vertical mode of radar operation,
which was also collected outside the wind project area.
- West located radar equipment 0.5 km (instead of the prescribed 1.5 km
from the river edge. As such, the study provides horizontal passage rate
data where a third of the radar sweep area is over the St. Lawrence River.
The bird activity in this airspace is totally impertinent [sic] for avian impacts
of this wind project and it likely severely biases the results. For example,
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lower density (low-altitude) migration over water wouldn't have been
included in the overall passage rate figure whereas higher density overland
migration would have. Why doesn't the SDEIS come out and say that the
radar was only located 0.5 km from the St Lawrence River instead of the
prescribed 1.5 km? Why does this SDEIS incorrectly state that the USFWS
and NYSDEC recommended that the radar be less than 1.5 km away from
the shore when, in fact, these agencies requested that it be "approximately
1.5 km away?
- The passage rate determined from the vertical radar analysis is just a
single small slice of atmosphere adjacent to the project area and doesn't tell
us anything about channeling dynamics or the migration density across the
larger project area.
The West study does provide directional data of targets, which has the
potential to indicate channeling dynamics if carried out properly. But the
directional data they use in their analysis is from targets detected across all
altitudes surveyed. West's inclusion of high-altitude targets in this analysis
13 2 Old Bird Inc. Evans, William will tend to mask any channeling along the shoreline region because such
channeling activity would be primarily at low-altitudes.
The West study does not provide quantification of the relative rates of
passage below turbine height over the water, over the coastal zone, or over
the inland regions -- data that would help substantiate whether channeling
along the lakeshore was occurring.
For various reasons, the preconstruction radar study for this wind project
was not as productive as it could have been. What this means is there is a
lot less certainty in any forecast for impact to night migrating songbirds,
13 3 Old Bird Inc. Evans, William which so far appear to compose more than 80% of fatalities in eastern
North American wind projects. I think the SDEIS and the West radar study's
predictions of inconsequential collision impacts to birds are without solid
basis. The avian collision impact is potentially much higher than is
suggested by the SDEIS and West.
13 4 Old Bird Inc. Evans, William I have conducted nocturnal migration research in the region of the St.
Lawrence wind project using acoustic monitoring of avian flight calls. While
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my data suggest channeling dynamics in the region and unusual avian
concentration dynamics due to the peninsular location of this wind project, it
is clear that more research needs to and could be conducted to understand
these complex nocturnal migration dynamics with regard to reducing the
avian impact of wind projects in the region. What is needed is a study with
multiple nocturnal monitoring methodologies that can monitor the
atmospheric stratum below turbine height of multiple sites. Such a study
would help site turbines in areas that would have less nocturnal migration
traffic below turbine height, and theoretically less collision risk. Such a
study is worth consideration by all parties as wind turbine development in
this region is a long-term prospect.
While the West radar study has serious flaws and could have been carried
out more productively, the NYSDEC bears some responsibility for making
sure than the preconstruction studies are on track to be productive. The
preconstruction studies for the SLWF wind project were designed and
13 5 Old Bird Inc. Evans, William carried out before the NYSDEC guidance on wind power development were
finalized and fully thought out. It should be noted that avian impact at wind
projects is a learning process for all involved. The wind industry is the
primary proponent (and receiver of significant public $ stimuli). As such, it
has to bear a major burden for compliance with the full spectrum of public
service surrounding wind projects, including environmental impact.
I have conducted an acoustic monitoring avian night migration study
approximately 1 km west of the intersection of Rosiere Rd and Millens Bay
Road, approximately 1 km south of the SLWF, rough the same distance as
the West radar equipment was from the wind project area. The breeding
bird survey should also consider the following five species based on my
13 6 Old Bird Inc. Evans, William study, which recorded multiple flight calls of these species in the first week
of June 2007: Black-crowned night heron, least bittern (NYS Threatened),
Virginia rail, whip-poor-will (NYS Special Concern), and grasshopper
sparrow (NYS Special Concern). The site where these species were
recorded was simply an open field area. For most of these species, this
suggests they were flying about at night in regions outside of their preferred
feeding and nesting habitat. The fact that three of these species are
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associated with wetlands suggests that they are breeding within (or in the
near vicinity) of the SLWF. I am happy to provide this data to SLWF and the
agencies.
The SDEIS does not contain enough data to support the conclusions made
in the SDEIS. For example, the Second Atlas of Breeding Birds in New
York State identifies Cape Vincent as having significant concentrations of
Onondaga bird species that are Threatened and Special Concern in New York State.
14 1 Riley, Thomas
Audubon The atlas is a culmination of five years of fieldwork by thousands of
volunteers across the state. The SDEIS does not report the same avian
concentrations. We believe this is because the fieldwork for the SDEIS was
not adequate in duration and expertise.
We are very concerned that the project will adversely impact breeding,
migrating, and wintering patterns and behavior on the project site and
Onondaga surrounding area for the following Threatened and Species of Special
14 2 Riley, Thomas Concern that occur in the project area: northern harrier, short-eared owl,
Audubon
rough-legged hawk, whip-poor-will, and grasshopper sparrow (contrary to
the SDEIS conclusion, there is no evidence that this species would benefit
from the project).
The environmental impact statement attempts to discount those concerns
with the citing of minimal studies. Considering the variety of weather and
Onondaga other natural cycles there was not enough study of the bird populations to
14 3 Riley, Thomas
Audubon be confident of the recommendations. We would request that at least two
additional years of avian studies be conducted before another
environmental impact statement is considered for review.
For all the assurances in the SDEIS, the operator does not know what
damage will be done to the bird species on this site. The impact of this
Onondaga project on the welfare of birds in the region and the state is so critical that
14 4 Riley, Thomas we should insist that all comments in the study be based on scientifically
Audubon
acquired data. Referencing other studies and the proposed wind projects
that do not have a historical basis for their data should be discounted and
removed from the report.
14 5 Onondaga Riley, Thomas Any wind power project that gets approved and built should include post-
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Audubon construction studies. For this unique site it is critical that the science be
done now, not after the facilities are built and the damage to the avian
resources is done.
Onondaga In conclusion we ask you to recommend that this site not be approved for
14 6 Riley, Thomas
Audubon wind power projects.
We have talked with DEC employees watching for short-eared owls by our
Bell, Dolores and house over the past few years. They've seen as many as seven owls at one
15 1 time. If those doing the SDEIS failed to find any of these owls they must be
Michael
either incomplete or negligent and it should call into question their credibility
on other aspects of the SDEIS.
Two years ago, Clif Schneider did a sound level study at our home. Sound
levels he recorded were much lower than background levels assumed in
the SDEIS. The ambient sound test for the SDEIS is not a correct
representation of typical non-participating residents because the testing
Bell, Dolores and positions were located in noisy areas (near a construction site, near the
15 2
Michael largest dairy in town, near working farms, near busy highway, one near a
farm and a road). We are a farming and a resident community. To achieve
a limit of no more than 5 dBA above ambient sound at our home we think
setbacks need to be at least 3500 feet. Assurances that non-participating
residents will be protected need to be made before development proceeds.
In reference to low frequency noise, independent studies show it adversely
affects young children and the elderly. There needs to be further studies
into that. We did not find reference to this problem in the SDEIS. Please
reference World Health Organization (WHO) Lares final report Noise effect
Bell, Dolores and Morbidity by Dr. Niemann and Dr. Maschke
15 3
Michael (http://www.who.int.docstore/peh/noise/guidelines2.html) on page 8 refers
to the nervous and cognitive systems and on page 14 it refers to noise and
sleep disturbances, let alone other health problems. Science suggests that
Fiber acoustic disease may be attributed to windmills, so further research
needs to be done here too.
Bell, Dolores and The SDEIS report claims shadow flicker will affect up to 2,700 feet. There
15 4
Michael are 10 proposed turbine sites within this distance of our house. We have
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bedroom windows facing east without shades, frequently watch the sunset
out the western windows, and spend a lot of time outdoors. We will be
subjected to shadow flicker thought the day.
Bell, Dolores and Under the complaint resolution it is very vague and no true resolutions are
15 5 listed. Fill out the paperwork and wait. It doesn't give any time constraints
Michael
for true resolution.
A concern to be included in the complaint resolution in the complaint
resolution would be for the wind farm, it's developer and participating
Bell, Dolores and landowners to put up a bond to purchase properties from non-participating
15 6
Michael owners of adjacent windmill property owners if adjacent windmill property to
remediate any problems, if adversely affected by the "effects" of the
windmills and unable to sell on the open market.
There are no mitigation measures for shadow flicker or sound levels in the
Bell, Dolores and report. In fact, the use of buffer zones is the primary protection for ice shed
15 7
Michael and blade failure. We think buffer zones should be at least 3,500 feet to
avoid problems with shadow flicker and sound levels.
Also, under the mediation measure it needs to state that if within 18 months
Bell, Dolores and a non-participating resident deems that the developer denies them health,
15 8
Michael safety, or well-being, the wind farm, its developers, and participating
landowners would purchase property at pre-development market value.
It's not the responsibility of this board to assess the wind power industry's
Bell, Dolores and affect on global warming based on questionable science or the financial
15 9 viability of the industry without government subsidies. It is this board's
Michael
responsibility to regulate development based on its effect on the health,
safety, and general welfare of the public of this community.
Bell, Dolores and We think the SDEIS should be rejected due to its obvious lack of credibility
15 10 and apparent attempt to deceive and a moratorium be placed on
Michael
development until these concerns can be more adequately addressed.
Bell, Dolores and We started building our home over 5 years ago. If we know then what we
15 11 knew now we wouldn't have built our home here. The public officials did us
Michael
a disservice by not letting us know of the proposed windmills.
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16 1 Boss, Mark As a result, the Department [NYS Ag & Mkts] recommends that the 34.5 kV
farmland?
16 2 Boss, Mark the NYS Ag & Mkts will be followed and the cable will be placed at a
16 3 Boss, Mark measure the impact of construction. Nor is there any information on wells
16 4 Boss, Mark specific processes that will be implemented to ensure the concrete is
16 5 Boss, Mark way will be identified post-construction on as-built drawings which will be
construction?
16 6 Boss, Mark transmission lines? What is the plan to ensure that there are sufficient
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17 1 Boss, Sarah they are migrating? How long do they stay in Cape Vincent? When do they
17 2 Boss, Sarah Impacts of shadow effect on wildlife should be part of the DEIS.
17 3 Boss, Sarah Individuals, guides, and town must be compensated if towers result in loss
17 4 Boss, Sarah SLWF needs to establish who the environmental monitor works for and how
17 5 Boss, Sarah during the following construction [sic], environmental considerations to be
17 6 Boss, Sarah It is important to know the impacts of shadow effect on the fish in the water.
17 7 Boss, Sarah major springs and their use or flow prior to construction. I would like to see
17 8 Boss, Sarah The project may require an Article 24 Freshwater Wetland Permit and
17 9 Boss, Sarah come up with proposals around the state, it would seem appropriate to
17 10 Boss, Sarah the project not performed as part of the DEIS. The DEIS should be updated
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comment.
17 11 Boss, Sarah years of intense further studies of many groups before any consultation of
value may be drawn.
17 12 Boss, Sarah on Pleasant Valley Road? How will it be affected? What does Audubon
say?
17 13 Boss, Sarah The lease with SLWF takes away landowners' constitutional rights to sue
17 14 Boss, Sarah properly during construction to limit the impacts to surface waters,
17 15 Boss, Sarah Chaumont Barrens and Three Mile Creek will not be impacted by the
project.
17 16 Boss, Sarah information should be included in the report along with a discussion of
17 17 Boss, Sarah establish [sic] the St. Lawrence Wetland and Grassland Management
SLWGMD.
17 18 Boss, Sarah (2007) be considered by the project sponsor in siting the project features
[sic].
17 19 Boss, Sarah Section 3.3.6 NYS Fish and Wildlife found insufficient data exists to
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project.
17 20 Boss, Sarah comprehensive manner. The DEIS states that additional data on wildlife
The SDEIS states that SLWF will meet the setbacks required by the
Planning Board of Cape Vincent. These setbacks are 1,500 feet from the
18 1 Boss, Sarah Village of Cape Vincent boundary line, 1,000 feet to a non-participating
property line, 1,250 feet to a non-participating residence, and 750 feet to a
participating residence. These are inadequate for the safety of our
residents. I request that you require changes to these setbacks.
Commentary regarding the impact on health and safety from the wind
18 2 Boss, Sarah turbines. It is bordering on a crime to even consider that some residents will
be forced out of their homes due to inability to live with conditions caused
by the location of their turbines to their homes.
The monies the town acquires from the PILOT will be eaten up by the loss
18 3 Boss, Sarah of revenue from property taxes. Properties will decrease in value due to the
turbine industry. Commentary regarding negative impacts to the community
from the wind project.
19 1 Bragdon, Brooks describing these impacts. There is no discussion to avoid adverse impacts;
19 2 Bragdon, Brooks project shall result in adverse impacts, that "visual analysis be used to
relocation of the turbine units as well as a reduction in height and the
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Vincent, NYS Route 12 from Chaumont and from Clayton. These turbines
19 3 Bragdon, Brooks designation of my home and my real estate development company. The
A large percentage of the property tax assessment base is made up of
19 4 Bragdon, Brooks waterfront and water view properties and would be adversely affected by
the imposition of the economic will of a minority of the tax assessment
base.
20 1 Bragdon, Brooks Who negotiates PILOT payments for our town is not addressed.
20 2 Bragdon, Brooks What is the estimated cost per kilowatt hour produced for the first year of
20 3 Bragdon, Brooks leaseholders have any guarantee that promises will be kept, construction
completed.
20 4 Bragdon, Brooks Job and Economic Development model. None was referenced in this DEIS
assumptions.
20 5 Bragdon, Brooks There is insufficient documentation to back up the claim that downsizing the
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20 6 Bragdon, Brooks are placed by assessed as industrial use and taxed accordingly and not
20 7 Bragdon, Brooks compensate businesses and individuals if the proposed wind project results
20 8 Bragdon, Brooks How will historic designated properties near towers be compensated?
20 9 Bragdon, Brooks How does SLWF plan to compensate Indigenous Americans if Indian burial
20 10 Bragdon, Brooks Why no mention of Dodge Bay in the historical Architecture Resource
20 11 Bragdon, Brooks describing these impacts. There is no discussion to avoid adverse impacts,
project shall result in adverse impacts, that "visual analysis be used to
20 12 Bragdon, Brooks relocation of the turbine units as well as a reduction in height and the
20 13 Bragdon, Brooks Vincent, NYS Route 12 from Chaumont and from Clayton. These turbines
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designation of my home and my real estate development company. The
The SDEIS is grossly incomplete. It should be returned to the developer to
be redone. The rights of interested parties in the community must be
respected. In my view, turbines may be allowed but in an area away from
20 14 Bragdon, Brooks unique community assets. Should I personally suffer economic loss as a
result of having my rights under the SEQR review process suppressed I
shall be obliged to defend myself legally in order to reverse any economic
losses I should suffer.
I am writing to clarify my comments on the SDEIS in regard to setbacks
[Comments 19.3 and 20.13]. The setbacks I proposed are intended to be
consistent with the Introductory Provisions of the Cape Vincent Zoning Law
which calls for the following: protecting existing development while
protecting the existing assets of the community, conserving property
values, minimizing negative environmental impacts of development,
protecting visually and environmentally sensitive areas such as viewsheds
along the lake and river, protecting scenic views and agricultural lands,
protecting historically significant land and buildings, allowing landowners to
20 15 Bragdon, Brooks make beneficial economic use of their land provided that such uses are not
harmful to neighboring properties.
I maintain that no turbines should be allowed on the lake side of or near
Route 12 from Cape Vincent to Chaumont and also not near Route 12 from
Cape Vincent to Clayton. Rather the turbines should be setback sufficiently
to protect the basic scenic sense and spirit of the community. This setback
may be variable depending on the landscape, but a starting point for
discussion would be 4000 ft inland from Route 12. The development should
fit in with the community, not vice versa. Interested parties in the community
must be allowed the right to have input into the SEQR review process and
any analysis of adverse effects and proposals to mitigate.
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The SDEIS is a dishonest document which avoids moving the turbines to
reasonable locations. If the project is allowed as proposed it would harm
20 16 Bragdon, Brooks the majority tax assessment comprised of waterfront and waterview
properties in favor of the minority interests of the relatively modest number
of landowners who have contracts for turbines.
Any turbines allowed should be setback so as to not change this unique
and lovely community. Views should be protected. The spirit of the
21 1 Brown, Mary Jane community should not be ruined. The SEQR process is not being carried
out fully and there has been no opportunity for input into the approval
process.
The proposal has too many turbines dominating the landscape. This would
22 1 Burpee, Edith destroy the community particularly together with the other proposed project.
Any turbines allowed should be setback so as not to damage the loveliness
of the community setting along the St. Lawrence River.
Commentary objecting to misinformation about the adverse impacts from
wind projects that have been suggested in other comments. My opinion is
that there are people in our community that just do not want wind power in
23 1 Burton, Darrell the area. I have observed the members of our planning board in action
since this project started. I believe you all have been very open minded and
conducted business properly. I think the results of the SDEIS are an
adequate report.
Commentary supporting the wind energy project and the benefits of wind
energy as opposed to other forms of energy production. Commentary
24 1 Burton, Marlene objecting to misinformation about the adverse impacts from wind projects
that have been suggested in other comments. I truly believe Tom Rienbeck,
Rich Edsall, and the Board Members are doing an honest, legally,
thankless job and should be applauded for the work they have done.
25 1 Byrne, Tatyana As a result, the Department [NYS Ag & Mkts] recommends that the 34.5 kV
farmland?
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25 2 Byrne, Tatyana the NYS Ag & Mkts will be followed and the cable will be placed at a
25 3 Byrne, Tatyana measure the impact of construction. Nor is there any information on wells
25 4 Byrne, Tatyana specific processes that will be implemented to ensure the concrete is
25 5 Byrne, Tatyana way will be identified post-construction on as-built drawings which will be
construction?
25 6 Byrne, Tatyana transmission lines? What is the plan to ensure that there are sufficient
25 7 Byrne, Tatyana Will the geotechnical investigation, necessary for project construction and
25 8 Byrne, Tatyana 3.1.3.3 In this paragraph, SLWF does not mention the use of an
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activities it is important that an environmental monitor be onsite for all pre-
25 9 Byrne, Tatyana 3.2.3.3 The discussion on soil is too general. Each turbine site, access
25 10 Byrne, Tatyana 3.4.2 Will the comprehensive transportation study, delivery routes, and
25 11 Byrne, Tatyana which is already out of compliance with EPA guidelines. What is the impact
25 12 Byrne, Tatyana responsibility of the Applicant and would be undertaken at no expense to
continue.
25 13 Byrne, Tatyana Bossanyi, and Siefert, 1998) is an 11-year old study. Why aren't you using
a more recent one?
25 14 Byrne, Tatyana cumulative effect on Indiana bats than the wind energy development. What
Indiana bats?
25 15 Byrne, Tatyana 4.1.11.2 Since the housing market has changed so dramatically since 2007
25 16 Byrne, Tatyana current?
- 1500 feet from Village of Cape Vincent boundary line
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25 17 Byrne, Tatyana 7.6 Table 7-1. What compensation are the three non-participating
25 18 Byrne, Tatyana Appendix E. The avian and bat study was conducted in one year. Why
25 19 Byrne, Tatyana Appendix E1. The bat studies were done with radar. Why not also sonar?
25 20 Byrne, Tatyana July Aug 2007 1.0 states that six captures Indiana bats were radio tracked
25 21 Byrne, Tatyana Appendix E3 is labeled Blanding Turtle but reports on bats.
25 22 Byrne, Tatyana Appendix E7. Which of the Blanding Turtle mitigation recommendations will
be adopted and which will not and why not?
25 23 Byrne, Tatyana Appendix J. What will you do to mitigate shadow flicker if your analysis is
wrong?
25 24 Byrne, Tatyana Appendix L. The data in Table 2.2.1 does not match the data from our paid
25 25 Byrne, Tatyana Appendix L.3.6 The negative impacts of low frequency sound are dismissed
25 26 Byrne, Tatyana Appendix N2. Who pays to mitigate the loss of TV signals in the project
area?
25 27 Byrne, Tatyana they are migrating? How long do they stay in Cape Vincent? When do they
25 28 Byrne, Tatyana Impacts of shadow effect on wildlife should be part of the DEIS.
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25 29 Byrne, Tatyana Individuals, guides, and town must be compensated if towers result in loss
25 30 Byrne, Tatyana SLWF needs to establish who the environmental monitor works for and how
25 31 Byrne, Tatyana during the following construction [sic], environmental considerations to be
25 32 Byrne, Tatyana It is important to know the impacts of shadow effect on the fish in the water.
25 33 Byrne, Tatyana major springs and their use or flow prior to construction. I would like to see
25 34 Byrne, Tatyana The project may require an Article 24 Freshwater Wetland Permit and
25 35 Byrne, Tatyana come up with proposals around the state, it would seem appropriate to
the project not performed as part of the DEIS. The DEIS should be updated
25 36 Byrne, Tatyana survey, and hydrogeological balance study based upon long-term runoff. By
comment.
25 37 Byrne, Tatyana At best the studies to date may be considered pilot efforts requiring 3-5
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years of intense further studies of many groups before any consultation of
value may be drawn.
25 38 Byrne, Tatyana on Pleasant Valley Road? How will it be affected? What does Audubon
say?
25 39 Byrne, Tatyana The lease with SLWF takes away landowners' constitutional rights to sue
25 40 Byrne, Tatyana properly during construction to limit the impacts to surface waters,
25 41 Byrne, Tatyana Chaumont Barrens and Three Mile Creek will not be impacted by the
project.
25 42 Byrne, Tatyana information should be included in the report along with a discussion of
25 43 Byrne, Tatyana establish [sic] the St. Lawrence Wetland and Grassland Management
SLWGMD.
25 44 Byrne, Tatyana (2007) be considered by the project sponsor in siting the project features
[sic].
Section 3.3.6 NYS Fish and Wildlife found insufficient data exists to
25 45 Byrne, Tatyana adequately conduct a risk assessment and predict wildlife mortality for this
project.
25 46 Byrne, Tatyana comprehensive manner. The DEIS states that additional data on wildlife
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25 47 Byrne, Tatyana Who negotiates PILOT payments for our town is not addressed.
25 48 Byrne, Tatyana What is the estimated cost per kilowatt hour produced for the first year of
25 49 Byrne, Tatyana leaseholders have any guarantee that promises will be kept, construction
completed.
25 50 Byrne, Tatyana Job and Economic Development model. None was referenced in this DEIS
assumptions.
25 51 Byrne, Tatyana There is insufficient documentation to back up the claim that downsizing the
25 52 Byrne, Tatyana are placed by assessed as industrial use and taxed accordingly and not
25 53 Byrne, Tatyana compensate businesses and individuals if the proposed wind project results
25 54 Byrne, Tatyana How will historic designated properties near towers be compensated?
25 55 Byrne, Tatyana How does SLWF plan to compensate Indigenous Americans if Indian burial
25 56 Byrne, Tatyana Why no mention of Dodge Bay in the historical Architecture Resource
25 57 Byrne, Tatyana is generating please explain how wind power eliminates pollutants and
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25 58 Byrne, Tatyana takeaway lines and what level of maintenance priority will these roads have
25 59 Byrne, Tatyana I am concerned that there are no safety measures to ensure children don't
25 60 Byrne, Tatyana The assumptions used to complete the DEIS/Supplemental are not listed.
25 61 Byrne, Tatyana that governs the application and decision-making process for the special
25 62 Byrne, Tatyana layout, elevation drawings indicating all major equipment, architectural
25 63 Byrne, Tatyana Agencies, and the public a better understanding of the project's impacts.
simulations alone.
The decommissioning process is inadequate. Watertight policies must be
25 64 Byrne, Tatyana original condition before the FEIS is accepted. Additionally, triggers need to
the FEIS is signed.
25 65 Byrne, Tatyana performance, payment, public improvements, and decommissioning. You
will need to figure out how that bonding follows to successive owners,
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25 66 Byrne, Tatyana come close to the transmission capacity and the impact that will have on
25 67 Byrne, Tatyana interconnect has limited capacity, which limits a larger project. In that case,
25 68 Byrne, Tatyana The DEIS states that the project will augment local electricity supply. Is this
a true statement?
25 69 Byrne, Tatyana adopted by the Town and how the project will fit into the goals set forth in
25 70 Byrne, Tatyana asked that SLWF work with BP on the transmission line and asked that any
25 71 Byrne, Tatyana asked that SLWF produce a revised visual impact study based upon the
25 72 Byrne, Tatyana asked that SLWF include measures of commercial and pleasure watercraft
25 73 Byrne, Tatyana asked that SLWF meet with Cape Vincent Fire Department and work out an
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25 74 Byrne, Tatyana site in the Project Area. What is the number that keeps the project
26 1 Cullen, Geoffrey I wish to express my profound concern regarding the proposed SLWF. I
have reviewed the SDEIS and feel it is inadequate.
26 2 Cullen, Geoffrey One only has to look across the river to Wolfe Island to see how radically
and permanently the landscape will be changed.
Property values will inevitable suffer if this project moves forward. What
26 3 Cullen, Geoffrey compensation is planned for those of us who will not have turbines but will
see a drop in our home and property values?
While I firmly believe in renewable energy, I also feel there are other more
26 4 Cullen, Geoffrey compelling issues to consider. The SDEIS is not adequate. The setbacks
are too low. I request that you reject the SDEIS.
I frequently drive through the town of Cape Vincent. I feel Cape Vincent is
not the right community for wind turbines. The roads and fields are lovely
27 1 Daub, Patricia and are to be protected as rural landscapes with historic preservation stone
farmhouses and old barns under the New York State preservation laws.
Input under the SEQR process has been inadequate.
28 1 Docteur, David asked that SLWF work with BP on the transmission line and asked that any
28 2 Docteur, David asked that SLWF produce a revised visual impact study based upon the
28 3 Docteur, David asked that SLWF include measures of commercial and pleasure watercraft
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28 4 Docteur, David asked that SLWF meet with Cape Vincent Fire Department and work out an
28 5 Docteur, David site in the Project Area. What is the number that keeps the project
Docteur, Dennis and Comments expressing support for the project and the Town Board's
29 1
Donald decisions. Comments requesting approval of the project not be delayed.
Comments supporting the project and objecting to information presented by
30 1 Docteur, Lee a vocal minority that has been opposed to the project. Comments
expressing the positive net benefits of wind power. Please do your civic
duty to uphold the rights of the majority.
31 1 Docteur, Mary cumulative effect on Indiana bats than the wind energy development. What
Indiana bats?
31 2 Docteur, Mary 4.1.11.2 Since the housing market has changed so dramatically since 2007
current?
31 3 Docteur, Mary - 1500 feet from Village of Cape Vincent boundary line
31 4 Docteur, Mary 7.6 Table 7-1. What compensation are the three non-participating
31 5 Docteur, Mary Appendix E. The avian and bat study was conducted in one year. Why
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31 6 Docteur, Mary Appendix E1. The bat studies were done with radar. Why not also sonar?
31 7 Docteur, Mary July Aug 2007 1.0 states that six captures Indiana bats were radio tracked
31 8 Docteur, Mary Appendix E3 is labeled Blanding Turtle but reports on bats.
31 9 Docteur, Mary Appendix E7. Which of the Blanding Turtle mitigation recommendations will
be adopted and which will not and why note?
31 10 Docteur, Mary Appendix J. What will you do to mitigate shadow flicker if your analysis is
wrong?
31 11 Docteur, Mary Appendix L. The data in Table 2.2.1 does not match the data from our paid
31 12 Docteur, Mary Appendix L.3.6 The negative impacts of low frequency sound are dismissed
31 13 Docteur, Mary Appendix N2. Who pays to mitigate the loss of TV signals in the project
area?
The SDEIS should not be accepted as written. There are too many issues
32 1 Docteur, Paul pertaining to the health, safety, and welfare of all residents of the
community. Over the past couple of years, many of us have learned a great
deal about the effects of noise and its effects on our health.
Shadow flicker also can have a very detrimental effect on our health as well
32 2 Docteur, Paul as safety issues. My wife is plagued with benign positional vertigo. It is
impossible for her to drive through the turbines on Route 177, making
setbacks a very important issue.
32 3 Docteur, Paul The other issue of importance is the Conflict Resolution Board. This cannot
be controlled by the wind company.
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Mr. Reinbeck, as our Supervisor, you are in charge. Put an end to this
hostile sell out of this most beautiful and historical part of the world.
32 4 Docteur, Paul Implement a two year moratorium immediately. Put together a legitimate
steering committee, which will document a zoning law for turbines, to clarify
it if can occur with our already accepted comprehensive plan.
The Blanding Turtle study conducted by SLWF is flawed. Results show only
one turtle found in 2005 and one in 2007. We gave permission to the
NYSDEC to study Blanding Turtles on our property during 2007 and 2008.
Numerous Blanding turtles have been found on our property in the
wetlands, farm pond and resting in hayfields. We have seen many crossing
Estelle, Douglas and the street from our property to the wetlands which continue on the opposite
33 1 side of the street. In addition, numerous Blanding turtles have been found
Michelle
on our neighbor's property, Francis & Brenda Aubertine, on Pelo Road.
The study was conducted when there wouldn't be much movement by

turtles, in mid-November. They even state that the active time for Blanding
turtles is in June, so why did they do it in winter? This is why it is so
important for the Town to do their own studies.
Freislich, John and Comments expressing concern regarding affects of the project, shadow
34 1 flicker and noise in particular, on existing health problems, fibromyalgia and
Michelle
Graves Disease.
The potential sleep disruption from turbine noise has me generally
concerned. The noise study is flawed. First, why should there be no sound
meters along the river from Burnham Pt to Sand Bay? The bulk of the
dwellings are located along the river on both sides of 12E as you well know.
Freislich, John and Why would the only location be at Wood's Farm? They are a participant so I
34 2 fail to see how this would be representative of the effect on the bulk of the
Michelle
populace. Why did the Planning Board not challenge the lack of additional
data affecting the populated areas? Secondly, the length of time spent
studying the ambient noise is laughable if it wasn't so serious a factor.
Seventeen days? One of the most critical issues and that was the total
winter test duration?
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Why was no measuring device placed at the school? Why no devices near
Beadles Pt, Millen's Bay, or further west near the trailer parks? Why did the
Town of Cape Vincent not hire an independent firm to conduct this critical
research?
Freislich, John and This SDEIS does nothing to guarantee that there will be no impact on my
34 3
Michelle quality of life.
35 1 Doull, Melodee is generating please explain how wind power eliminates pollutants and
35 2 Doull, Melodee takeaway lines and what level of maintenance priority will these roads have
35 3 Doull, Melodee I am concerned that there are no safety measures to ensure children don't
35 4 Doull, Melodee The assumptions used to complete the DEIS/Supplemental are not listed.
35 5 Doull, Melodee that governs the application and decision-making process for the special
35 6 Doull, Melodee layout, elevation drawings indicating all major equipment, architectural
35 7 Doull, Melodee Agencies, and the public a better understanding of the project's impacts.
simulations alone.
35 8 Doull, Melodee The decommissioning process is inadequate. Watertight policies must be
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original condition before the FEIS is accepted. Additionally, triggers need to
the FEIS is signed.
performance, payment, public improvements, and decommissioning. You
35 9 Doull, Melodee will need to figure out how that bonding follows to successive owners,
35 10 Doull, Melodee come close to the transmission capacity and the impact that will have on
35 11 Doull, Melodee interconnect has limited capacity, which limits a larger project. In that case,
35 12 Doull, Melodee The DEIS states that the project will augment local electricity supply. Is this
a true statement?
35 13 Doull, Melodee adopted by the Town and how the project will fit into the goals set forth in
Concerns regarding impacts to aquifer providing water to spring off of
Mason Road as a result of possible blasting for wind turbine footings in the
36 1 Henchy, Harold general vicinity of the spring. What is the plan of the Town to provide water
to my home in a timely manner, within 24 hours, if the aquifer is
compromised?
37 1 Hetzler, Eileen Concerns regarding the impact of the project on property values and
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existing tourism from visual impacts.
Concerns regarding the impact of the project on property values from visual
38 1 Hetzler, Stephen impacts. Also concerns that the escrow for the warranty of the wind turbine
generators would more than likely be used up before the warranty period is
over.
Concerns that there has not been sufficient time for public review of the
39 1 Hirschey, Urban SDEIS. The SDEIS was submitted over 2 years after the DEIS and is twice
as long yet public was given only half the time to review and make
comments.
Concerns regarding the cumulative impacts from the BP Cape Vincent
project, as well as the proposed, dormant PB application for a project in
Lyme which would also share the same transmission line. Also, the
39 2 Hirschey, Urban Alternatives Section Table 7-1, states that the 53-turbine project will
encompass 7849 acres. This amounts to 148 acres per turbine and if you
include the 140 turbines of BP that would total over 28,000 acres which
amounts to 88% of the mainland area of the Town of Cape Vincent.
Concerns regarding the adequacy of the ice shedding discussion in the
SDEIS, specifically the lack of an ice shedding study and relevance of the
existing research referenced in the discussion.
The Morgan, Bossani, and Siefert 1988 study calls for ice studies to be
completed in three stages. An estimate should be made of the time
(number of days per year) during which icing conditions occur at the turbine
40 1 Hludzenski, Kathryn site:
- "heavy icing" more than 5 days, less than 25 days icing per year
- "moderate icing" more than 1 day, less than 5 days icing per year
- "light icing" less than 1 day icing per year
- "no icing" no appropriate icing conditions occur
Also, the report is now old. Since it was written, many cases of injury from
turbine ice shed have been documented. For example,
http://www.caithnesswindfarms.co.uk/fullaccidents.pdf.
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Concerns that the Cape Vincent Indiana bat studies are insufficient.
The length of time may not be sufficient to determine bat presences

because weather conditions changes from year to year and this could affect
bat activity. The Cape Vincent test was done in July/August 2007 but is not
clear on how many days were spent in the field and under what conditions.
41 1 Hludzenski, Kathryn Sampling was done in July and August but the report for the Horse Creek
Wind Farm in neighboring Clayton, New York trapped their first bat on June
2 and after July 31st capture rates significantly decreased. Depending on
when the Cape Vincent studies were done, this may have had an effect on
the results also.
The study did not do thermal imaging or use acoustical radar. The Indiana
brown bat is difficult to distinguish from the little brown bat therefore
additional mist net surveys are needed during spring and fall migration.
Concerns regarding cumulative impacts from the several wind projects in
the area: operational Wolfe Island project (86 turbines), Horse Creek in
41 2 Hludzenski, Kathryn Clayton (62 turbines), Galoo Island (77 turbines), BP's Cape Vincent wind
project (140 turbines), and the SLWF (53 turbines). All for a total of 418
turbines within a 25 mile radius of the Indiana bat hibernacula in Glen Park,
New York.
Concerns regarding mortality to Indiana bats from the wind project, from
fragmenting its habitat and destroying its foraging ground and pressure
changes that spinning blades have on the lungs of bats. A more extensive
41 3 Hludzenski, Kathryn study is necessary to know how many Indiana bats are actually in the area
and the impact the project would have. Not only do I think that the bat
studies are inadequate, but I think that due to the plight of the Indiana bat
and the sensitive nature of the area, the project should not be in Cape
Vincent.
41 4 Hludzenski, Kathryn Were the transmission line routes also included as part of the area being
tested?
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42 1 Hubbard, Sandy they are migrating? How long do they stay in Cape Vincent? When do they
42 2 Hubbard, Sandy Impacts of shadow effect on wildlife should be part of the DEIS.
42 3 Hubbard, Sandy Individuals, guides, and town must be compensated if towers result in loss
42 4 Hubbard, Sandy SLWF needs to establish who the environmental monitor works for and how
42 5 Hubbard, Sandy during the following construction [sic], environmental considerations to be
42 6 Hubbard, Sandy It is important to know the impacts of shadow effect on the fish in the water.
42 7 Hubbard, Sandy major springs and their use or flow prior to construction. I would like to see
42 8 Hubbard, Sandy The project may require an Article 24 Freshwater Wetland Permit and
42 9 Hubbard, Sandy come up with proposals around the state, it would seem appropriate to
42 10 Hubbard, Sandy the project not performed as part of the DEIS. The DEIS should be updated
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comment.
42 11 Hubbard, Sandy years of intense further studies of many groups before any consultation of
value may be drawn.
42 12 Hubbard, Sandy on Pleasant Valley Road? How will it be affected? What does Audubon
say?
42 13 Hubbard, Sandy The lease with SLWF takes away landowners' constitutional rights to sue
42 14 Hubbard, Sandy properly during construction to limit the impacts to surface waters,
42 15 Hubbard, Sandy Chaumont Barrens and Three Mile Creek will not be impacted by the
project.
42 16 Hubbard, Sandy information should be included in the report along with a discussion of
42 17 Hubbard, Sandy establish [sic] the St. Lawrence Wetland and Grassland Management
SLWGMD.
42 18 Hubbard, Sandy (2007) be considered by the project sponsor in siting the project features
[sic].
42 19 Hubbard, Sandy Section 3.3.6 NYS Fish and Wildlife found insufficient data exists to
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project.
42 20 Hubbard, Sandy comprehensive manner. The DEIS states that additional data on wildlife
The Complaint Appeal Procedure states that the Complaint Resolution
Board shall consist of three members: an SLWF designee, a Town Officer
or Employee appointed to the position annually, and an independent third
party expert."
Since the appeal procedure follows the original complaint which "SLWF will
make every reasonable effort to resolve" it does not make any sense that
SLWF would also be included in an appeal board. If they had resolved the
43 1 Jury, Charles complaint in the first place the appeal would not be necessary.
The appendix also states "in making such decision, the Complaint
Resolution Board shall take into account the terms and conditions of the
special use permit and approved site plans, and shall not require any
resolution that is inconsistent with such terms." This seems to say that as
long as the permit and site plans are approved there is no way any
complaint will be heard. This statement should be eliminated from the
SDEIS.
Regarding the TV analysis and the statement that TV programming by
alternative means can be offered to mitigate the issue of loss of coverage,
who will determine whether there is a problem and who will pay for the
44 1 Jury, Ellen alternative method? It should also be noted that cable TV is not available to
all areas of Cape Vincent and that DBS does not offer all local channels.
These local channels are necessary for local news, emergency information,
weather alerts, school closings, security alerts, etc.
45 1 LaMora, David Concerns regarding conflict of interest of the Planning Board members in
reviewing the SLWF. A majority of the Planning Board, which I believe
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illegally voted itself Lead Agency for this process, have prohibitive conflicts
of interest, which you refuse to acknowledge or seek an authoritative
decision on in the best interest of this community.
Further information is necessary to substantiate the conclusion that the
wind project will have a positive benefit to air quality. In many cases, the
45 2 LaMora, David existing plants that provide electricity at a much higher efficiency level do
not shut down when wind-generated power is being substituted; they
merely redirect their energy source so it is available to ramp up with the
wind stops blowing.
The visual impacts from the project are enough to prevent acceptance of
45 3 LaMora, David the SLWF on the basis of the zoning law, which specifies that if any
deleterious effect cannot be mitigated then the subsequent site plan review
must be disapproved.
The SLWF is not compliant will all town zoning and land use regulations
because the project does not comply with the Comprehensive Plan, which
guides all land use laws in Cape Vincent. The Plan states that one of its
45 4 LaMora, David goals is to encourage development that minimizes any negative impact on
the natural vistas and scenic landscapes. This is in complete contradiction
to the claim SLWF makes that this project complies with all land use
regulations by its own admission that it cannot mitigate the visual impact of
these turbines.
In Section 3.5.1.3 this report states that turbine locations and other project
components will conform to setbacks and standards required by the Town
Planning Board in response to public comments on the SLWF DEIS. These
setbacks and standards are not legitimate validated criteria for site plan
45 5 LaMora, David review. According to the Cape Vincent Zoning Law all zoning criteria must
be legislated by the Town Board. Stipulating that these standards must be
conformed to is an illegal attempt to circumvent the proscribed legislative
process and cannot be allowed to guide the SEQR process. The planning
board must not allow this, since these criteria would not hold up to a
challenge by either the developer or a dissenting landowner.
45 6 LaMora, David The noise analysis has flaws. Why were 5 to 6 testing locations chosen
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only at participating properties? They should have tested at non-
participating properties, because impacts to non-participating residents
should be evaluated. Also, the equipment used to collect the data was not
suitable for sever winter weather and didn't provide a statistically adequate
percentage of raw data.
My final comment concerns the complaint resolution process. It is obvious
that even though they go to great lengths to detail every impact and
describe what they consider a suitable mitigation for each impact, they are
certain that the criteria suggested to site this project are inadequate to the
extent that it will require a sophisticated and complex complaint resolution
process to deal with noncompliance. I believe it is inherent in the biased
45 7 LaMora, David unwillingness of the Town Board and Planning Board to significantly restrict
this development that will lead to this compliance nightmare. The final insult
to the residents of Cape Vincent is the proposed makeup of SLWF's
resolution board. If it is true that we require resolution beyond what the
Zoning Board of Appeals can provide then the process should not be
determined by the developer and certainly not controlled by them to the
extent they propose. A resolution board should be designed and controlled
by members of the community just as any zoning regulations should be.
If this Supplemental Study is approved by this Planning Board, it will do
nothing but illuminate the severity of the bias produced by the conflicts of
45 8 LaMora, David interest prevalent in this government. I sincerely hope you will consider the
ramifications of approving this document and instead will either ask for
another Supplemental Review of halt the process until this community can
resolve some of these issues for ourselves.
The wind turbine setbacks are in violation of several paragraphs under
46 1 Leschord, Paul Article I, Section 115 of the Cape Vincent Planning and Zoning Introductory
Provisions. Setbacks should be examined in miles, not feet. Anything else
creates visual impacts.
Concerns regarding the cumulative impacts from both Cape Vincent and
47 1 LeTendre, Gerard the other proposed project on wildlife. The SDEIS does not adequately
address this and does not have adequate studies of impacts to wildlife.
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We had deep rooted problems in attempting to resolve the wind tower issue
in this town. The Town Board is conflicted as is the Zoning Board (including
47 2 LeTendre, Gerard the Chairman). These people that have little or no biological training are
making decisions favoring the developer that will affect the town drastically
in the future. Favorable decisions are often rendered no matter how poor or
wrong the information is that is provided.
The bird and turtle studies are inadequate and never even develop an
accurate portrayal of the various populations as they exist today. The
47 3 LeTendre, Gerard developer fills many pages with information about other wind farms that
don't apply to Cape Vincent and then neglects local information such as the
data generated in the 1980 and 1984 NYS Breeding Bird Atlas.
Blanding Turtles: The developer and paid consultants have been unable to
determine where the turtles exist in town so they have no idea of population
size. Yet, they want us to believe that once the wind towers are in place the
47 4 LeTendre, Gerard turtles will survive. Additional effort is required to locate this species. Once
location and numbers are known they can move forward and determine
possible adverse effects and develop a wind turbine placement plan that
will avoid the turtle habitat or mitigate the problem.
Bats: Studies have been completed. Several Indiana Bats were captured in
2006, but in the SDEIS there is no report of follow-up studies on the Indiana
Bat. The studies done are too narrow in scope and avoid review of such
problems as white nose syndrome and how that relates to expected
47 5 LeTendre, Gerard mortality rates caused by wind tower blades. Much more and better
information is necessary in order to mitigate turbine mortality of bats. Cape
Vincent is near the Glen Park, NY hibernaculum and at least 3 years of
sound pre-construction bat studies should be required to learn how the
wind towers will effect the various populations of bat species.
Hawks: The studies done to date are minimal. A case in point is the
Northern Harrier that is NYS threatened and not adequately studied. These
47 6 LeTendre, Gerard birds nest in our town and will require protection. Acciona consultants are
not providing population status and no mitigation to protect species can be
applied at this time. Other hawks such as rough-legged, sharp-shinned,
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coopers and American kestrel depend on areas such as Cape Vincent for
their survival. Rough-legs require over-wintering habitat while the other
three species successfully nest here. The fact that all local hawks are
stressed means more and better studies are required.
Owls: Cape Vincent habitat is of particular importance to short-eared owl
survival. It is inconceivable that people hired to study birds in the Acciona
wind tower area never even located one! The developer either hired
unqualified people to collect bird data or they simply don't care. I have
47 7 LeTendre, Gerard personally shown short-eared owls to many bird watchers and nature lovers
that visited the area in recent years. Yes, they are here and require
protection from wind towers. The developer has not located the species and
therefore is unable to determine the number of short-eared owls present.
Once they know where the owls are and how many they can begin the
process of mitigating potential damage. Several years will be required.
Migrating Birds: The studies of migrating birds are especially poor. The
counters are not able to identify ducks and geese in flight and this is
compounded by short study times and too few counts. Information is
required on all bird migration and what can be done to avoid collisions.
Wind tower siting should not be anticipated until this is completed.
Note: In 2005, I spent one May morning watching birds on Gosier Road in
Cape Vincent. This site is the Acciona footprint. Large numbers of ducks
47 8 LeTendre, Gerard and geese were migrating north and I decided to make an impromptu
count. Over 20,000 ducks and geese were counted that morning. Of these,
over 1,000 were Snow Geese, a few hundred were Mallard Ducks and
approximately 19,000 Canada Geese were tallied. This was in a one mile
wide area that I selected because they were outside the count area. I
believe that more birds migrated through the area that morning than were
represented in all studies conducted and reported in the DEIS and the
SDEIS.
Breeding Birds: This study should start from scratch. A good place to start
47 9 LeTendre, Gerard is the 2000 to 2004 New York State Breeding Bird Atlas. Major problem
identified in bird studies: Adequate bird studies can't be completed unless
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you have competent bird counters that can identify birds by site and sound.
Counts of hawks, owls, ducks, geese, gulls, and songbirds were all poorly
done and should be expanded and repeated.
Invasive Plants: The disturbed earth created by wind farm construction will
compromise the ongoing swallow-wort control effort in the entire Town of
Cape Vincent. This invasive species is being controlled with funding by
47 10 LeTendre, Gerard NYS at the present time. There is no specific mention in the SDEIS of this
control effort which is funded for two more years. Stopping the possible
spread of swallow-wort and other invasive species should be given high
priority. Methodology for implementing this stoppage must be developed
prior to wind tower approval.
Noise: The noise issue is the most interesting and confounding issue of the
Cape Vincent wind tower sites. The developer hired a consultant (Hessler)
that appears to know exactly what decibel levels are required for maximum
placement of wind towers. Amazingly, the data provided by this consultant
came out at just the proper level for maximum wind tower placement.
This information on decibel background levels and the methodology
Hessler used is being challenged by several noise experts. I believe the
47 11 LeTendre, Gerard consultant hired by the Town of Cape Vincent (Cavanaugh Tossi
Associates Inc) came up with lower decibel background levels. It is
imperative that the Town Board and Zoning Board members get this right
because all the residents will be affected by the noise levels.
In addition to the consultant Cape Vincent hired, another consultant was
hired (Shomer and Associates) and neither of these (Shomer or
Cavanaugh) agreed with the results produced by Hessler. Paul Carr, a local
noise expert, also does not agree with Hessler.
Request for a moratorium of at least 12 months to investigate and
determine if this project is safe for the town. The issues of accurate
LeTendre, Jerry and measurement of ambient noise levels, nighttime noise levels affecting
48 1
Judith sleep, project effect on our water supplies, shadow flicker effects, migratory
bird impact, and the dominant visual impact of 390 foot tall turbines on our
landscape need to be resolved.
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49 1 Macura, David Will the geotechnical investigation, necessary for project construction and
3.1.3.3 In this paragraph, SLWF does not mention the use of an
49 2 Macura, David activities it is important that an environmental monitor be onsite for all pre-
49 3 Macura, David 3.2.3.3 The discussion on soil is too general. Each turbine site, access
49 4 Macura, David 3.4.2 Will the comprehensive transportation study, delivery routes, and
49 5 Macura, David which is already out of compliance with EPA guidelines. What is the impact
49 6 Macura, David responsibility of the Applicant and would be undertaken at no expense to
continue.
49 7 Macura, David Bossanyi, and Siefert, 1998) is an 11-year old study. Why aren't you using
a more recent one?
50 1 Macura, Joan Why not bury the overhead lines in the farmland?
50 2 Macura, Joan Will the cable depth be 24" or 6" below the soil surface?
50 3 Macura, Joan Will nearby well/spring info be included in the FEIS? Are there any plans to
provide potable water to citizens if well problems occur?
50 4 Macura, Joan How will concrete be handled during construction?
50 5 Macura, Joan Why not identify final overhead transmission line right-of-way pre-
construction?
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50 6 Macura, Joan Why doesn't it include long-distance transmission lines? What is the plan to
ensure sufficient funds? How will bonding follow to successive owners?
51 1 Mahrer, Carolyn Request for 12 month moratorium to investigate project safety.
Mahrer, Michael and Request for more time to review impacts and 1 year moratorium.
52 1
Susan
Mason, Elaine and Expressed support of the project.
53 1
Paul
54 1 Metzger, Donald Request for 30 days of public comment period
54 2 Metzger, Donald What is the second of the two alternative pathways? If second pathway is
taken, what are the steps involved?
54 3 Metzger, Donald Discuss decommissioning overhead collection lines. Confusion and
skepticism over decommissioning process.
54 4 Metzger, Donald Confusion regarding decommissioning concrete foundations.
54 5 Metzger, Donald Overhead transmission line shares same right-of-way with water line -
potential issue?
54 6 Metzger, Donald Request for testing of stray voltage every 6 months.
54 7 Metzger, Donald Who appoints the Complaint Resolution Board Town Officer member?
What town is represented?
54 8 Metzger, Donald Request for pre- and post-construction tests for signal quality.
54 9 Metzger, Donald Request for Saratoga Associates to apologize for calling community "late
risers."
54 10 Metzger, Donald Request for testing of all wells within 500' radius of turbines.
54 11 Metzger, Donald Expressed concern over cumulative effects of overall project.
55 1 Metzger, Donald Same as comment letter #54
56 1 Moehs, Charles Request public health/medical impact research
56 2 Moehs, Charles Request for mitigation of impacts through setbacks if impacts exist
57 1 Radley, Jerry Will people want to come to the area if they see turbines everywhere?
57 2 Radley, Jerry How will turbines affect child and adult health?
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57 3 Radley, Jerry Request for more research on wildlife.
57 4 Radley, Jerry Will turbines decrease property values? Will industrialization affect
seasonal residents?
58 1 Radley, Pattie Marie Expressed support of the project.
Reed, Alfred and Turbine #38 will decrease property value.
59 1
Maria
Reed, Alfred and Noise from turbines #38 and #39 will affect their way of life.
59 2
Maria
60 1 Ross, Pat Request for 12 month moratorium to investigate project safety.
61 1 Ryon, Doug Expressed concern over visual effects of overall project.
62 1 Schneider, Clifford Maps showing non-resident receptors are inadequate.
62 2 Schneider, Clifford Request for new survey that represents background noise for non-
participating residents.
62 3 Schneider, Clifford References to LEQ noise metrics in SEQR should be struck.
62 4 Schneider, Clifford Request to conduct another background survey using more representative
monitoring sites and incorporate recommendations from Town's consultant.
62 5 Schneider, Clifford Request to conduct project layout and impact analysis that assumes 26
dBA background sound along with the NYSDEC noise impact allowance.
62 6 Schneider, Clifford Provide details on source levels presented in Table 3-30.
62 7 Schneider, Clifford Request to recast analysis using 31 dBA as critical operational design level.
62 8 Schneider, Clifford Request to correct the ground absorption coefficient.
62 9 Schneider, Clifford Request to adjust model analysis (including setbacks) that will reduce
predicted noise levels by 5 dBA.
62 10 Schneider, Clifford Request to adjust siting plan to ensure non-participating residences will not
have noise impacts that exceed state guidelines.
62 11 Schneider, Clifford Provide siting plan and design level based on 31 dBA impact contour for
Project only noise addition.
62 12 Schneider, Clifford Remove comments and opinions that diminish importance of State
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guidelines.
62 13 Schneider, Clifford Increase the setback from the nearest offending turbines to reduce noise
impacts.
62 14 Schneider, Clifford Complaint Resolution Board Town Officer membership appointment issues.
62 15 Schneider, Clifford SLW Noise Impact Assessment - Provide measures of background noise
based on more conventional standards.
62 16 Schneider, Clifford SLW Noise Impact Assessment - Issues with background sounds -
misrepresentation of summertime noise levels.
62 17 Schneider, Clifford SLW Noise Impact Assessment - Van Der Berg references impacts would
be 15-18 dBA higher than expected.
62 18 Schneider, Clifford Noise Modeling Methodology - Request to re-do noise modeling
62 19 Schneider, Clifford Model Results - Redesign the layout plan accounting for background levels
at least 10 dBA lower than provided.
63 1 Schoeberlein, Donna Expressed concern over human and environmental health effects of project.
Requested more time to determine health effects.
63 2 Schoeberlein, Donna Who will purchase more expensive form of energy? What will this project
do to tourism revenue?
64 1 Simpson, Carol What is cumulative impact of both White Nose Syndrome and continued
human encroachment?
64 2 Simpson, Carol A more recent housing value impact study should be done due to the recent
changes in the housing market.
64 3 Simpson, Carol Are the listed setbacks correct?
64 4 Simpson, Carol Compensation for non-participating residents with noise over 40 dBA?
64 5 Simpson, Carol Why not multi-year study?
64 6 Simpson, Carol Are there Indiana Bats within the project area? If so, mitigation?
64 7 Simpson, Carol Appendix E3 is labeled "Blanding Turtles" but is about bats.
64 8 Simpson, Carol Appendix E7 - Which of the mitigation efforts for Blanding Turtles will be
adopted, which not?
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64 9 Simpson, Carol Appendix J - if analysis is wrong, what will be done to mitigate?
64 10 Simpson, Carol Appendix L - The negative impacts of low frequency noise are dismissed.
Where is the medical data?
64 11 Simpson, Carol Appendix N2 - who pays to mitigate loss of TV signals?
65 1 Simpson, Carol The SDEIS should provide specific impacts to specific
threatened/endangered.
What is the potential impact to Northern Harrier? How many breeding pairs
could be affected? Is this a significant portion of the breeding population in
65 2 Simpson, Carol the area? How will the impact be mitigated? What is the range of
reasonable alternatives considered to avoid this species pursuant to
617.9(b)(5)(iv)?
65 3 Simpson, Carol Cumulative Impacts on bird species with regard to Wolf Island
66 1 Steinhouse, Barbara Request for 12 month moratorium to investigate project safety.
Thomas, Carol and Who negotiates PILOT payments for the town?
67 1
Dan
Thomas, Carol and What is the estimated cost per kilowatt hour produced for the first year of
67 2
Dan the project, first 5 years and the first 10 years?
Thomas, Carol and No mention of payment, performance and maintenance bonding. If project
67 3
Dan is not bonded, how will promises be kept?
Thomas, Carol and No Economic Development Impact Model, so it appears the
67 4
Dan socioeconomics section was based on assumptions.
Thomas, Carol and Insufficient documentation to backup project downsizing claim.
67 5
Dan
Thomas, Carol and Since the turbines are a utility, then shouldn't the land be zoned as
67 6
Dan industrial and taxed accordingly.
Thomas, Carol and SDEIS does not address who will compensate business and individuals if
67 7
Dan proposed project results in loss of fishing revenues.
68 1 Uhlig, Bob and Ruth Who is responsible for the safety, repairs, maintenance, and removal of
turbines?
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What evidence do we have to keep swallow wort from spreading? Will
68 2 Uhlig, Bob and Ruth equipment be power washed when moved from site to site? Will turbines
spread seeds? Will farmers discontinue to plow fields which allows swallow
wort to spread?
68 3 Uhlig, Bob and Ruth Visible damage at Wolfe Island. Will this happen to Cape Vincent?
69 1 Vooder, Linda Request for 12 month moratorium to investigate project safety.
Wiley, Karen and Request for 12 month moratorium to investigate project safety.
70 1
Richard
71 1 Williams, Sharon Request for 12 month moratorium to investigate project safety.
72 1 Williams, Tina Request to set turbines back from roads, views of the St. Lawrence River,
and village.
72 2 Williams, Tina The SEQR process should allow for input from interested parties.
72 3 Williams, Tina Feels the SDEIS is incomplete.
73 1 Grant, Cindy General concerns over health and safety of residents within 2 mile radius of
project.
73 2 Grant, Cindy Believes residents will be harmed by low frequency noise, or infrasound.
Noise should be measured using dBC in addition to dBA.
73 3 Grant, Cindy Project area is highly populated. Other wind farms are in less populated
areas, far enough away so people are not harmed.
Typically industrial wind turbines cause the most disturbance at night, when
73 4 Grant, Cindy the winds at ground level are still but the wind up at the hub height are still
blowing, and the noise from the turbine will be very noticeable in the home.
Noise studies done at an industrial wind project sites after they have been
73 5 Grant, Cindy up and running often show that they are making much more noise than the
developers said they would, but by then it's too late.
73 6 Grant, Cindy Also believes that the residents will be harmed by the shadow flicker effect,
especially people who already suffer from migraines, epilepsy and vertigo.
73 7 Grant, Cindy Believes that large oil companies are not good to do business with, and
residents may never see compensation citing Exxon Valdez as an example.
3-118
004084
Table 3-2
Agency/
Organization
Believes there is also no way that the town of Cape Vincent residents will
ever be able force developer to make right any violations against the
73 8 Grant, Cindy residents that live near this project unless proper regulations are put into
effect now. Before this project is allowed, requests more safeguards in
place now.
Expressed concern over raptor area. States that issues are barely
73 9 Smith, Gerry addressed, and they are not addressed significantly, especially on the part
of the field teams that were out looking at these birds and bats, specifically
short-eared owl. Also, disagrees with breeding bird summary.
73 10 Metzger, Don The SDEIS doesn't state anything about alternative two. What is alternative
two?
The public only gets ten days in which to consider the final Environmental
73 11 Metzger, Don Impact Statement. Believes that ten days to consider a project of this size is
insufficient for the community.
Do the foundations go, the collection cables, the 37 miles of underground
73 12 Metzger, Don collection cables? At one point a depth of 44 inches is used. Believes that's
a misprint.
Concerns about the safety and integrity of the Development Authority of the
North Country's western Jefferson County regional water line, the 12-inch
interior diameter water line that goes for 25 miles from Cape Vincent to
73 13 Metzger, Don Glen Park, serving four towns, five villages, the General Brown School, and
many, many water hydrants. That is a potential -- with the poles there being
set 15 feet into the ground, there is a physical integrity, physical security
problem.
73 14 White, Beth In favor of accepting SDEIS and supports the proposed wind farm.
73 15 Doull, Melodee States that the project is not in compliance with the local zoning ordinance
and land use regulations.
73 16 Doull, Melodee Claims setbacks have not been legally adopted.
73 17 Doull, Melodee Claims downsizing is not enough to mitigate visual impacts.
73 18 Doull, Melodee There is no mention of the transmission lines; there is no mention of secure
3-119
004085
Table 3-2
Agency/
Organization
funds to implement the plan. Will there be bonding? What happens when
the wind farm is sold to another company?
What happens when the wind farm is sold to another company? Will the
73 19 Doull, Melodee new company adhere to the decommissioning plan as described in the
SDEIS?
73 20 Doull, Melodee A mitigation solution would be to increase turbine setbacks in order to
lessen the effects of flicker, noise, and vibration concerns.
73 21 Hirschey, Urban Feels 5 months are necessary for SDEIS comment period.
73 22 Hirschey, Urban Disagrees with separating two (BP and Acciona) Cape Vincent projects.
73 23 Hirschey, Urban Concerned that Lyme project was not considered in projects within 13 miles
of site.
73 24 Ciocci, Theresa Concerns over overall impacts to human health.
73 25 Byrne, John Expressed concern over 5 dB increase in background noise.
73 26 Docteur, David Why is this area even considered when there can be visual and health
impacts? Specifically, disease from vibrations.
Claims a 1,250-foot setback from a nonparticipating residence results in
putting the generating plant practically on top of them and will cause
73 27 Docteur, David intolerable conditions with the shadows, flicker, and noise. Says it is
recommended that there be a one-and-a-half-mile setback, not two-tenths
of a mile.
73 28 Docteur, David Land will become undevelopable. Why does St. Lawrence want to do this?
73 29 White, Kenneth In favor of accepting SDEIS and supports the proposed wind farm.
73 30 King, Gary In favor of accepting SDEIS and supports the proposed wind farm.
73 31 Chapman, Tom Does not feel that wind energy is green energy and does not create jobs.
73 32 Lawrence, Rick Supports the proposed wind farm.
73 33 Johnson, Warren Expresses concern over overhead lines and requests burying lines
underground.
73 33 LeTendre, Jerry Disagrees with SDEIS findings on impacts to birds.
3-120
004086
Table 3-2
Agency/
Organization
73 34 Sirianni, Paul Supports the proposed wind farm.
73 35 Clark, John Supports the proposed wind farm.
73 36 Gauthier, Bob Supports the proposed wind farm.
73 37 Mason, Paul Supports the proposed wind farm.
73 38 Kenney, Gail Resident of Wolfe Island warns of negative impacts.
73 39 Brown, Tom Wants to know why other potentially less visually intrusive sites were not
considered.
73 40 Brown, Tom Disagrees with exempting alternative sites.
Disagrees that during operation approximately 48 residences would have a
73 41 Ebbing, Chuck nominal project sound level slightly above the project impact threshold of
60B over the estimated 42 dBA.
Challenges Table 1-1 when it talks about impacts, potential impacts and
73 42 Ebbing, Chuck what they're going to do. Disagrees that the project will not have significant
noise impacts during operation.
73 43 Ebbing, Chuck Challenges overall noise study, claims it is biased.
73 44 Schneider, Clif Challenges overall noise study, says estimate of ambient at 37 dB is about
10 dB high.
73 45 Haskins, Janet Concern over living adjacent to turbines.
Insists that the town and the developer fully give rights under the SEQR
73 46 Bragdon, Brooke law, the National Federal Historic Preservation laws, and other -- the local
zoning law.
73 47 Cullen, Cyril How is decommissioning going to be funded, bonding, no bonding,
deposits, etc.?
73 48 Cullen, Cyril Requests for a moratorium and zoning law.
73 49 Kobylarz, Virginia Climate may not be adequate for wind power.
73 50 Kobylarz, Virginia Concern over migrating birds.
73 51 Kobylarz, Virginia Who is responsible for repair, decommissioning, and restoration?
73 52 Radley, Jarvis Supports SDEIS findings and the proposed wind farm.
3-121
004087
Table 3-2
Agency/
Organization
Requests identification of liability in the case of damages caused by the
73 53 Jolliff, Tom wind farm to persons or property and how they would be handled, such as
by insurance.
73 54 McTaggert, Pat Requests further health studies.
73 55 Boss, Sally Projects turbines will take-up 88% of land mass and requests a moratorium.
73 56 White, Harvey Supports SDEIS findings and the proposed wind farm.
73 57 Chase, Hester Requests clarification on sound/distance relationship.
73 58 Chase, Hester Proposes development of alternatives.
73 59 Falcon, Mary Concerns over red light at night.
73 60 Falcon, Mary Concerns over protecting water during construction.
73 61 Falcon, Mary Concerns over subsidies - feels that citizens will be paying for putting it up
and taking it down.
73 62 Bourquin, Don Supports the Planning Board.
73 63 Bowers, Bert Does not believe 79.5 megawatts of power will be produced.
Production of this clean, renewable energy will not create air or water
73 64 Bowers, Bert pollution or add to greenhouse gases in the atmosphere. This statement
again is totally false as it pretends that industrial wind power can be an
independent stand-alone source of power.
73 65 Bowers, Bert Concern over 10 to 15-decibel sound level increase.
73 66 Falcon, Spencer Concern over psychiatric impact.
73 67 DeLong, Sam Concern over the effect on his vertigo and migraine health conditions.
73 68 Edgar, Chris Supports the SDEIS and proposed wind farm.
73 69 Moehs, Charles Concerns over low frequency noise, cardiac issues, children, elderly, and
learning disabilities, and sees no way of mitigating these issues.
73 70 Metzger, Don Concerns over decommissioning, with regard to long-distance transmission
line that would run to Lyme.
73 71 Metzger, Don Concern over proposed 485 turbines all within 17 miles of the building they
are in.
3-122
004088
Table 3-2
Agency/
Organization
Claims there will be a degradation of signal with the cell phone, with the AM
73 72 Metzger, Don radio, with the FM radio, with wireless communication, wireless internet,
issues with the VHF and UHF communication for police, fire, emergency
responders.
73 73 Ciocci, Theresa General health concerns.
73 74 Ciocci, Theresa Asks for liability of damages for both short- and long-term outcomes of
health risks.
73 75 Ciocci, Theresa Concerns regarding sleep deprivation.
Shadow flicker concerns, citing Maine Medical Association results of
73 76 Ciocci, Theresa shadow flicker and noise emissions from turbines on humans living within
3500 feet of industrial turbines
73 77 Schneider, Clif Finds SDEIS exceedances of acceptable noise levels.
73 78 Ebbing, Chuck Concern over night-time noise conditions. Overall concern with noise
study.
Requests ambient noise is measured in the area directly beside each
proposed turbine locations so that you have an accurate noise baseline to
73 79 Grant, Cindy start with and is performed by an independent acoustic engineer that is
chosen by the Town Board but paid for by the developer. Stresses
importance of measuring low frequency noise.
73 80 Grant, Cindy Requests testing of drinking water.
73 81 Grant, Cindy Suggests a buyout clause.
There is no further communication after this letter from Acciona to the
73 82 Bragdon, Brooke State, no follow-up whatsoever in terms of delineating what the adverse
impacts are, and no discussion whatsoever about relocating turbines or
coming up with greater setbacks.
73 83 Byrne, John Questions background noise levels. Feels that noise study is flawed.
What if a well goes dry while blasting for a turbine foundation is done
74 1 various landowners nearby? According to the SDEIS, pre-construction and post-construction
hydrological studies will be conducted to determine if project construction is
3-123
004089
Table 3-2
Agency/
Organization
responsible for any wells going dry. But what about the time between the
blasting and the post-construction studies? Will the landowner have to find
an alternative water supply and pay for it out of his own pocket, while
waiting for the post-construction study to be completed?
1
Source 73 represents oral comments received during May 16, 2009 Public Hearing.
3-124
004090
Table 4-1
Comment
ID 1
Alternatives Stilwell, David and Tim Sullivan USFWS 2.44
Alternatives Falcon, Mary 12.10
Alternatives Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 22.2
Alternatives Zovistoski, Mary 38.7
Alternatives Hirschey, Urban C. 40.7
Cultural Resources Uhlig, Robert Stone Building Appreciation Society 9.1
Cultural Resources Falcon, Mary 12.5
Cultural Resources Chase, Hester 14.5
Cultural Resources Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.9
Cultural Resources Gormel, Thomas 31.1
Cultural Resources Gormel, Joyce 33.1
4-2
004091
Table 4-1
Comment
ID 1
Cultural Resources Zovistoski, Mary 38.3
Cultural Resources Hirschey, Urban C. 40.3
Jefferson County Historical Society,
Cultural Resources Abel, Timothy J., PhD 69.1
Watertown, NY
Cultural Resources Hanson, Rollin V 71.2
Cultural Resources Boss, Sarah F. 79.1
Cumulative Impacts Stilwell, David and Tim Sullivan USFWS 2.43
Cumulative Impacts Caddick, Jennifer and Aaron Vogel 19.1
Land Trust
Cumulative Impacts Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.7
Cumulative Impacts Brown, Thomas 65.2
Cumulative Impacts Docteur, David 113.3
Cumulative Impacts Hambrose, Johanna 113.8
Cumulative Impacts Hanson, Rollin V 113.9
Cumulative Impacts Henchy, Harold 113.10
Cumulative Impacts Hludzenski, Ed 113.13
Cumulative Impacts Metzger, Don 113.15a
Cumulative Impacts Schneider, Clifford P. 113.17a
4-3
004092
Table 4-1
Comment
ID 1
4-4
004093
Table 4-1
Comment
ID 1
4-5
004094
Table 4-1
Comment
ID 1
Land Trust
Land Trust
Ecological Resources Faulknham, R. Dennis 24.2
Ecological Resources Gormel, Thomas 29.1
Ecological Resources Hirschey, Urban C. 43.1
Ecological Resources Liner, Jillian M. Audubon New York 47.1
Ecological Resources Duehkind, Winnie 63.1
Ecological Resources Walker, Tom and Mabel 64.1
Ecological Resources Crossby, William and Barbara 68.1
Ecological Resources Article: Los Angeles Times 70.4
Brown, Thomas; R. Dennis
Ecological Resources Faulknham, Gerard LeTendre, and 104.1
Clifford Schneider
Ecological Resources Smith, Gerald 109.1
Ecological Resources Docteur, David H. 110.2
Ecological Resources Schneider, Clifford P. 111.7
4-6
004095
Table 4-1
Comment
ID 1
Resources
Resources
Endangered Species
Endangered Species
Endangered Species
Endangered Species
Endangered Species
Endangered Species
Endangered Species
4-7
004096
Table 4-1
Comment
ID 1
Facility Layout and Design Falcon, Mary 12.6
Facility Layout and Design Petras, Leigh and James 16.1
Facility Layout and Design Vail, Alan 26.6
4-8
004097
Table 4-1
Comment
ID 1
Facility Layout and Design Brown, Thomas 93.1
Facility Layout and Design Wiley, Karen 99.2
Facility Layout and Design Schneider, Clifford P. 111.1
Facility Layout and Design Byrne, John 113.2a
Facility Layout and Design Metzger, Don 113.15b
Facility Layout and Design Reinhart, Marianna 113.16a
Facility Layout and Design Reinhart, Marianna 113.16b
General/Miscellaneous Chase, Hester 14.15
General/Miscellaneous Gaudette, Richard and Jan 15.1
General/Miscellaneous Dziekan, Andrew 17.1
General/Miscellaneous Merchant, Jerry 20.1
General/Miscellaneous Zovistoski, Mary 38.4
General/Miscellaneous Bracket, Mr. and Mrs. Montgomery 46.1
General/Miscellaneous Article: Source Unknown 70.5
General/Miscellaneous Pressly, Nicholas 81.6
General/Miscellaneous Bouchard, Gerry and Michelle 84.1
General/Miscellaneous Internet Article: Daily-John.com 90.1
General/Miscellaneous Gormel, Thomas 97.1
General/Miscellaneous Wiley, Karen 99.5
General/Miscellaneous Graf, David 100.1
General/Miscellaneous Callery, Judith Anne 101.1
4-9
004098
Table 4-1
Comment
ID 1
General/Miscellaneous Kemmis, Richard J. 102.1
General/Miscellaneous Brown, Thomas 103.1
General/Miscellaneous Brooks, Colin 107.3
General/Miscellaneous Bragdon, Brooks 108.1
Land Use and Zoning Walker, Tom and Mabel 64.2
Land Use and Zoning Article: Watertown Daily Times 70.3
Land Use and Zoning Boss, Sarah F. 79.2
Land Use and Zoning Cape Vincent Zoning Law 83.3
Land Use and Zoning - Agriculture Davis, Andrew NYSDPS 4.6
Noise Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 7.7
Noise LeTendre, Gerard 11.9
Noise Chase, Hester 14.7
Noise Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.8
Noise Jury, Charles 25.1
Noise Hirschey, Urban C. 43.7
Letter to Editor: Watertown Daily
Noise 94.1
Times
Noise Article: Utica Observer Dispatch 106.2
4-10
004099
Table 4-1
Comment
ID 1
Noise Letter: NYSDEC 111.9
Noise Schneider, Clifford P. 113.17b
Decommissioning
Decommissioning
Physiography, Geology and Soils Macura, Daniel 61.1
Physiography, Geology, and Soils Tomasik, Steven for Jack Nasca NYSDEC 1.12
Physiography, Geology, and Soils Hirschey, Urban C. 40.10
Physiography, Geology, and Soils Boss, Sarah F. 79.7
Chase, Hester 14.2
Construction
Dimmick, Kris Bernier, Carr, and Associates 112.1
Soils/Wildlife
Falcon, Mary 12.7
Benefits
Chase, Hester 14.8
Benefits
Chase, Hester 14.9
Benefits
Gormel, Thomas 27.1
Benefits
4-11
004100
Table 4-1
Comment
ID 1
Benefits
Benefits
Gormel, Joyce 75.6
Benefits
Boss, Sarah F. 79.4
Benefits
Gormel, Joyce 91.1
Benefits
Brooks, Colin 107.2
Benefits
Hirschey, Urban C. 113.12b
Benefits
Benefits
Benefits
Benefits
Benefits
Benefits
Benefits
Benefits
Benefits
Recreation Wiley, Karen 99.4
Safety and Security Davis, Andrew NYSDPS 4.46
4-12
004101
Table 4-1
Comment
ID 1
Safety and Security Falcon, Spencer, MD 13.1
Safety and Security Chase, Hester 14.6
Safety and Security Zovistoski, Mary 38.2
Safety and Security Boss, Mark 45.1
Safety and Security Moehs, Charles, MD, MPH 62.1
Safety and Security Freislich, Michele L. 73.1
Safety and Security Gormel, Joyce 75.4
Safety and Security Pundt, Art 76.1
Safety and Security Wiley, Karen 99.6
Safety and Security Haskins, Janet and James 105.1
Safety and Security Docteur, David H. 110.1
Safety and Security E-Mail 110.3
Safety and Security Hludzenski, Ed 113.14
Boss, Sarah F. 79.14
Design
Moehs, Charles, MD, MPH 92.1
Design
SEQR Process Falcon, Mary 12.4
Land Trust
Land Trust
SEQR Process Hanson, Rollin V 71.1
SEQR Process Simpson, Carol 74.1
SEQR Process Gormel, Joyce 75.1
SEQR Process Boss, Sarah F. 79.3
4-13
004102
Table 4-1
Comment
ID 1
SEQR Process Dziekan, Andrew 87.1
SEQR Process Levy, Ann E. 96.1
SEQR Process Nasca, Jack NYSDEC 113.19
Socioeconomics LeTendre, Gerard 11.7
Socioeconomics Caddick, Jennifer and Aaron Vogel 19.8
Land Trust
Socioeconomics Gormel, Thomas 32.1
Socioeconomics Hludzenski, Kathryn A. 66.1
Socioeconomics Boss, Sarah F. 79.13
Socioeconomics Schneider, Clifford P. 111.4
Traffic and Transportation Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.4
Traffic and Transportation Gormel, Thomas 28.1
Traffic and Transportation Zovistoski, Mary 38.1
4-14
004103
Table 4-1
Comment
ID 1
Traffic and Transportation Hirschey, Urban C. 43.2
Traffic and Transportation Boss, Mark 45.2
Traffic and Transportation Boss, Sarah F. 79.11
Traffic and Transportation/
Construction
Utilities and Community Services Hirschey, Urban C. 39.1
Utilities and Community Services Boss, Mark 45.3
Visual Resources Tomasik, Steven for Jack Nasca NYSDEC 1.13b
Visual Resources Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 7.6
Visual Resources Harris, Michael 8.1
Visual Resources Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.10
4-15
004104
Table 4-1
Comment
ID 1
Visual Resources Gregory, Maureen Wiley 50.2
Visual Resources Doull, Melodee 60.1
Visual Resources Gormel, Thomas 97.2
Visual Resources Brooks, Colin 107.1
Visual Resources Boss, Sally 113.1
Visual Resources Byrne, John 113.2b
Visual Resources Hambrose, Harold 113.7
Visual Resources Hirschey, Sally 113.11
Visual Resources Hirschey, Urban C. 113.12a
Visual Resources/Cultural Resources Bragdon, Brooks 49.1
Visual Resources/Noise Wiley, Karen 99.7
Visual Resources/Recreation/Cultural
Resources
Visual Resources/Safety and Security Chase, Hester 14.16
Water Resources Tomasik, Steven for Jack Nasca NYSDEC 1.13a
4-16
004105
Table 4-1
Comment
ID 1
Water Resources Davis, Andrew NYSDPS 4.15
Land Trust
Land Trust
Water Resources Macura, Daniel 61.2
Valley, NY
Valley, NY
Valley, NY
Valley, NY
Valley, NY
1
Comment ID represents a combination of the Comment Letter ID (before decimal) and Comment ID within letter (after decimal) as
identified in Table 3-1.
4-17
004106
Table 4-2
Alternatives Byrne, Tatyana 25.16
Alternatives Docteur, Mary 31.3
Alternatives Docteur, David 73.26
Alternatives Brown, Tom 73.40
Alternatives Chase, Hester 73.58
Alternatives/Noise Byrne, Tatyana 25.17
Alternatives/Noise Docteur, Mary 31.4
Climate and Air Quality Stilwell, David USFWS 1.3
Climate and Air Quality Byrne, Tatyana 25.11
Climate and Air Quality LaMora, David 45.2
Climate and Air Quality Macura, David 49.5
Construction Tomasik, Stephen NYSDEC 2.23
Construction Boss, Sarah 17.4
Construction Hubbard, Sandy 42.4
Construction Macura, David 49.2
Construction Metzger, Don 73.12
4-18
004107
Table 4-2
Cultural Resources Daub, Patricia 27.1
Cumulative Impacts Tomasik, Stephen NYSDEC 2.3
Cumulative Impacts Byrne, Tatyana 25.14
Cumulative Impacts Docteur, Mary 31.1
Cumulative Impacts Hirschey, Urban 39.2
Cumulative Impacts Hludzenski, Kathryn 41.2
Cumulative Impacts Simpson, Carol 64.1
Decommissioning Davis, Andrew NYSDPS 4.21
Decommissioning Boss, Mark 16.6
Decommissioning Bragdon, Brooks 20.3
4-19
004108
Table 4-2
Decommissioning Macura, Joan 50.6
Decommissioning Cullen, Cyril 73.47
Decommissioning Kobylarz, Virginia 73.51
Decommissioning Metzger, Don 73.70
4-20
004109
Table 4-2
Ecological Resources Lyons, Thomas NYSOPRHP 7.5
Ecological Resources Bell, Dolores and Michael 15.1
4-21
004110
Table 4-2
Ecological Resources Estelle, Douglas and Michelle 33.1
4-22
004111
Table 4-2
Ecological Resources Radley, Jerry 57.3
Ecological Resources Uhlig, Bob and Ruth 68.2
Ecological Resources Smith, Gerry 73.9
Ecological Resources LeTendre, Jerry 73.33
Ecological Resources Kobylarz, Virginia 73.50
Endangered Species
Endangered Species
Endangered Species
Endangered Species
4-23
004112
Table 4-2
Facility Layout and Design Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 11.10
Facility Layout and Design Boss, Sarah 18.1
Facility Layout and Design Metzger, Donald 54.5
Facility Layout and Design Grant, Cindy 73.3
Facility Layout and Design Johnson, Warren 73.33
Facility Layout and Design/Alternatives Boss, Mark 16.1
Facility Layout and Design/Alternatives Byrne, Tatyana 25.1
General Davis, Andrew NYSDPS 4.7
General Docteur, Dennis and Donald 29.1
General Docteur, Lee 30.1
Groundwater various landowners 74.1
Land Use and Zoning Zappieri, Jeff NYSDOS 3.1
Land Use and Zoning Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 11.2
4-24
004113
Table 4-3
Comment
ID 1
Jefferson County Historical
Abel, Timothy J., PhD 6/4/2007 Cultural Resources 69.1
Society
Article: Los Angeles Times No Date Ecological Resources 70.4
Article: Source Unknown No Date General/Miscellaneous 70.5
Article: Utica Observer Dispatch 3/8/2007 Noise 106.2
Article: Watertown Daily Times 5/31/2007 Land Use and Zoning 70.3
Boss, Mark 6/10/2007 Safety and Security 45.1
Boss, Mark 6/10/2007 Traffic and Transportation 45.2
Boss, Mark 6/10/2007 45.3
Services
Boss, Sally 3/24/2007 Visual Resources 113.1
Boss, Sarah F. 6/1/2007 Cultural Resources 79.1
Boss, Sarah F. 6/1/2007 Land Use and Zoning 79.2
Boss, Sarah F. 6/1/2007 SEQR Process 79.3
Boss, Sarah F. 6/1/2007 79.4
and Benefits
Boss, Sarah F. 6/1/2007 79.7
Soils
Boss, Sarah F. 6/1/2007 Traffic and Transportation 79.11
Boss, Sarah F. 6/1/2007 Socioeconomics 79.13
Boss, Sarah F. 6/1/2007 Safety and Security / Facility 79.14
4-35
004114
Table 4-3
Comment
ID 1
Layout and Design
Bouchard, Gerry and Michelle 3/29/2007 General/Miscellaneous 84.1
Bracket, Mr. and Mrs. Montgomery 6/11/2007 General/Miscellaneous 46.1
Visual Resources / Cultural
Bragdon, Brooks 6/7/2007 49.1
Resources
Bragdon, Brooks 6/13/2007 General/Miscellaneous 108.1
Brooks, Colin 3/8/2007 Visual Resources 107.1
Brooks, Colin 3/8/2007 107.2
and Benefits
Brooks, Colin 3/8/2007 General/Miscellaneous 107.3
Agriculture
Agriculture
Agriculture
Brown, Thomas 6/4/2007 Cumulative Impacts 65.2
Brown, Thomas 3/24/2007 Facility Layout and Design 93.1
Brown, Thomas 2/21/2007 General/Miscellaneous 103.1
Brown, Thomas; R. Dennis Faulknham,
Gerard LeTendre, and Clifford 2/24/2007 Ecological Resources 104.1
Schneider
Byrne, John 3/24/2007 Facility Layout and Design 113.2a
4-36
004115
Table 4-3
Comment
ID 1
Byrne, John 3/24/2007 Visual Resources 113.2b
Caddick, Jennifer and Aaron Vogel 6/14/2007 Cumulative Impacts 19.1
Land Trust
Land Trust
Land Trust
Land Trust
Land Trust
Land Trust
Land Trust
Caddick, Jennifer and Aaron Vogel 6/14/2007 Socioeconomics 19.8
Land Trust
Callery, Judith Anne 2/20/2007 General/Miscellaneous 101.1
Cape Vincent Zoning Law 3/24/2007 Land Use and Zoning 83.3
Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 6/15/2007 Visual Resources 7.6
Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 6/15/2007 Noise 7.7
Chase, Hester 6/15/2007 14.2
Soils / Construction
Chase, Hester 6/15/2007 Cultural Resources 14.5
4-37
004116
Table 4-3
Comment
ID 1
Chase, Hester 6/15/2007 Safety and Security 14.6
Chase, Hester 6/15/2007 14.8
and Benefits
Chase, Hester 6/15/2007 14.9
and Benefits
Chase, Hester 6/15/2007 General/Miscellaneous 14.15
Visual Resources / Safety and
Chase, Hester 6/15/2007 14.16
Security
Crossby, William and Barbara 6/4/2007 Ecological Resources 68.1
Agriculture
Davis, Andrew NYSDPS 6/13/2007 Soils / Construction / 4.7
Agriculture
4-38
004117
Table 4-3
Comment
ID 1
Resources
Resources
Davis, Andrew NYSDPS 6/13/2007 Water Resources 4.15
Davis, Andrew NYSDPS 6/13/2007 Threatened and Endangered 4.24
Species
Traffic and Transportation /
Construction
Visual Resources /
Davis, Andrew NYSDPS 6/13/2007 Recreation / Cultural 4.32
Resources
4-39
004118
Table 4-3
Comment
ID 1
Dimmick, Kris Bernier, Carr, and Associates 6/28/2007 Soils / Construction / 112.1
Agriculture
Docteur, David 3/24/2007 Cumulative Impacts 113.3
Docteur, David H. 6/9/2007 Safety and Security 110.1
Docteur, David H. 6/9/2007 Ecological Resources 110.2
Duehkind, Winnie 6/5/2007 Ecological Resources 63.1
Dziekan, Andrew 6/14/2007 General/Miscellaneous 17.1
Dziekan, Andrew 3/19/2007 SEQR Process 87.1
E-Mail 6/9/2007 Safety and Security 110.3
4-40
004119
Table 4-3
Comment
ID 1
Falcon, Mary 6/14/2007 SEQR Process 12.4
Falcon, Mary 6/14/2007 Cultural Resources 12.5
Falcon, Mary 6/14/2007 Facility Layout and Design 12.6
Falcon, Mary 6/14/2007 12.7
and Benefits
Falcon, Mary 6/14/2007 Alternatives 12.10
Falcon, Spencer, MD 6/14/2007 Safety and Security 13.1
Faulknham, R. Dennis 6/12/2007 Ecological Resources 24.2
Freislich, Michele L. No Date Safety and Security 73.1
4-41
004120
Table 4-3
Comment
ID 1
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/13/2007 Traffic and Transportation 21.4
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/13/2007 Cumulative Impacts 21.7
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/13/2007 Noise 21.8
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/13/2007 Cultural Resources 21.9
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/13/2007 Visual Resources 21.10
Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 6/14/2007 Alternatives 22.2
Gaudette, Richard and Jan No Date General/Miscellaneous 15.1
Gormel, Joyce 6/11/2007 Cultural Resources 33.1
4-42
004121
Table 4-3
Comment
ID 1
Gormel, Joyce 6/5/2007 SEQR Process 75.1
Gormel, Joyce 6/5/2007 Safety and Security 75.4
Gormel, Joyce 6/5/2007 75.6
and Benefits
Gormel, Joyce 3/24/2007 91.1
and Benefits
Gormel, Thomas 6/11/2007 27.1
and Benefits
Gormel, Thomas 6/11/2007 Traffic and Transportation 28.1
Gormel, Thomas 6/11/2007 Ecological Resources 29.1
Gormel, Thomas 6/11/2007 Cultural Resources 31.1
Gormel, Thomas 6/11/2007 Socioeconomics 32.1
Gormel, Thomas 3/24/2007 General/Miscellaneous 97.1
Gormel, Thomas 3/24/2007 Visual Resources 97.2
Graf, David 3/14/2007 General/Miscellaneous 100.1
Gregory, Maureen Wiley 6/6/2007 Visual Resources 50.2
Gregory, Maureen Wiley 6/6/2007 Project Purpose, Public Need 52.1
4-43
004122
Table 4-3
Comment
ID 1
and Benefits
Gregory, Maureen Wiley 6/6/2007 58.1
and Benefits
Hambrose, Harold 3/24/2007 Visual Resources 113.7
Hambrose, Johanna 3/24/2007 Cumulative Impacts 113.8
Hanson, Rollin V No Date SEQR Process 71.1
Hanson, Rollin V No Date Cultural Resources 71.2
Hanson, Rollin V 3/24/2007 Cumulative Impacts 113.9
Harris, Michael 6/15/2007 Visual Resources 8.1
Haskins, Janet and James 3/7/2007 Safety and Security 105.1
Henchy, Harold 3/24/2007 Cumulative Impacts 113.10
Hirschey, Sally 3/24/2007 Visual Resources 113.11
Hirschey, Urban C. 6/12/2007 39.1
Services
Hirschey, Urban C. 6/12/2007 Cultural Resources 40.3
Hirschey, Urban C. 6/12/2007 Alternatives 40.7
Hirschey, Urban C. 6/12/2007 Physiography, Geology, and 40.10
4-44
004123
Table 4-3
Comment
ID 1
Soils
Hirschey, Urban C. 6/10/2007 Ecological Resources 43.1
Hirschey, Urban C. 6/10/2007 Traffic and Transportation 43.2
Hirschey, Urban C. 6/10/2007 Noise 43.7
Hirschey, Urban C. 3/24/2007 Visual Resources 113.12a
Hirschey, Urban C. 3/24/2007 113.12b
and Benefits
Hludzenski, Ed 3/24/2007 Cumulative Impacts 113.13
Hludzenski, Ed 3/24/2007 Safety and Security 113.14
Hludzenski, Kathryn A. 6/5/2007 Socioeconomics 66.1
Internet Article: Daily-John.com No Date General/Miscellaneous 90.1
Jury, Charles No Date Noise 25.1
Kemmis, Richard J. 2/20/2007 General/Miscellaneous 102.1
4-45
004124
Table 4-3
Comment
ID 1
LeTendre, Gerard 6/14/2007 Socioeconomics 11.7
Letter to Editor: Watertown Daily Times 3/18/2007 Noise 94.1
Letter: NYSDEC 4/6/2007 Noise 111.9
Levy, Ann E. 3/24/2007 SEQR Process 96.1
Liner, Jillian M. Audubon New York 6/11/2007 Ecological Resources 47.1
Physiography, Geology and
Macura, Daniel No Date 61.1
Soils
Macura, Daniel No Date Water Resources 61.2
Merchant, Jerry 6/13/2007 General/Miscellaneous 20.1
Metzger, Don 3/24/2007 Cumulative Impacts 113.15a
Metzger, Don 3/24/2007 Facility Layout and Design 113.15b
Moehs, Charles, MD, MPH 6/7/2007 Safety and Security 62.1
Safety and Security / Facility
Moehs, Charles, MD, MPH 3/24/2007 92.1
Layout and Design
Soils
Soils
Soils
Nasca, Jack NYSDEC 3/24/2007 SEQR Process 113.19
Petras, Leigh and James 6/14/2007 Facility Layout and Design 16.1
and Benefits
4-46
004125
Table 4-3
Comment
ID 1
and Benefits
and Benefits
and Benefits
and Benefits
and Benefits
Pressly, Nicholas 5/29/2007 General/Miscellaneous 81.6
Pundt, Art 6/1/2007 Safety and Security 76.1
Reinhart, Marianna 3/24/2007 Facility Layout and Design 113.16a
Reinhart, Marianna 3/24/2007 Facility Layout and Design 113.16b
Schneider, Clifford P. 6/12/2007 Facility Layout and Design 111.1
Schneider, Clifford P. 6/12/2007 Socioeconomics 111.4
Schneider, Clifford P. 6/12/2007 Ecological Resources 111.7
4-47
004126
Table 4-3
Comment
ID 1
Schneider, Clifford P. 3/24/2007 Cumulative Impacts 113.17a
Schneider, Clifford P. 3/25/2007 Noise 113.17b
Simpson, Carol 6/5/2007 SEQR Process 74.1
Smith, Gerald 6/8/2007 Ecological Resources 109.1
and Benefits
and Benefits
Soils / Ecological Resources
4-48
004127
Table 4-3
Comment
ID 1
Species
Species
Species
Species
Species
Stilwell, David and Tim Sullivan USFWS 6/15/2007 Cumulative Impacts 2.43
Stilwell, David and Tim Sullivan USFWS 6/15/2007 Alternatives 2.44
4-49
004128
Table 4-3
Comment
ID 1
Decommissioning
Decommissioning
Tomasik, Steven for Jack Nasca NYSDEC 6/15/2007 Threatened and Endangered 1.11
Species
Soils
Tomasik, Steven for Jack Nasca NYSDEC 6/15/2007 Water Resources 1.13a
Tomasik, Steven for Jack Nasca NYSDEC 6/15/2007 Visual Resources 1.13b
Stone Building Appreciation
Uhlig, Robert 6/15/2007 Cultural Resources 9.1
Society
Vail, Alan 6/12/2007 Facility Layout and Design 26.6
4-50
004129
Table 4-3
Comment
ID 1
Walker, Tom and Mabel No Date Ecological Resources 64.1
Walker, Tom and Mabel No Date Land Use and Zoning 64.2
Wiley, Karen 2/16/2007 Facility Layout and Design 99.2
Wiley, Karen 2/16/2007 Recreation 99.4
Wiley, Karen 2/16/2007 General/Miscellaneous 99.5
Wiley, Karen 2/16/2007 Safety and Security 99.6
Wiley, Karen 2/16/2007 Visual Resources / Noise 99.7
Zovistoski, Mary 6/10/2007 Traffic and Transportation 38.1
Zovistoski, Mary 6/10/2007 Safety and Security 38.2
Zovistoski, Mary 6/10/2007 Cultural Resources 38.3
Zovistoski, Mary 6/10/2007 General/Miscellaneous 38.4
Zovistoski, Mary 6/10/2007 Alternatives 38.7
1
4-51
004130
Table 4-4
Comment
ID 1
Bell, Dolores and Michael 5/28/2009 Ecological Resources 15.1
Bell, Dolores and Michael 5/28/2009 Visual Resources 15.4
Bell, Dolores and Michael 5/28/2009 Operations and Maintenance 15.5
Bell, Dolores and Michael 5/28/2009 Noise/Visual Resources 15.7
Boss, Mark 5/25/2009 Facility Layout and Design/Alternatives 16.1
Boss, Mark 5/25/2009 Water Resources 16.3
Boss, Mark 5/25/2009 Decommissioning 16.6
Boss, Sally 5/16/2009 Land Use and Zoning 73.55
Boss, Sarah 5/26/2009 Construction 17.4
Boss, Sarah 5/26/2009 Operations and Maintenance 17.5
4-52
004131
Table 4-4
Comment
ID 1
Boss, Sarah 5/29/2009 Facility Layout and Design 18.1
Bourquin, Don 5/16/2009 Project Purpose, Public Need and Benefits 73.62
Bowers, Bert 5/16/2009 Noise 73.65
Bragdon, Brooks 5/28/2009 Decommissioning 20.3
4-53
004132
Table 4-4
Comment
ID 1
Brown, Mary Jane 5/28/2009 Visual Resources 21.1
Brown, Tom 5/16/2009 Visual Resources 73.39
Brown, Tom 5/16/2009 Alternatives 73.40
Burpee, Edith 5/28/2009 Visual Resources/Cumulative Impacts 22.1
Burton, Darrell 5/26/2009 SEQR Process 23.1
Burton, Marlene 5/26/2009 SEQR Process 24.1
Byrne, Tatyana 5/28/2009 Facility Layout and Design/Alternatives 25.1
Byrne, Tatyana 5/28/2009 Climate and Air Quality 25.11
4-54
004133
Table 4-4
Comment
ID 1
Byrne, Tatyana 5/28/2009 Cumulative Impacts 25.14
Byrne, Tatyana 5/28/2009 Alternatives 25.16
Byrne, Tatyana 5/28/2009 Alternatives/Noise 25.17
Byrne, Tatyana 5/28/2009 Telecommunications 25.26
4-55
004134
Table 4-4
Comment
ID 1
Chapman, Tom 5/16/2009 Project Purpose, Public Need and Benefits 73.31
4-56
004135
Table 4-4
Comment
ID 1
Chase, Hester 5/16/2009 Alternatives 73.58
Ciocci, Theresa 5/16/2009 Socioeconomics 73.74
Clark, John 5/16/2009 Project Purpose, Public Need and Benefits 73.35
Cullen, Cyril 5/16/2009 Decommissioning 73.47
Cullen, Cyril 5/16/2009 Land Use and Zoning 73.48
Cullen, Geoffrey 5/30/2009 Visual Resources 26.2
Cullen, Geoffrey 5/30/2009 Socioeconomics 26.3
Daub, Patricia 5/28/2009 Cultural Resources 27.1
Davis, Andrew NYSDPS 5/28/2009 General 4.7
Davis, Andrew NYSDPS 5/28/2009 SEQR Process 4.10
Davis, Andrew NYSDPS 5/28/2009 Telecommunications 4.15
4-57
004136
Table 4-4
Comment
ID 1
Davis, Andrew NYSDPS 5/28/2009 Operations and Maintenance 4.17
Davis, Andrew NYSDPS 5/28/2009 Decommissioning 4.21
DeLong, Sam 5/16/2009 Safety and Security 73.67
Docteur, David 5/28/2009 Visual Resources 28.2
Docteur, David 5/28/2009 Noise 28.3
Docteur, David 5/28/2009 Safety and Security 28.4
Docteur, David 5/16/2009 Alternatives 73.26
Docteur, David 5/16/2009 Socioeconomics 73.28
Docteur, Dennis and Donald 5/29/2009 General 29.1
Docteur, Lee No Date General 30.1
Docteur, Mary 5/28/2009 Cumulative Impacts 31.1
Docteur, Mary 5/28/2009 Socioeconomics 31.2
Docteur, Mary 5/28/2009 Alternatives 31.3
Docteur, Mary 5/28/2009 Alternatives/Noise 31.4
Docteur, Mary 5/28/2009 Visual Resources 31.10
4-58
004137
Table 4-4
Comment
ID 1
Docteur, Mary 5/28/2009 Telecommunications 31.13
Docteur, Paul 5/29/2009 Operations and Maintenance 32.3
Docteur, Paul 5/29/2009 SEQR Process 32.4
Doull, Melodee 5/28/2009 Operations and Maintenance 35.2
Edgar, Chris 5/16/2009 Project Purpose, Public Need and Benefits 73.68
Estelle, Douglas and Michelle 5/27/2009 Ecological Resources 33.1
4-59
004138
Table 4-4
Comment
ID 1
Falcon, Mary 5/16/2009 Socioeconomics 73.61
Falcon, Spencer 5/16/2009 Safety and Security 73.66
Freislich, John and Michelle 5/30/2009 Safety and Security 34.1
Freislich, John and Michelle 5/30/2009 Noise 34.2
Freislich, John and Michelle 5/30/2009 SEQR Process 34.3
Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 5/22/2009 Land Use and Zoning 11.2
Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 5/22/2009 Facility Layout and Design 11.10
Fucillo, Thomas Menter, Rudin & Trivelpiece, P.C. 5/22/2009 Water Resources 11.12
Gauthier, Bob 5/16/2009 Project Purpose, Public Need and Benefits 73.36
Grant, Cindy 5/16/2009 Facility Layout and Design 73.3
4-60
004139
Table 4-4
Comment
ID 1
Grant, Cindy 5/16/2009 Project Purpose, Public Need and Benefits 73.8
Haskins, Janet 5/16/2009 Safety and Security 73.45
Henchy, Harold 5/4/2009 Water Resources 36.1
Hetzler, Eileen 5/26/2009 Socioeconomics 37.1
Hetzler, Stephen 5/26/2009 Socioeconomics 38.1
Hirschey, Urban 5/28/2009 Cumulative Impacts 39.2
Hludzenski, Kathryn 5/26/2009 Safety and Security 40.1
Hludzenski, Kathryn 5/29/2009 Cumulative Impacts 41.2
Hubbard, Sandy 5/28/2009 Socioeconomics 42.3
Hubbard, Sandy 5/28/2009 Construction 42.4
Hubbard, Sandy 5/28/2009 Operations and Maintenance 42.5
Hubbard, Sandy 5/28/2009 Safety and Security 42.9
4-61
004140
Table 4-4
Comment
ID 1
Johnson, Warren 5/16/2009 Facility Layout and Design 73.33
Jolliff, Tom 5/16/2009 Operations and Maintenance 73.53
Jury, Charles No Date SEQR Process 43.1
Jury, Ellen No Date Telecommunications 44.1
Kenney, Gail 5/16/2009 Project Purpose, Public Need and Benefits 73.38
King, Gary 5/16/2009 Project Purpose, Public Need and Benefits 73.30
Kobylarz, Virginia 5/16/2009 Project Purpose, Public Need and Benefits 73.49
Kobylarz, Virginia 5/16/2009 Ecological Resources 73.50
Kobylarz, Virginia 5/16/2009 Decommissioning 73.51
LaMora, David 5/27/2009 Climate and Air Quality 45.2
LaMora, David 5/27/2009 Land Use and Zoning 45.5
LaMora, David 5/27/2009 Noise 45.6
Lawrence, Rick 5/16/2009 Project Purpose, Public Need and Benefits 73.32
Leschord, Paul No Date Land Use and Zoning 46.1
LeTendre, Gerard 5/29/2009 SEQR Process 47.2
4-62
004141
Table 4-4
Comment
ID 1
LeTendre, Jerry 5/16/2009 Ecological Resources 73.33
LeTendre, Jerry and Judith 5/19/2009 SEQR Process 48.1
Lyons, Thomas NYSOPRHP 5/29/2009 SEQR Process 7.1
Lyons, Thomas NYSOPRHP 5/29/2009 Ecological Resources 7.5
Lyons, Thomas NYSOPRHP 5/29/2009 Noise 7.8
Lyons, Thomas NYSOPRHP 5/29/2009 Project Purpose, Public Need and Benefits 7.9
Macura, David 5/27/2009 Construction 49.2
Macura, David 5/27/2009 Climate and Air Quality 49.5
Macura, David 5/27/2009 Safety and Security 49.7
Macura, Joan 5/28/2009 Water Resources 50.3
Macura, Joan 5/28/2009 Decommissioning 50.6
4-63
004142
Table 4-4
Comment
ID 1
Mahrer, Carolyn 5/19/2009 Safety and Security 51.1
Mahrer, Michael and Susan No Date Safety and Security 52.1
Mason, Elaine and Paul 5/19/2009 Project Purpose, Public Need and Benefits 53.1
Mason, Paul 5/16/2009 Project Purpose, Public Need and Benefits 73.37
McTaggert, Pat 5/16/2009 Safety and Security 73.54
Metzger, Don 5/16/2009 Construction 73.12
Metzger, Don 5/16/2009 Water Resources 73.13
Metzger, Don 5/16/2009 Decommissioning 73.70
Metzger, Don 5/16/2009 Visual Resources 73.71
Metzger, Don 5/16/2009 Telecommunications 73.72
Metzger, Donald 5/26/2009 Facility Layout and Design 54.5
Metzger, Donald 5/26/2009 Safety and Security 54.6
Metzger, Donald 5/26/2009 Telecommunications 54.8
Metzger, Donald 5/26/2009 Water Resources 54.10
Radley, Jarvis 5/16/2009 Project Purpose, Public Need and Benefits 73.52
Radley, Jerry No Date Safety and Security 57.2
Radley, Jerry No Date Ecological Resources 57.3
4-64
004143
Table 4-4
Comment
ID 1
Radley, Pattie Marie 5/28/2009 Project Purpose, Public Need and Benefits 58.1
Reed, Alfred and Maria 5/29/2009 Socioeconomics 59.1
Reed, Alfred and Maria 5/29/2009 Noise 59.2
Ross, Pat 5/19/2009 Safety and Security 60.1
Ryon, Doug 5/28/2009 Visual Resources 61.1
Schneider, Clifford 5/20/2009 Utilities and Community Services 62.14
4-65
004144
Table 4-4
Comment
ID 1
Schoeberlein, Donna 5/23/2009 Safety and Security 63.1
Schoeberlein, Donna 5/23/2009 Socioeconomics 63.2
Simpson, Carol 5/28/2009 Cumulative Impacts 64.1
Simpson, Carol 5/28/2009 Visual Resources 64.9
Simpson, Carol 5/28/2009 Noise 64.10
Simpson, Carol 5/28/2009 Telecommunications 64.11
Endangered Species
Endangered Species
Sirianni, Paul 5/16/2009 Project Purpose, Public Need and Benefits 73.34
Smith, Gerry 5/16/2009 Ecological Resources 73.9
Steinhouse, Barbara 5/29/2009 Safety and Security 66.1
Stilwell, David USFWS 5/29/2009 Climate and Air Quality 1.3
4-66
004145
Table 4-4
Comment
ID 1
Thomas, Carol and Dan 5/28/2009 Land Use and Zoning 67.6
Tomasik, Stephen NYSDEC 5/29/2009 Safety and Security 2.2
Tomasik, Stephen NYSDEC 5/29/2009 Cumulative Impacts 2.3
Tomasik, Stephen NYSDEC 5/29/2009 Physiography, Geology, and Soils 2.5
Tomasik, Stephen NYSDEC 5/29/2009 Physiography, Geology, and Soils/ Water 2.6
Resources
Endangered Species
4-67
004146
Table 4-4
Comment
ID 1
Endangered Species
Tomasik, Stephen NYSDEC 5/29/2009 Construction 2.23
Uhlig, Bob and Ruth 5/19/2009 Operations and Maintenance 68.1
Uhlig, Bob and Ruth 5/19/2009 Ecological Resources 68.2
Uhlig, Bob and Ruth 5/19/2009 Visual Resources 68.3
various landowners Groundwater 74.1
Vooder, Linda 5/19/2009 Safety and Security 69.1
White, Beth 5/16/2009 Project Purpose, Public Need and Benefits 73.14
White, Harvey 5/16/2009 Project Purpose, Public Need and Benefits 73.56
White, Kenneth 5/16/2009 Project Purpose, Public Need and Benefits 73.29
Wiley, Karen and Richard 5/16/2009 Safety and Security 70.1
Williams, Sharon 5/19/2009 Safety and Security 71.1
Williams, Tina 5/28/2009 Visual Resources 72.1
Williams, Tina 5/28/2009 SEQR Process 72.2
Williams, Tina 5/28/2009 Project Purpose, Public Need and Benefits 72.3
Zappieri, Jeff NYSDOS 5/26/2009 Land Use and Zoning 3.1
Zappieri, Jeff NYSDOS 5/26/2009 SEQR Process 3.12
1
4-68
004147
Table 4-5
Saint Lawrence Windpower Project DEIS Comments Requiring No Response
1
Comment ID Commenter Agency Date
4.49 Davis, Andrew State of New York Department of Public Service 6/13/2007
11.1 LeTendre, Gerard 6/14/2007
14.8 Chase, Hester 6/15/2007
15.1 Gaudette, Richard and Jan No Date
20.1 Merchant, Jerry 6/13/2007
27.1 Gormel, Thomas 6/11/2007
46.1 Bracket, Mr. and Mrs. Montgomery 6/11/2007
58.1 Gregory, Maureen Wiley 6/6/2007
70.2 LaPlante, J.O. 6/4/2007
70.3 Article: Watertown Daily Times No Date
70.4 Article: Los Angeles Times No Date
70.5 Article: Source Unknown No Date
81.6 Curriculum Vitae 5/29/2007
82.1 Cuda, Kenneth 4/5/2007
83.3 Cape Vincent Zoning Law 3/24/2007
87.1 Dziekan, Andrew 3/19/2007
96.1 Levy, Ann E. 3/24/2007
99.5 Wiley, Karen 2/16/2007
100.1 Graf, David No Date
103.1 Brown, Thomas 2/21/2007
106.2 Schneider, Clifford P. 3/12/2007
113.10 Henchy, Harold 3/24/2007
1
Comment ID represents a combination of the Comment Letter ID (before decimal) and Comment ID within letter
(after decimal) as identified in Table 3-1.
4-69
004148
Table 4-6
3.12 Zappieri, Jeff NYSDOS 5/26/2009
4.1 Davis, Andrew NYSDPS 5/28/2009
7.9 Lyons, Thomas NYSOPRHP 5/29/2009
10.2 Corbin, James FOX Broadcasting 5/12/2009
14.6 Riley, Thomas Onondaga Audubon 5/28/2009
20.14 Bragdon, Brooks 5/28/2009
23.1 Burton, Darrell 5/26/2009
24.1 Burton, Marlene 5/26/2009
29.1 Docteur, Dennis and Donald 5/29/2009
30.1 Docteur, Lee no date
34.3 Freislich, John and Michelle 5/30/2009
48.1 LeTendre, Jerry and Judith 5/19/2009
51.1 Mahrer, Carolyn 5/19/2009
52.1 Mahrer, Michael and Susan No date
53.1 Mason, Elaine and Paul 5/19/2009
54.9 Metzger, Donald 5/26/2009
58.1 Radley, Pattie Marie 5/28/2009
60.1 Ross, Pat 5/19/2009
61.1 Ryon, Doug 5/28/2009
63.1 Schoeberlein, Donna 5/23/2009
66.1 Steinhouse, Barbara 5/29/2009
69.1 Vooder, Linda 5/19/2009
4-70
004149
Table 4-6
70.1 Wiley, Karen and Richard 5/16/2009
71.1 Williams, Sharon 5/19/2009
72.3 Williams, Tina 5/28/2009
73.7 Grant, Cindy 5/16/2009
73.8 Grant, Cindy 5/16/2009
73.14 White, Beth 5/16/2009
73.20 Doull, Melodee 5/16/2009
73.25 Byrne, John 5/16/2009
73.27 Docteur, David 5/16/2009
73.29 White, Kenneth 5/16/2009
73.30 King, Gary 5/16/2009
73.32 Lawrence, Rick 5/16/2009
73.34 Sirianni, Paul 5/16/2009
73.35 Clark, John 5/16/2009
73.36 Gauthier, Bob 5/16/2009
73.37 Mason, Paul 5/16/2009
73.38 Kenney, Gail 5/16/2009
73.45 Haskins, Janet 5/16/2009
73.52 Radley, Jarvis 5/16/2009
73.56 White, Harvey 5/16/2009
73.61 Falcon, Mary 5/16/2009
73.62 Bourquin, Don 5/16/2009
73.68 Edgar, Chris 5/16/2009
73.71 Metzger, Don 5/16/2009
1
Comment ID represents a combination of the Comment Letter ID (before decimal) and
Comment ID within letter (after decimal) as identified in Table 3-2.
4-71
004150
53
1
52
48 St. Lawrence
50 Windpower, LLC
51
49 Proposed
47 St. Lawrence
Windpower
Project
39 44
46
40 FIGURE 2-1
Project Layout
41 45
and Boundary
42 Towns of Cape Vincent
37 and Lyme
Jefferson County, NY
MARCH
36 2010
35 43
30
34
Project Boundary
26 25
53 Turbine Locations
with 150 foot Temporary
29 33 Radius Laydown Area
32 Existing
23 31
Meteorological Tower
27
22 28 Proposed
24 Buried Interconnect
20
21
Permanent Access Road
17
19
Overhead
Transmission Line
18 2 Ancillary Facilities
16
10 1: Potential Cement Batch Plant
2: Collector Substation/O&M Building
3: Temporary Construction Work Area
4: Transmission Owner
Interconnection Substation
15
Project Location
12
13
14
3
2
9
Region: Northeastern US
8
Project Location
7
5
6
State: New York
3
4
St. Lawrence
1 Project Location
Jefferson
2 Herkimer
Lewis
Oswego
Cayuga Oneida
County: Jefferson
0 1,000 2,000
Feet
0 0.25 0.5
Miles
NOTES:
FEIS
MARCH 2010
Sources:
USGS 7.5 Minute
Topographic Quadrangles:
Cape Vincent N & S, Chaumont,
St. Lawrence, Clayton and Dexter, 1958.
4
Projection:
State Plane New York Central (feet)
NAD 83
T:\GIS\Acciona\St_Lawrence\Spatial\MXD\
FEIS\Fig_2_1_Project_Boundary.mxd
004151
53
1
52
48
St. Lawrence
50 Windpower, LLC
51
49 Proposed
47
St. Lawrence
Windpower
Project
39 44
46
40 FIGURE 2-2
Project Layout
41 45
and Boundary
42 Towns of Cape Vincent
37
and Lyme
MARCH
36 2010
35 43
30
34
Project Boundary
26 25
53 Turbine Locations
with 150 foot Temporary
29 Radius Laydown Area
33
32 Existing
23 31
27
22 28 Proposed
24 Buried Interconnect
20
21
Permanent Access Road
17
19
Overhead
Transmission Line
18
16
2 Ancillary Facilities
2: Collector Substation/O&M Building
4: Transmission Owner
15
Project Location
12
13
14
3
2
9
8
Project Location
7
5
6
State: New York
3
4
St. Lawrence
1
Project Location
Jefferson
2 Herkimer
Lewis
Oswego
Cayuga Oneida
County: Jefferson
0 1,000 2,000
Feet
0 0.25 0.5
Miles
NOTES:
FEIS
MARCH 2010
Sources:
USGS 7.5 Minute
4 Jefferson County 12 & 24-inch Resolution
Natural Color Orthoimagery: April, 2006
http://www.nysgis.state.ny.us
Projection:
NAD 83
FEIS\Fig_2_2_Project_Boundary.mxd
004152
53
St. Lawrence
Windpower, LLC
52
Proposed
St. Lawrence
50
48
Windpower
51
Project
FIGURE 2-3
49
39
Turbine Setback
47 Constraints
40 44
Towns of Cape Vincent
and Lyme
46
41 MARCH
2010
53
45 Turbine Location
37
Non- Participating
Residence
42
Participating Recidence
36 Project Boundary
Village of Cape Vincent
Line
35
30
Signed Landowner Parcel
26 Unsigned Landowner
Parcel
43
Participating Residence
Constraint (750 ft)
34
23 Non-Participating
29 25 Residence Constraint
22 (1250 ft)
Village of Cape Vincent
Constraint (1500 ft)
Non-Participating Property
Line Constraint (1000 ft)
27 33
31
28
21 24
20 32
19
Project Location
17
18
10
16
Project Location
State: New York
15
12
St. Lawrence
Project Location
13
Jefferson
9 Herkimer
8 Lewis
14
Oswego
Cayuga Oneida
County: Jefferson
7
5
6
Feet
0 500 1,000
3
4 Miles
0 0.125 0.25
1
2
NOTES:
FEIS
MARCH 2010
Sources:
USGS 7.5 Minute
Residence Points: TRC, 9/30/08
Projection:
NAD 83
FEIS\Fig_2_3_Setbacks.mxd
004153
w44
Stay out
W44-T
53
W8 1
W5 W4
52
48
W6
50 POND St. Lawrence
51 W3 W2 Windpower, LLC
49
W7
47
Proposed
St. Lawrence
W31 Windpower
39 44
W1 46 Project
40
W60 W14 FIGURE 2-4
W15
41 45
Layout with
w46 Delineated Wetlands
42
37 W17-T
W9
W10 and Lyme
36
W17
43 MARCH 2010
35
30
W13-T W13-T 34
W51 W52 W16
W51-T 26
25 53 Turbine Locations
W13 W11 with 150 foot Temporary
W40 29 Radius Laydown Area
W50
W16-T1 33 W11-T
W26-T1 Existing
W42-T Meteorological Tower
23 W16-T2 32
W47
W42 W42 W34-T1 31
W25 w48
22 28 Proposed
W34-T10 27
w26 W34 Meteorological Tower
W34-T12 W34-T
POND 24 W34-T2 W34 Buried Interconnect
W26-T2
W26-T3 W61 W34-T3 W34-T12
21 W23-T W49 20 W34-T4 Permanent Access Road
17
W34-T4
W23 W34-T11
W57 W34-T5
W55 W20 19 Overhead
W29 POND W34-T6 Transmission Line
W55 W34-T7
W28 18 POND
W34-T8 2 Ancillary Facilities
W56 W35 W34-T9 16
W27 W36 1: Potential Cement Batch Plant
W29-T W35 2: Collector Substation/O&M Building
10 4: Transmission Owner
W38-T2 W30
W12
Delineated Wetland
W59
w58
15
W38
12
W39-T1 W53
3 Project Location
13 14
2 OT-1
W54 W-53
OT1
W39
9
OT20 OT2
OT3 OT5
8
OT6 Region: Northeastern US
W18-T2
W18 W33
5 7 Project Location
W18 OT7
W18-T1
OT8
W18 W18 6
W18
W32 W18
W18 State: New York
w22
3
W37 4
W45 St. Lawrence
1
Project Location
W24-T OT10
W43
2 OT9 Jefferson
Herkimer
W24
W19 Lewis
Oswego
Cayuga Oneida
County: Jefferson
OT11
Feet
OT18 OT18 0 1,000 2,000
Miles
0 0.25 0.5
OT13
OT14
NOTES:
OT15 FEIS
MARCH 2010
Sources:
USGS 7.5 Minute
OT21 Cape Vincent N & S, Chaumont,
OT17 Delineated Wetland: TRC
OT16 4
OT12 Projection:
NAD 83
OT19
FEIS\Fig_2_4_TRC_WET.mxd
004154
T:\GIS\Acciona\St_Lawrence\Spatial\MXD\FEIS\Fig_2_5_Prime_Access_Roads.mxd
Rd
v ret
Fa
St. Lawrence Windpower, LLC

NOTES: Legend
Project Location FEIS Proposed
Project Location MARCH 2010 Primary Delivery Route St. Lawrence
Windpower Project
Turbine Locations
SOURCES: World Street Map,
ArcGIS cached Map Service FIGURE 2-5
Primary Delivery Routes
PROJECTION:
NAD 83
Miles and Lyme
0 1 2 4 6 8 10 Jefferson County, NY
Region: Northeastern US State: New York MARCH 2010
004155
T:\GIS\Acciona\St_Lawrence\Spatial\MXD\FEIS\Fig_2_6_Prime_Sec_Accesses_11x17.mxd
St. Lawrence
Windpower, LLC
Proposed St. Lawrence
Windpower
53
Project
R d
52
lo
48
FIGURE 2-6
Pe
50
51 Primary, Secondary
49 and Private Access Roads
47 Co
un
ty
R ou
t Towns of Cape Vincent
39 44 46
e9 and Lyme
40 Jefferson County, NY
MARCH 2010
41
d
45
R
Primary Construction
er
Access Road
ev
Ke
42
Mc
37 Secondary Construction
Access Road
C
ou From I81
36 nt Private Access Road
35 y Exit 48
R 43
ou
t e
30 8 53
Turbine Locations
34
26 25
29 33
Existing
Co n s
32 Meteorological Tower
23
31
Rd
tance
22 28 Go
on
sie Proposed
as
27
rR Meteorological Tower
M
d
Rd
24
20 Overhead
4
21 17
te
Transmission Line
ou
19
R
2 Ancillary Facilities
ty
16
un
Co
Hell St
10 2: Collector Substation/O&M Building
Co
un
15 ty St. Lawrence
Ro
ut e
d Project Location
tR 12 8
re
Fa
v
Fa Jefferson
v
W
Herkimer
re
Ma
ils 13 14
tR
3 2
o
Lewis
so
nR
d
nR
9
Rd
d
Oswego
ck
d
Oneida
t Ro Cayuga
8 Vo rn County: Jefferson
tra Bu
5
Rd
te
ou
5
R
7
ty
un
Feet
6 0 1,000 2,000 4,000
Co
Rd
Miles
0 0.25 0.5
3
nd
4
hl a
As
1 d
kR
lic
er
2
De
NOTES:
FEIS
MARCH 2010
Sources:
World Street Map, ArcGIS cached Map Service
Projection:
NAD 83
004156
2.0 PROJECT MODIFICATIONS AND SUPPLEMENTAL INFORMATION

This section describes modifications that were made to the Project since the SDEIS was filed in
March 2009 and provides supplemental information regarding existing conditions, potential
environmental impacts, and mitigation measures that have become available since the March
2009 filing.
2.1 Revised Project Layout/Details

The revised Project layout, shown in Figures 1 and 2, includes 51 turbines, approximately 16.5
miles of temporary access roads, 14.7 miles of permanent access roads, 36 miles of buried cable
and an Operations and Maintenance Exhibit 2.1.1 – Example of Acciona-built O&M
(O&M) Building. An example of a Building at EcoGrove Wind Farm, IL
potential design for the O&M building is
illustrated in Exhibit 2.1.1. A maximum
of five meteorological towers will also be
installed during the construction and
operations phases of the Project to
monitor wind resources. They will be
supported by three to four guy wires and
rest on concrete footings. SLW will add
bird deflectors to the supporting guy
wires to increase visibility to avian
species. Placement of these deflectors is
shown in blue in Exhibit 2.1.2.
The proposed Project includes relatively minor modifications to the layout presented/described
in the SDEIS. These modifications include elimination of two wind turbine generators (WTGs),
selection of the alternate location for one WTG, revised locations for most WTGs, and relocation
of associated roads and underground interconnects. In addition, the rotor diameter for WTG 28
was reduced to 77 meters to accommodate turbulence interference. Most proposed locations for
WTGs in the revised Project layout were only shifted about 100 feet from the locations
previously provided in the SDEIS. Although substitution of one WTG for the alternate WTG
location resulted in a 2.9 mile change from its original location.
Specific changes were made to minimize impacts associated with noise, agriculture, wetlands,
New York State Department of Environmental Conservation (NYSDEC) Wetland Adjacent
Areas, or sensitive species including:
x Elimination of WTG 11 to reduce noise impacts below reasonable thresholds;
2-1
004157

habitat area.
turbulence.
32, 39, 40, 41, 47, and 53 to
eliminations.

Groundwater
2-2
004158


Vegetation
from the Project.

2-5
004159
Exhibit 2.2.2 – Proposed Grassland Bird Conservation Easement
2.2.3 Noise
SLW has conducted a Final Noise Modeling Assessment of the revised Project layout. This
assessment is provided in Appendix C-4. The primary basis for evaluating noise impacts is the
Program Policy “Assessing and Mitigating Noise Impacts” published by the New York State
Department of Environmental Conservation (NYSDEC, 2001). The NYSDEC guideline
document states that “increases ranging from 0-3 dB should have no appreciable effect on
receptors. Increases from 3-6 dB may have potential for adverse noise impact only in cases
where the most sensitive receptors are present. Sound pressure increases of more than 6 dB may
require closer analysis of impact potential depending on existing SPLs (sound pressure levels)
and the character of surrounding land use and receptors.” What this essentially says is that an
incremental increase of 6 dBA or less over the ambient sound level is unlikely to constitute an
adverse community impact. Ambient levels were derived as described in Section 3.10.1 of the
SDEIS.

Construction and Operational Impacts
Construction related impacts remained unchanged from those discussed in the SDEIS. SLW
conducted a Final Noise Modeling Assessment for the revised Project
2-11
004160
Exhibit 2.2.3 – Noise Modeling Results – Predicted Mean Sound Contours 42 dBA Threshold
2-14
004161
Exhibit 2.2.4 – Noise Modeling Results – Predicted Sound Contours 44 dBA Threshold
2-15
004162
Exhibit 2.2.5 – Noise Modeling Results – Cumulative Impact from Proposed Neighboring Windfarm
2-17
004163
Exhibit 2.2.6 – Plan View of Proposed Transmission Owner Interconnection Substation
2-21
004164
Exhibit 2.2.7 – Profile View of Proposed Transmission Owner Interconnection Substation
2-22
004165
Exhibit 4.1.1 – Maximum Magnetic Field of 5.73 (mG) found at Station 30184 offset – 5.00
feet (Source: Sargeant & Lundy).

lines.
magnetic field.
4-129
004166
Exhibit 4.1.2 – Maximum Magnetic Field of 1.142 (kV/m) found at Station 30184 offset –
5.00 feet (Source: Sargeant & Lundy).

lines.
magnetic field.
SDEIS Response 16.5 Section 2.2.5 of the FEIS includes the full description of the proposed
transmission line route. However, "as-built" drawings can only be
provided after the Project is constructed.
SDEIS Response 18.1 The St Lawrence Wind Power project exceeds all the requirements for
setbacks established by the Town of Cape Vincent Planning Board.
4-130
004167
Exhibit 4.1.3 - Population Density Associated with Operational Wind Energy Facilities in New York.
Population
Density
(Persons Power
Name Municipality Location Population Area Units
per square Capacity (MW)
mile)
Dutch Hill/Cohocton Wind Farm Cohocton Steuben County 2,626 54.68 48.02 125 50
Steel Winds Wind Farm Lackawanna Erie County 19,064 6.45 2957.89 20 8
High Sheldon Energy Sheldon Wyoming County 2,561 47.45 53.97 112.5 75
Noble Altona Windpark Altona Clinton County 3,160 101.43 31.16 97.5 65
Noble Chateaugay Chateaugay Franklin County 2,036 48.77 41.75 106.5 71
Noble Wethersfield Wethersfield Wyoming County 891 36.13 24.66 126 84
Noble Bliss Windpark Bliss, Eagle Wyoming County 1,194 36.48 32.73 100.5 67
Noble Clinton Windpark Clinton Clinton County 727 67.13 10.83 100.5 67
Noble Ellenburg Windpark Ellenburg Clinton County 1,812 107.29 16.89 81 54
Munnsville Munnsville Madison County 437 0.86 506.22 34.5 23
Maple Ridge Wind Farm Lowville Lewis County 4,548 36.43 124.85 321.75 195
South Holt Wind Farm East Shoreham Suffolk County 448,248 241.03 1859.74 0.1 2
(Brookhaven)
Calverton Calverton (Riverhead) Suffolk County 27,680 68.01 407.00 0.05 1
HARBEC Plastics Inc. Wind Turbine Ontario Wayne County 9,778 32.55 300.38 0.25 1
Fenner Wind Power Project Cazenovia Madison County 6,481 50.17 129.17 30 20
Madison Wind Power Project Madison Madison County 2,801 40.94 68.42 11.55 7
Wethersfield Wind Power Gainesville Wyoming County 2,333 33.91 68.80 6.6 10
Average 393.09
SLW Cape Vincent, Town Jefferson County 3,345 55.91 59.83 79.5 53
SLW Cape Vincent, Village Jefferson County 760 0.54 1413.98 79.5 53
4-133
004168
St. Lawrence Windpower (SLW)
Acciona Energy
T&E Species Discussion
DEC Region 6, Watertown
August 24, 2009
In attendance:
DEC Region 6 Office:
Blayne Gunderman, Acciona

Pete Zedick, Acciona
David Tidhar. WEST
Bill Gordon, DEC
Angie Ross, DEC
Irene Mazzocchi, DEC
Ken Kogut, DEC
Conference Call:
David Young, WEST

Tim Sullivan, USFWS
Margaret Crawford, USACE
Scott Crocoll, DEC
Dan Rosenblatt, DEC
Peter Nye, DEC
Brianna Gary, DEC
Steve Tomasik, DEC
David Tidhar opened the discussion with results from the 2009 grassland species survey,
comprising four rounds of surveys during June and July. The survey focused on northern harrier
(Cirus cyaneus), upland sandpiper (Bartramia longicauda), Henslow’s sparrow (Ammodramus
henslowii), grasshopper sparrow (Ammodramus savannarum), vesper sparrow (Pooecetes
gramineus) and sedge wren (Cistothorus platensis). Relatively few individuals were found but
all species were detected except sedge wren. These results are included in the draft report dated
August 1, 2009, currently under review by DEC staff.
Irene Mazzocchi led the discussion regarding Short-eared owl (SEOW) forage areas.
They were discussed as follows:
CV-1 (Cape Vincent -1)
Underground collection line runs through this area. SLW was asked to consider re-
locating this line or conversely agree to limit time of construction to no earlier than
August 1 or later than October 20 of the construction season. Disturbance to this area
from proposed construction would be temporary and result in no permanent impact to this
resource.
004169
CV-2
Wind turbine generators (WTG) 18 and 24 are in the middle of this foraging area. DEC
asked SLW to consider moving turbines closer to the edge of this open area.
CV-3
WTG 31 is in the middle of this foraging area. SLW was asked if it was possible to move
this turbine slightly north toward the edge of the woods.
CV-4
The set of WTGs in this area is considered to be the most problematic. It was
recommended to look at this array of turbines and move project components (turbines,
roads, interconnects) closer to edges of open areas away from prime foraging area;
alternately consider re-locating or eliminating turbines that impact this area.
David Young cautioned that re-location of turbines towards woodlands may increase
risks for impacts to Indiana Bats, and recommended that any proposed changes to the project
layout be based on consultation with all agencies representing all concerns for T&E species in
the project development area.
SLW indicated that they are willing to look at potential WTG re-location based upon this
discussion, wind resource assessment and other factors. To address residual impacts, SLW will
also explore the potential for long-term habitat conservation through agreements with
landowners, possibly other landowners in the area that are not currently participants in the
project, to result in a net conservation benefit for affected species.
Angie Ross discussed the potential Blanding’s Turtle habitat areas, and recommended
that these areas be fenced from active construction areas prior to construction start, and fences
maintained through the project restoration phase, at which time they would no longer be
necessary and should be removed. In addition, there should be a Blanding's turtle expert serving
as an environmental monitor present during the construction of towers and underground
interconnect lines (not just fencing). The highlighted areas of greatest concern are near turbines
32, 33, 43.
WEST will prepare a “Wildlife Conservation Plan” to include the range of avoidance and
mitigation practices to be applied to this project for avian, bat and terrestrial species.
Irene Mazzocchi will provide a model for submitting a Special License application under
Article 11. The application is separate from the existing UPA Article 24 (wetland) application
but will follow UPA timeframes for review and approval.
Additional comments provided by Irene Mazzocchi (attached).
004170
New York State Department of Environmental Conservation
Region 6
Dulles State Office Building
317 Washington Street, Watertown, New York 13601-3787
Phone: (315) 785-2261 • Fax: (315) 785-2242
Website: www.dec.ny.gov Alexander B. Grannis
Commissioner
TO: Steve Tomasik
FROM: Irene Mazzocchi
DATE: August 26, 2009
RE: T&E Species Discussion with STLA Wind on August 24th, 2009
I would like to go on record with the following comments in reference to the meeting with STLA
wind/Acciona regarding T&E species and the ST. Lawrence Windpower project.
First, I would like to note that NYSDEC staff (regional and Endangered Species Unit in Albany)
believe as the project stands, an Article 11 Threatened and Endangered species take permit would
be required.
There are at least four known Short-eared Owl (SEOW) wintering roost sites (CV-1, CV-2, CV-3, CV-
4) within the footprint of the project and these sites have been identified and the project consultant
has been informed of these sites.
As stated in the minutes submitted by Steve Tomasik, CV-4 is considered to be the most problematic
regarding the numbers of wind turbines, roads, etc. I would also like to note that CV-3 is also in an
area of real concern regarding the impact to SEOWs. Besides WTG 31, WTG 34 is also a concern
since it is located in the middle of a grassland field within the same CV-3 and CV-4 complex.
To eliminate disturbance to the SEOWs, timing of construction within all the known SEOW roost sites
should be limited to August 1st through October 20th, not just for CV-1.
Since Henslow’s Sparrow and Upland Sandpipers were identified during the 2009 BBS, timing of
construction for those areas or nearby fields where they were located needs to also be limited.
Although not discussed thoroughly during the meeting, I would suggest limiting construction in those
areas to August 1st through April 15th.
In addition, it should be noted that a good percentage of this area is critical foraging habitat for not
only the SEOW, but other raptors as well. This includes the state threatened Northern Harrier which
can be found throughout the project area during most of the calendar year. The map provided by
STLA wind depicts some of that data. This area has some of the highest raptor density numbers in
the Northeast, particularly during migration and we need to consider that when evaluating the project
for impacts to T&E species.
004171
004172
004173
004174
004175
004176
004177
004178
004179
004180
004181
004182
Assessor
Supervisor
THOMAS K RIENIlECK TOWN OF CAPE VINCENT ROBERTVR. BARNARD
JEFFERSON COUNTY, NEW YORK 13618
Historian
Town C1erk/Tex Collector
JERI A MASON PETER J MARGREY
Planning Board Chairman

Councilmen
MARTYT MASON RICHARD J EDSALL
JOSEPH H. WOOD
Boord of Appeals Chairmen
DONALD J MASON
EDWARD p. BENDER
MICKEY W. ORVIS
Superintendent of Highways Zoning Enforcement Officer

DANNY p. HUBBARD ALAN N. WOOD
FAX (315) 654-3366
10/30/09
Re: Visual Mitigation for Cape Vincent
To: Whom It May Concern
I have been involved in the process of collaborating with St. Lawrence Windpower on
mitigation for unavoidable visual impacts caused by the St. Lawrence Wind Farm. I have
also been involved in brainstorming and ultimately proposing projects that the Town can
support. In doing so, we would be amenable to the following projects:
• Restoration/painting of buildings at the Tibbett's Point Lighthouse

• Burying the electric lines and transformer at Tibbett's Point
• Restoring the tower/clock at the Fire Hall
• Fixing the fence at the Market Street Cemetery, and
• Setting up a fund for screening of historically significant buildings and homes
I look forward to working with the St. Lawrence Team in finalizing these plans in the
near future. Thank you.
Sincerely,
Thomas K. Rienbeck
Town Supervisor
Town of Cape Vincent
004183
03/23/2813 9413070274 PAGE 02

t_ HIRSCHJ!,"r TOWN OF CAPE VINCENT- AS'X$St:'lr
ttOfjERTV.R. RARNARO
JEFJ."ERSON COUNTY, NEW YORK J3618
!tlWn Ocrvru:. (A1ll:1!Ic:>r f·hsto(,/u'.
ro-s:re.R). MARGRE\"
Counr.il:l\I!I' l"i.l!nnjr.g lJo;In.l

kL\50N RlCli.>\RD.I. F.f)5ALL
1$l\(;IQJ.:.S J. BMGLJON
oo["'l.'\l)) j, ool!rd til Chi)lrlft,,'"
MICKEY W. ORVlS El)WARD 81!NDtm.
Qi El'!forcclJlt..:nt Offia.:r
DAI\IN'I' ;:0 H1.JI1MRD I'L,\N WOOf)
March 24, 2010
Bryan Stumpt
St La\VT.ence Windpower
122 South Point Street
Cape Vincent, New 13636

W'e appreciate and accept the invitation for the balance of the Wind to attend
the presentation by Hessler Associates t.o the Plannitlg Board on Apri114 at 7:00PM.
It is important that the Committee has an opportlUlity to learn how Hessler

sound as compared to the Town's consultant and detemline for thenlselves what is
appropriate for Cape Vincent. That bessler has been the sOl..llld consultant for 54 wind
projects is indeed iInpresslve. To that extent it would be nl0st helpful to have the names
and loc.ations of those projects so as to compare them witb the demographics and other
characteristics of our proposed project.
Please send this infonnalion to the Wind Committee to mv attention. Additionally where
the sound studies where part of a public document such a DEIS we would appreCiate
that information as welL
We look forward to receiving this information. and meeting the officiaJs from Hessler and
Associates on April 14.
Urban Hirschey /
it
Supervisor Cape NY
004184
Sound Level Survey
and
Noise Impact Assessment
Acciona St. Lawrence Wind Project
004185
Study Overview
Establish existing conditions through field
surveys of natural environmental sound levels
Model and map the expected sound emissions
of the project
Evaluate project sound levels relative to existing
levels to gauge potential impact
004186
Background Sound Surveys
Necessary to evaluate NYSDEC guidelines,
which suggest a maximum increase of no more
than 6 dBA over the existing background level
due to a new source.
Summertime Conditions:
17 Day Survey - Aug. 22 to Sep. 8, 2007

Wintertime Conditions:
20 Day Survey – Dec. 14, 2007 to Jan. 4, 2008
004187
Survey Objectives
Conservatively determine the existing site-wide
background sound level as a function of wind
speed.
Evaluate any seasonal variation.
Evaluate any variation in level within the site area.
Specifically evaluate sound levels at the River’s
edge.
Establish baseline levels from which a 6 dBA
increase could be calculated.
004188
Measurement Positions
004189
Position 1 – Co. Rd. 9
Setting: Edge of wooded area remote from all roads and
farm activity, 1025 ft. from Co. Rd. 9
004190
Position 2 – Millen Bay Rd.
Setting: Open field, 330 ft. from road
004191
Position 3 – River Bank
Setting: Within 10 ft. of the River shore. At the bottom of an
embankment shielding the location from Rt. 12E
004192
Position 4 – Branche Road
Setting: Open field adjacent to typical farm
004193
Position 5 – Rt. 12 E
Setting: Side yard of farmhouse located directly on Rt. 12E
004194
Position 6 – Hell St.
Setting: Open fields, outside farm buildings
004195
Measurement Quantities
Principal Measure: the L90 statistical level
Secondary Measure: the Average (Leq) Level
90
PARTICULARLY LOUD
VEHICLE PASSING TRAFFIC, TYPICAL
80 Leq ,TRUE AVERAGE
L10
70
60
50
40 1/2-MINUTE
L90, RESIDUAL LEVEL
Sound Pressure Level, dBA

LULL IN
TRAFFIC
30 1-MINUTE LULL IN TRAFFIC
20
3:05 PM
3:10 PM
3:15 PM
3:20 PM
Time (min), 15 minute Sample
004196
0
10
20
30
40
50
60
70
80
12/14/07 12:00
12/15/07 0:00
12/15/07 12:00
12/16/07 0:00
12/16/07 12:00
12/17/07 0:00
12/17/07 12:00
12/18/07 0:00
12/18/07 12:00
12/19/07 0:00
12/19/07 12:00
12/20/07 0:00
12/20/07 12:00
12/21/07 0:00
12/21/07 12:00
12/22/07 0:00
12/22/07 12:00
12/23/07 0:00
12/23/07 12:00
12/24/07 0:00
12/24/07 12:00
12/25/07 0:00
12/25/07 12:00
12/26/07 0:00
Date and Time

12/26/07 12:00
Wintertime Conditions
12/27/07 0:00
12/27/07 12:00
12/28/07 0:00
12/28/07 12:00
12/29/07 0:00
12/29/07 12:00
12/30/07 0:00
12/30/07 12:00
12/31/07 0:00
12/31/07 12:00
Residual, L90(10 min) Sound Levels vs Time at All Positions (Except 6)
1/1/08 0:00
1/1/08 12:00
1/2/08 0:00
Pos. 5 Rt. 12E

1/2/08 12:00
Pos. 1 Co. Rd. 9
Pos. 3 River Bank

1/3/08 0:00
Pos. 4 Branche Rd.

Pos. 2 Millen Bay Rd.
1/3/08 12:00
1/4/08 0:00
1/4/08 12:00
Overall L90 Survey Results - Winter
004197
0
10
20
30
40
50
60
70
80
12/14/07 12:00
12/15/07 0:00
12/15/07 12:00
12/16/07 0:00
12/16/07 12:00
12/17/07 0:00
12/17/07 12:00
12/18/07 0:00
12/18/07 12:00
12/19/07 0:00
12/19/07 12:00
12/20/07 0:00
12/20/07 12:00
12/21/07 0:00
12/21/07 12:00
12/22/07 0:00
12/22/07 12:00
12/23/07 0:00
12/23/07 12:00
12/24/07 0:00
12/24/07 12:00
12/25/07 0:00
12/25/07 12:00
12/26/07 0:00
Date and Time

12/26/07 12:00
12/27/07 0:00
12/27/07 12:00
12/28/07 0:00
12/28/07 12:00
12/29/07 0:00
12/29/07 12:00
12/30/07 0:00
12/30/07 12:00
12/31/07 0:00
12/31/07 12:00
1/1/08 0:00
Residual, L90(10 min) Sound Levels vs Time at the Principal Design Positions
1/1/08 12:00
Pos. 5 Rt. 12E

1/2/08 0:00
Pos. 1 Co. Rd. 9
Pos. 3 River Bank

1/2/08 12:00
Pos. 2 Millen Bay Rd.

1/3/08 0:00
L90 Results Omitting Position 4
1/3/08 12:00
1/4/08 0:00
1/4/08 12:00
004198
0
10
20
30
40
50
60
70
80
12/14/07 12:00
12/15/07 0:00
12/15/07 12:00
12/16/07 0:00
12/16/07 12:00
12/17/07 0:00
12/17/07 12:00
12/18/07 0:00
12/18/07 12:00
12/19/07 0:00
12/19/07 12:00
12/20/07 0:00
12/20/07 12:00
12/21/07 0:00
12/21/07 12:00
12/22/07 0:00
12/22/07 12:00
12/23/07 0:00
12/23/07 12:00
12/24/07 0:00
12/24/07 12:00
12/25/07 0:00
12/25/07 12:00
12/26/07 0:00
Date and Time

12/26/07 12:00
12/27/07 0:00
12/27/07 12:00
12/28/07 0:00
12/28/07 12:00
12/29/07 0:00
12/29/07 12:00
12/30/07 0:00
12/30/07 12:00
Design Site-wide L90
12/31/07 0:00
12/31/07 12:00
Site-wide Residual (L90) Sound Level vs Time - Wintertime Conditions
Design L90 Background Level (Average of Principal Design Positions)
1/1/08 0:00
1/1/08 12:00
1/2/08 0:00
1/2/08 12:00
1/3/08 0:00
1/3/08 12:00
1/4/08 0:00
1/4/08 12:00
004199
Wind Speed at 10 m agl., m/s
10
12
14
16
18
20
0
2
4
6
8
12/14/07 12:00
12/15/07 0:00
12/15/07 12:00
12/16/07 0:00
12/16/07 12:00
12/17/07 0:00
12/17/07 12:00
12/18/07 0:00
12/18/07 12:00
12/19/07 0:00
12/19/07 12:00
12/20/07 0:00
12/20/07 12:00
12/21/07 0:00
12/21/07 12:00
12/22/07 0:00
12/22/07 12:00
12/23/07 0:00
12/23/07 12:00
12/24/07 0:00
12/24/07 12:00
12/25/07 0:00
12/25/07 12:00
12/26/07 0:00
Date and Time

12/26/07 12:00
12/27/07 0:00
12/27/07 12:00
12/28/07 0:00
12/28/07 12:00
12/29/07 0:00
12/29/07 12:00
12/30/07 0:00
12/30/07 12:00
12/31/07 0:00
Wind Speed at 10 m
12/31/07 12:00
Design L90 Sound Level
1/1/08 0:00
1/1/08 12:00
Design L90 Background Sound Level vs. Normalized Wind Speed
1/2/08 0:00
1/2/08 12:00
1/3/08 0:00
Sound Level vs. Wind Speed
1/3/08 12:00
1/4/08 0:00
1/4/08 12:00
0
10
20
30
40
50
60
004200
Wind Speed Normalization
Wind speed measured at
elevation of turbine rotor by
met mast anemometers (40 –
80 m)
Wind speed converted to a
standard elevation of 10 m in
accordance with IEC 61400-
11
Wind that the turbines will
experience is correlated to
the sound level measured
at ground level
004201
Sound Level as a
Function of Wind Speed - Winter
Regression Analysis of Site-wide L90 Sound Level vs. Normalized Wind Speed
60
55
50
45
40
35
y = 2.6355x + 20.776
30 R2 = 0.6451
25
20

15
10
0
0 1 2 3 4 5 6 7 8 9 10 11 12
Wind Speed at 10 m above Ground Level, m/s
004202
Sound Level as a
Function of Wind Speed - Summer
Regression Analysis of Site-wide L90 Sound Level vs. Normalized Wind Speed
Summertime Conditions
60
55
50
45
40
35
30
y = 0.7185x + 40.085
25
R2 = 0.0647
20

15
10
0
0 1 2 3 4 5 6 7 8 9 10 11 12
004203
Overall Results
Sound Levels by Wind Speed
60
50
Summer Leq
40
Sound
Summer L90
Pressure 30
Level, dBA
20 Winter Leq
10 Winter L90
0
3 4 5 6 7 8 9 10
Wind Speed at 10 m, m/s
004204
Critical Design Conditions
Determine the wind speed where the background level is
lowest relative to the turbine sound power level
Wind Speed, m/s 6 7 8 9 10

Winter L90, dBA 37 39 42 44 47
Turbine Sound
Power Level, 101.7 102.5 102.2 101.8 101.5
dBA re 1 pW
Differential, dB 65 63 60 58 54
004205
NYSDEC 6 dBA Threshold
Design Background Level: L90 Wintertime during
6 m/s wind conditions: 37 dBA
Assume 6 dBA increase is cumulative
Design threshold then 5 dBA above background at
42 dBA
37 dBA background + 42 dBA Project = 43 dBA,
or 6 dBA above the original level
004206
Project Sound Modeling
Predicts the mean or most common project sound
level at any point
Plotted as sound contour maps over the project
area
Calculations based on ISO standard 9613-11
Turbine sound power level based on field tests per
IEC 61400
Downwind conditions assumed in all directions
Moderately absorptive ground assumed (Ag=0.5)
004207
Model Verification – Example 1
Typical comparison between modeled sound levels at various
wind speeds and actual measured project sound levels
New York Project, General Electric Turbines
Regression Analysis of Measured Project-Only Sound Level vs. Normalized Wind Speed
Position 9
65
60
55
50
45
40
35
30
3 2
y = -0.1481x + 2.012x - 5.4756x + 35.702
25 2
R = 0.4643
20
15
Turbine Not Operating Below 2.5 m/s Model Prediction at Key Wind Speeds
L90(10 min) Sound Pressure Level, dBA

10
0
2 3 4 5 6 7 8
004208
Model Verification - Example 2
Typical comparison between modeled sound levels at various
wind speeds and actual measured project sound levels
Wisconsin Project, Vestas Turbines
Regression Analysis of Measured Project-Only Sound Level vs. Normalized Wind Speed
Position 6
70
65
60
55
50
45
40
35
y = 0.0541x 2 + 1.2993x + 36.287
30
R2 = 0.5292
25
Model Prediction at Key Wind Speeds
20

15
10
0
2 3 4 5 6 7 8 9 10 11
004209
Model Verification - Example 3
Comparison between modeled sound level at 7 m/s and actual
measured project sound levels at all wind speeds
Texas Project, Gamesa Turbines
Regression Analysis of L90(10 min) Sound Level at Newman Ranch
vs. Normalized Wind Speed at 10 m
70
Approximate Turbine Cut-in Point
65
60
55
Typical Project Sound Level Approx. 43 dBA
50
45
40
35
30
25 Model Prediction for 7 m/s

Wind Conditions: 43.9 dBA
20 Natural Environmental Sound
Level during Calm Conditions Sound Levels with Project Operating

15
10
0
0 1 2 3 4 5 6 7 8 9 10 11 12
004210
Model Results for St. Lawrence –
Critical Design Conditions (6 m/s Wind)
004211
Model Results for St. Lawrence –
At Maximum Turbine Sound Level (7 m/s Wind)
004212
Model Results
Mean project sound level below NYSDEC 6
dBA increase threshold at all residences
Note, however, that the project will not be

inaudible beyond the 6 dBA increase threshold
Audibility likely much of the time out to roughly
2000 ft.
Sound level and character will vary with wind
and weather conditions
004213
Actual Reaction to Operating Projects
Operational sound surveys
conducted at 8 recently
completed projects
5 are similar in nature to St.
Lawrence
Sound levels measured for 2
weeks at all residences where
concerns or complaints about
noise have been received and
at a number of other homes
where modeling predicts
relatively high sound levels
004214
Observed Complaints at
Recently Tested Projects
Number of Complaints as a
Total Function of Project Total Number Percentage
Households Sound Level, dBA (1)
Project of Relative
in the Site Area
< 40 40 - 44 45 Complaints to Total
(within 2000’)
Site A 107 0 2 1 3 3%
Site B 147 0 3 3 6 4%
Site C 151 0 3 0 3 2%
Site D 268 0 2 4 6 (2) 2%
Site E 91 1 1 4 6 7%
(3)
Overall Average: 4%
(1) As-measured long-term, mean sound levels
(2) There were only 3 reported complaints at this site but others may have existed that we were not
made aware of; hence a total number of 6 were assumed
(3) Most noise issues related to mechanical nacelle noise unique to the turbine model at this site
004215
Low Frequency Noise
Wind turbine sound levels below about 100 Hz
inconsequential and similar to the sound levels
naturally present in a rural area
Mistaken belief that wind turbines produce high
levels of low frequency noise apparently stems
primarily from measurement error
Wind-induced false signal noise is recorded
whenever a measurement is taken under windy
conditions
004216
Wind-Induced Measurement Error
Wind blowing over a microphone creates false
signal noise in the low end of the frequency
spectrum that is often mistaken for actual
turbine noise
Low frequency sound levels in a windy
environment will be high whether a turbine is
present – or not
004217
Low Frequency Microphone Distortion Example
004218
004219
004220
Wind Tunnel Testing of Windscreen
Performance and Wind-induced
Measurement Error
004221
Windscreens
as Installed in the Wind Tunnel
004222
On-Off Measurements of a Typical
Turbine at Maple Ridge
004223
Frequency Spectra 1200 ft. from Vestas V82 Turbine with Unit On and Off
Compared to Sound Level Inside Typical Car
100 Unit Off

Unit Off
90 Unit Off
Unit On
80 Unit On
Unit On
70 Unit On
Inside Car at 60 mph
60
50
40
Sound Pressure Level, dB

30
20
10
0
dBA
dBC
1 kHz
2 kHz
4 kHz
5 kHz
8 kHz
16 Hz
20 Hz
25 Hz
40 Hz
50 Hz
63 Hz
80 Hz
10 kHz
100 Hz
125 Hz
160 Hz
200 Hz
250 Hz
315 Hz
400 Hz
500 Hz
630 Hz
800 Hz
1.6 kHz
2.5 kHz
6.3 kHz
12.5 Hz
31.5 Hz
1.25 kHz
3.15 kHz
12.5 kHz
1/3 Octave Band Center Frequency, Hz
004224
Health Effects
The issue of possible
health impacts from wind
turbines was recently
reviewed by a panel of
independent doctors
004225
Health Study Conclusions
“There is nothing unique about the sounds and
vibrations emitted by wind turbines”
“The Body of accumulated knowledge about
sound and health is substantial”
“The body of accumulated knowledge provides
no evidence that the audible or subaudible
sounds emitted by wind turbines have any direct
adverse physiological effects”
004226
“Sound from wind turbines does not pose a risk
of hearing loss or any other adverse health
effects on humans”
“Subaudible, low frequency sound and
infrasound from wind turbines do not present a
risk to human health”
“Some people may be annoyed at the presence
of sound from wind turbines. Annoyance is not
a pathological entity”
004227
“A major cause of concern about wind turbine
sound is its fluctuating nature. Some may find
this annoying, a reaction that depends primarily
on personal characteristics as opposed to the
intensity of the sound”
004228
General Summary
The noise assessment study for St. Lawrence was
based on the near-minimum (L90) background
sound level conservatively measured under
wintertime conditions
Sound levels measured at ground level correlated
to wind speed measured by met mast at turbine
rotor elevation
Modeling indicates that the project will comply
with the NYSDEC guidelines, which recommend
that a new project not increase the overall sound
level by more than 6 dBA
004229
General Summary
In absolute terms the mean sound levels from
the project are expected to be 42 dBA or, in
most cases, less at all homes in the project area
Most other completed projects in NY and
elsewhere have significantly higher mean sound
levels, often in the 45 to 50 dBA range
004230
General Summary
Although the impact is expected to be relatively
low, the project will not be inaudible
There is no reason for any concerns about low
frequency or infrasonic noise
There is no reason to believe that any significant
adverse health impact will result from the
project
004231
004232
004233
P. O. Box 660 • 122 South Point Street
Cape Vincent, New York 13618
info@stlawrencewind.com
(315) 654-2210
June 28, 2010
Mr. Kris D. Dimmick

Bernier, Carr & Associates, P.C.
327 Mullin Street
Watertown, NY 13601
Dear Mr. Dimmick:
St. Lawrence Windpower, LLC (SLW) is in receipt of your letter dated May 20, 2010
containing comments on the Engineering Concept Report for the St. Lawrence Wind
Farm 115 kV transmission line dated March 18, 2010. We offer the following response
to the comments:
1. The Engineering Concept Report represents a preliminary design for the

transmission line. The scope and format of the report was created in
collaboration with the Development Authority of the North Country (DANC), the
owner and operator of the Western Jefferson County Regional Waterline. The
purpose of the Engineering Concept Report was to address, preliminarily, safety
and operational concerns regarding the compatibility of the proposed
transmission line with the existing waterline. The enclosed letter from DANC
dated June 21, 2010 indicates that the proposed conceptual design meets the
minimum requirements specified by DANC. The letter outlines DANC’s
additional requirements that will need to be met by SLW prior to commencement
of construction. Prior to commencing construction, SLW will obtain DANC’s
approval of the final design and construction plan for the transmission line and
ensure that all applicable design and safety standards are met.
2. Comment about using stationing that corresponds to the stationing used along
the waterline - If SLW is provided the appropriate station reference information, it
will include it in the final engineering drawings. Cross street names will be added
to the final engineering drawings.
3. Comments about the location of the waterline relative to the embankment and
the horizontal separation between the waterline and transmission pole locations
– See 1 above. Prior to commencing construction, SLW will obtain DANC’s
approval of the final design and construction plan for the transmission line,
including the horizontal separation to be used between the waterline and
transmission line components.
004234
4. Comment on soil overloading from heavy equipment – See 1 above. SLW’s
engineer created a construction mitigation summary but DANC said that it was
not necessary to include it in the Engineering Concept Report. Prior to
commencement of construction, SLW will create a response plan that is
approved by DANC and will be utilized in the unlikely event that there is a
disturbance to the waterline during construction or maintenance of the
transmission line.
5. Comment about transmission system being outside of the original railroad right of
way - Required easements outside of the DANC easement area are being
obtained and will be in place prior to the commencement of construction.
We trust the above responses are sufficient to satisfy the requirements of SEQR review.
If you have questions or require additional information, please let me know.
Sincerely,
Tim Conboy
Project Development Manager
Enclosure: Letter from DANC dated June 21, 2010
Copy to: Mr. Rich Edsall, Planning Board Chairman, Town of Cape Vincent
Mr. Todd Mathes – Town of Cape Vincent Planning Board Attorney
Blayne Gunderman and Jason Donajkowski - SLW
Rich Cogen – Attorney for SLW
004235
004236
004237
004238
004239
004240
P.O. Box 660 • 122 South Point Street
Tel: 315.654.2210
July 7, 2010
Mr. Kris D. Dimmick

327 Mullin Street
Watertown, NY 13601
Dear Mr. Dimmick:
St. Lawrence Windpower, LLC (SLW) is in receipt of your letter dated June 28, 2010
containing comments on the Route Evaluation Study for the St. Lawrence Wind Farm.
We offer the following response to the comments:
1. Unless the landowner and responsible transportation agency prefers

otherwise, intersections will be restored to their original condition upon
completion of construction. This has been specified in Section 2.2.7 of the
FEIS.
2. Existing conditions of pavement systems for areas which are required to be
modified have been addressed in the Transportation/Traffic section. In
addition, an in depth analysis of existing road conditions and an assessment
of impacts to roads are provided in the Route Evaluation Study (Appendix C-5
of the FEIS). This study also includes a photographic inventory of existing
road conditions which is presented in Appendices A and C of the report.
During the site plan review process, road use agreements with the
responsible transportation agencies will be developed. These agreements
will address the existing condition of public roads and restoration following
any damages that occur during construction and operation of the Project.
We trust that these responses are sufficient to satisfy requirements of SEQR review. If
you have questions or require additional information, please let me know.
Sincerely,
Tim Conboy
Blayne Gunderman - SLW
File
004241
004242
Tel: 315.654.2210
July 8, 2010
Mr. Kris D. Dimmick

327 Mullin Street
Watertown, NY 13601
Dear Mr. Dimmick:
containing comments on the Construction Environmental Monitoring (CEM) Outline for
the St. Lawrence Wind Farm. We offer the following response to the comments:
1. The CEM Plan will be utilized specifically for the construction phase (and brief
period prior to, and after, construction.) A site-specific Site Management Plan
will be developed for use during long-term operations.
2. The construction management organizational chart was added to the revised
outline. It will be in Section 2.4.
3. We agree – clear definition of responsibilities and the chain of command is
essential to meet the high expectations SLW has for the Project. We have added
reference to this in the revised outline. It will also be in Section 2.4.
4. As part of the chain of command, this will be defined and described in Section
2.4, as stated above.
5. Environmental monitoring locations and types will be determined by the
construction schedule. SLW will require a well laid out construction schedule
prior to commencement of construction. Environmental monitors will be brought
in for specific tasks (i.e. avian experts during construction in sensitive areas
during the breeding season.)
6. Diesel emissions compliance was added to the outline. It will be in Section 5.5.1.
7. Staffing levels will be determined once permits are issued and SLW has a better
idea of what will be required. SLW will hire a sufficient number of, and relevant
expertise level of, staff in order to fulfill its commitments.
8. SLW does not expect to use blasting as a method of construction. If, for some
reason, blasting is required SLW will include monitoring of blast locations to
ensure environmental and safety compliance.
9. Reporting was included in Section 9.5 of the outline; however, we have revised
that section to better illustrate our intentions. In addition, Enforcement and Non-
compliance Penalties now has its own section; Section 9.8.
004243
Sincerely,
Tim Conboy
Enclosure: Revised Construction Environmental Monitoring Implementation Plan

Table of Contents (“outline”)
File
004244
CONSTRUCTION ENVIRONMENTAL MONITORING
IMPLEMENTATION PLAN
TABLE OF CONTENTS
1.0 INTRODUCTION
1.1 Regulatory Framework and Applicable Permits
1.1.1 Township and County Permits
1.1.2 New York State Environmental Quality Review Act (SEQRA) Review and
Findings
1.1.3 Wetlands Permits
1.1.3.1 State
1.1.3.2 U.S. Army Corps of Engineers
1.1.3.2.1 Indiana Bat Incidental Take
1.1.4 State Pollutant Discharge Elimination System (SPDES) General Permit
1.1.5 New York State Department of Transportation Highway Work Permits
1.1.6 NYSDEC Article 11 Permit – Incidental Take
2.0 ROLES AND RESPONSIBILITIES DURING CONSTRUCTION

2.1 St. Lawrence Windpower Project
2.1.1 St. Lawrence Wind Project Management
2.1.2 St. Lawrence Wind Environmental Compliance Team
2.2 Contractors
2.3 Agency Monitors
2.4 Construction Organizational Chart and Chain of Command
2.5 Daily Communication and Briefings
3.0 CONTACT LIST
4.0 PRE-CONSTRUCTION COORDINATION

4.1 Environmental Training
4.2 Identification of Construction Work Sites
4.3 Pre-construction Walkover
4.4 Permits, Programs and Plans
4.5 Sediment and Erosion Control
4.6 Survey of Wetland Contours
4.7 Flagging, Fencing, and Signage
4.8 Vehicular Access & Public Road Considerations
4.9 Construction Vehicles and Equipment
5.0 CONSTRUCTION OPERATIONS

5.1 Site Preparation
5.1.1 Sediment and Erosion Control Measures
5.1.2 Clearing and Grading
5.1.3 Construction in Agricultural Areas
5.2 Construction of Project Facilities (without stream crossings)
5.2.1 Staging Areas
5.2.2 Access Roads
5.2.3 Turbine Foundations and Erection
5.2.4 Buried Interconnect
5.2.5 Overhead Electric
5.2.6 Metrological Towers
5.3 Construction in Wetland Areas and Streams
5.4 Wetland Mitigation
5.5 Discharge of Pollutants
5.5.1 Diesel Emissions
004245
5.6 Dust Controlҏ
5.7 Archaeological Resources
5.7.1 Unanticipated Discoveries
5.8 Invasive Species Management
5.9 Wildlife
5.9.1 Blanding’s Turtle
5.9.2 Grassland Birds – Breeding Birds
5.9.3 Short-eared Owl
5.9.4 Indiana bat
5.10 Rare Plants
6.0 POST-CONSTRUCTION ACTIVITIES

6.1 General
6.2 Restoration Punch List
6.3 Transition to Operations – Site Management Plan
7.0 PROJECT SAFETY

7.1 Contractor Safety Plans
7.2 Acciona Policy on Safety
7.3 Public Road Safety
8.0 INDUSTRIAL WASTES AND TOXIC SUBSTANCES

8.1 Human Sanitation
8.2 Industrial Sanitation
8.3 Toxic and Hazardous Substances
9.0 ENVIRONMENTAL COMPLIANCE AND PROJECT CHANGES

9.1 Compliance Levels and Field Protocols
9.1.1 Monitoring Criteria
9.1.2 Compliance Approach
9.1.3 Compliance Levels
9.2 Permits, Programs and Plans
9.3 Training
9.4 Communications
9.5 Reporting
9.5.1 Daily Reporting
9.5.2 Weekly Reporting
9.5.2.1 SWPPP Reporting
9.5.3 Monthly Compliance Reports
9.5.4 Emergency Reporting
9.6 Stop Work Orders
9.7 Changes to the Project Plan
9.8 Enforcement and Non-Compliance Penalties
004246
004247
004248
Tel: 315.654.2210
July 14, 2010
Mr. Kris D. Dimmick

327 Mullin Street
Watertown, NY 13601
Dear Mr. Dimmick:
containing comments on the Residential Well Study and Mitigation Plan for the St.
Lawrence Wind Farm. We offer the following response to the comments:
1. The plan has been revised to indicate that SLW will pay mitigation expenses for
Cape Vincent Fire Department providing potable water and a water storage tank,
until the conclusion of all studies. However, the mitigation option of construction
of a connection to a municipal water line has been deleted, because if SLW is
ultimately proven innocent of well damage, the landowner would have to pay
what would most likely be a prohibitive cost. The revised plan is enclosed herein.
2. Comment noted.
3. We agree. Testing will be performed by an impartial third party laboratory.
Sincerely,
Tim Conboy
Enclosure
File
004249
ST. LAWRENCE WINDPOWER, LLC
RESIDENTIAL WELL STUDIES AND MITIGATION
July 2010
BACKGROUND
Construction activities can generate ground-transmitted vibration forces that may result in
ground disturbance and can potentially affect existing features proximal to the activity.
These generated vibrations attenuate over distance from the source. The magnitude of
the vibration and the attenuation rate are related to the construction method used for
excavation (e.g., mechanical, blasting), type of construction equipment (e.g., hydraulic
excavators, front end loaders), and conductivity of the surface and subsurface substrates
(e.g., sands, clays, frozen soils, bedrock). In determining the distance from turbines for
pre-construction surveys of private water supply wells, it was assumed that standard
excavation equipment would be used and no blasting would be required. Using such
equipment and techniques, vibration effects typically are below levels of perception at
distances of 500 feet from the source1. Even considering the use of controlled blasting,
construction vibrations should be well below the threshold for residential damage.
PURPOSE
In recent years, new municipal water lines have been constructed in the Town of Cape
Vincent which make water from the Village and Town of Cape Vincent available to
residents in some parts of the Town, Construction of these new supply lines has reduced
reliance on old residential water supply wells; however, many residential wells still exist.
In response to public concerns with respect to potential damage to residential water
supply wells during the construction phase of the St. Lawrence Wind Project, SLW
performed a study to identify existing private residential water supply wells near the site
of its proposed wind energy project. SLW mailed well surveys were to all project
landowners. On the well surveys, the project landowners were asked to declare
knowledge of any wells within 500 feet of proposed turbine locations. All surveys were
1
Hal Amick and Michael Gendreau, 2000, Construction Vibrations and Their Impact on Vibration-
Sensitive Facilities, ASCE Construction Congress 6.
004250
collected, and the GPS coordinates were recorded for all wells described in the survey as
existing within 500 feet of proposed turbine locations. (See Appendix A).
PRE-CONTRUCTION STUDY
Prior to commencing construction of its wind energy project, SLW will conduct a
pre-construction study to characterize existing conditions of residential potable water
wells within approximately 500 feet of the final proposed turbine locations.. The pre-
construction survey will document well depth, flow rates, water quality, and connectivity
through karst features.
CONSTRUCTION MITIGATION AND POST-CONSTRUCTION STUDIES

In the event that the owner of a residential potable water well located within 500 feet of a
turbine location believes that his or her well has been adversely affected by construction
of the SLW project:
1. The well owner must contact a representative of St. Lawrence Windpower (SLW)
to document the location of the well and verify its inoperability. SLW phone
contact: 315-654-2210.
2. Upon verification of the well’s inoperability and its proximity within 500 feet of a
turbine location, as interim mitigation, a SLW representative will assist the well
owner in one of the following ways:
Request the Cape Vincent Fire Department to provide potable water within a
reasonable time frame, with SLW paying all expenses;
Provide water storage tank that accommodates the well owner, within a
reasonable time frame. McCabes Supply, Inc. (20707 State Route 232,
Watertown, New York; Phone: 315-788-5587) can deliver water storage tanks
up to 2,500 gallons, with SLW paying all expenses;; and/or
3 Following the provision of interim mitigation, the following post-construction
study process shall be implemented for each well that is the subject of interim
mitigation.
004251
SLW will conduct an initial post-construction well study for each such well. Each post-
construction study will initially be a desktop study assessing distance of the well to the
turbine(s) location, depth of well in relationship to the turbine foundation(s), the pre-
construction condition of the well, and causative factors leading to reported damage.
If, based upon the initial post-construction study, SLW determines that project
construction activities may have had an impact on the potable well that is the subject of
the study, a third-party certified laboratory will conduct a subsequent post-construction
study to address, as appropriate, :
a) Flow rate or yield from the well;
b) Water quality of the water produced by the well. Water quality testing may
include, as appropriate, data collected from a hand held water quality meter (e.g.,
pH, dissolved oxygen, conductivity, salinity, total dissolved solids (TDS), specific
gravity, temperature, turbidity, siltation); and chemical anlayses for total hardness
or concentration of calcium and magnesium.
Based upon a comparision of pre- and post-construction conditions, SLW will assess
whether its construction activities caused any adverse impacts to the subject potable
water well.
Where the post-construction study indicates that a well’s characteristics have been
adversely affected, SLW will conduct subsequent studies to determine the cause for the
change. Subsequent studies may include an evaluation of potential karst conduits (i.e.,
fractures) underlying a specific turbine, or other project component, and their
connectivity to a potable well using groundwater tracers (commonly fluorescent dyes).
Dye tracer tests can be either qualitative or quantitative. Qualitative tests are the simplest,
most common, but are less informative. They are designed to answer the basic question
of connection. Quantiative studies are more complex and labor intensive, but provide a
more accurate groundwater velocity. For SLW’s purposes, initially a qualitative study
would be performed.
004252
Should the subsequent studies determine that the Project construction did not adversely
affect a residential potable water well, the impacted landowner will reimburse SLW for
all expenses. Should the subsequent studies determine that Project construction did
indisputably adversely affect a residential potable water well, SLW will provide
mitigation in one of the following ways:
A new well will be provided at no expense to the property owner; or
If a new well cannot be provided, a connection with municipal water will be
provided; this installation will be funded by SLW.
004253
APPENDIX A
Landowner Wells within 500 ft GPS GPS POSITION

SYSTEM
Darrel and Margaret Aubertine No Known Wells
Terry and Linda Aubertine No Known Wells
Wesley Bourcy No Known Wells
Rockne and Beverly Burns No Known Wells
Dennis Docteur No Known Wells
Donald and Wava Docteur NAD83 X: 0401838
Y: 4890951
David Fralick NAD83 X: 0393802

Y: 4884208
X: 0393821
Y: 4884218
X: 0393835
Y: 4884193
X: 0393999
Y: 4884258
Frank Giaquinto NAD83 X: 0399431

Y: 4889323
X: 0399386
Y: 4888944
X: 0399210
Y: 4889017
Chris Henchy No Known Wells

Ron Jacobs No Known Wells
Michael and Melinda Kieff NAD83 X: 0394173
Y: 4886547
Richard and Sheila Lawrence NAD83 X: 0400275
Y: 4889238
X: 0399595
Y: 4888894
Maloneys No Known Wells
Donald Mason NAD83 X: 0398248
Y: 4886942
004254
Landowner Wells within 500 ft GPS GPS POSITION
SYSTEM
Ennis and Marilyn Mason NAD83 X: 0400951
Y: 4889190
X: 0402464
Y: 4889305
Marty Mason No Known Wells
Paul and Elaine Mason NAD83 X: 0402785.
Y: 4893502
X: 0402531
Y: 4893260
Pat Meaney and Traci Mason NAD83 X: 0400522
Y: 4890623
Wallace McDowell NAD83 X: 0404142

Y: 4889464
Jarrod & Jarvis Radley No Known Wells
Jim and Patti Radley NAD83 X: 0399468
Y: 4889940
Andrew VanVliet NAD83 X: 0400531
Y: 4890199
Don Votra NAD83 X: 0395499
Y: 4886547
White Farms No Known Wells
Alan Wood NAD83 X: 0405072
Y: 4893074
Wood Farms No Known Wells
004255
004256
004257
Tel: 315.654.2210
July 21, 2010
Mr. Kris D. Dimmick

327 Mullin Street
Watertown, NY 13601
Dear Mr. Dimmick:
St. Lawrence Windpower, LLC (SLW) is in receipt of your letter dated July 7, 2010
containing comments on Section 2.0 of the St. Lawrence Windpower Project Final
Environmental Impact Statement (FEIS). We offer the following response to the
comments:
2.1 Wording will be changed from “required setbacks” to indicate

compliance with the Planning Board’s setback criteria stipulated in their
June 11, 2007 letter to SLW.
2.2.1.1 The text will be changed to indicate that SLW has conducted a pre-
construction survey of residential wells, and that SLW will conduct
additional pre and post construction studies of identified wells to
determine individual well characteristics.
2.2.1.2 SLW will develop a Project Blasting Plan prior to construction. This
plan will include the use of controlled blasting to assure that
construction vibrations would be maintained below the threshold for
well and residential damage. Since site-specific geologic and
hydrogeologic investigation has not been completed in the Project
Area, SLW has committed to revisit distances for the well survey radius
as part of these studies, and the distance may be adjusted either
nearer or further from the potential source. This plan will also include
conventional seismic monitoring at wells or homes within the identified
potential impact zone to mitigate potential seismic impacts associated
with blasting.
2.2.3 In a letter dated June 21, 2010, SLW responded to the comments
regarding potential noise impacts referred to in this comment.
Subsequent to receipt of your July 7, 2010 letter, SLW also received a
copy of a July 15, 2010 letter from Cavanaugh, Tocci Associates which
responds to SLW’s June 21, 2010 letter. That letter suggests that the
Planning Board consider a complaint response process to address
004258
potential noise issues. SLW has committed to such a process. The
complaint resolution plan is included as Appendix C 11.0 of the FEIS.
2.2.5.3 The last bullet will be revised to indicate that reasonable efforts will be
made to repair a breach in the waterline within 8-12 hours of notice to
SLW. An additional bullet will be added indicating the a plan to provide
water in the event of a water main breach will be developed and
approved by DANC and the New York State Department of Health
prior to start of construction. This plan will also indentify a contractor
responsible for implementing the approved plan.
2.2.7.3 Road use agreements will be developed with the transportation

departments responsible for public roads during the site plan review
process. These agreements will include adequate detail for evaluating
the pre-construction condition of existing roads, standards for required
improvements and restoration, and a mechanism for establishing that
restoration has been satisfactorily completed to the agreed upon
standards.
We trust that these responses are sufficient to satisfy the requirements of SEQR review
and enable prompt acceptance of the FEIS. If you have questions or require additional
information, please let me know.
Sincerely,
Tim Conboy
File
004259
004260
004261
004262
004263
004264
004265
004266
004267
004268
004269
004270
004271
004272
004273
004274
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004276
004277
004278
004279
004280
004281
004282
004283
004284
004285
CAVANAUGH TOCCI ASSOCIATES, INCORPORATED
327 F BOSTON POST ROAD, SUDBURY, MA 01776-3027 • TEL: (978) 443-7871 • FAX: (978) 443-7873 • E-MAIL: cta@cavtocci.com
SENIOR PRINCIPALS SENIOR AND STAFF CONSULTANTS

WILLIAM J. CAVANAUGH, FASA, Emeritus ALEXANDER G. BAGNALL
GREGORY C. TOCCI, PE, FASA, PRESIDENT ANDREW C. CARBALLEIRA
WILLIAM J. ELLIOT, LEED AP
PRINCIPALS AARON M. FARBO, LEED AP
DOUGLAS H. BELL JOHN T. FOULKES
LINCOLN B. BERRY MARK V. GIGLIO
TIMOTHY J. FOULKES, FASA, INCE, Bd. Cert. BRION G. KONING
MATTHEW J. MOORE, CTS MICHAEL D. MAYNARD, CTS
CHRISTOPHER A. STORCH
ADMINISTRATOR
DONNA L. RAFUS MARKETING MANAGER
PATRICIA A. CASASANTO
ASSOCIATED CONSULTANTS
NICHOLAS BROWSE, SMPTE
STEWART RANDALL, CTS-D
MARTIN CALVERLEY, CTS
July 15, 2010
Mr. Kris D. Dimmick, P.E.

Bernier Carr & Associates, P.C
327 Mullin Street
Watertown, NY 13601
Subject: Review of Reponses to Cavanaugh Tocci/Bernier Carr Comments Letter, issued June 21, 2010
St. Lawrence Wind Farm Project
Dear Kris,
This letter summarizes our review of the Reponses to Cavanaugh Tocci/Bernier Carr Comments letter,
issued June 21, 1010 for the St. Lawrence Wind Farm Project in the Town of Cape Vincent, Jefferson
County, New York.
The following are comments regarding the June 21, 2010 letter issued by Hessler Associates. The
numbers in parentheses refer to the specific items in the June 21, 2010 letter.
(3) Using a linear regression to associate wintertime background sound with wind speed
underestimates wind turbine noise impact at some receptors. Linear regression analysis has, in
essence, been used to determine the average L90 sound level for integer wind speeds. It is to this
average L90 that Hessler Associates adds the NYSDEC recommended margin of 6 dBA to
determine sound level impacts for each integer wind speed.
Cavanaugh Tocci Associates, Inc. recommends that the 90th percentile of the measured
wintertime L90 sound levels in each integer wind speed bracket be used as the background, to
which the NYSDEC recommended margin of 6 dBA be added to evaluate sound impacts at each
wind speed. The CTA method leads to an impact threshold based on the NYSDEC policy that is
approximately 5 dBA lower than the impact threshold estimated by Hessler for a 6 m/s wind
speed. It is at this wind speed that Hessler indicates the greatest potential noise impact may
occur.
MEMBER FIRM, NATIONAL COUNCIL OF ACOUSTICAL CONSULTANTS
004286
Mr. Kris D. Dimmick, Bernier Carr & Associates, P.C Page 2
July 15, 2010
Response to Hessler 6-21-2010 Letter
In comment (7) of the June 21, 2010 Hessler Associates Letter, the following is stated:
The objective of the field survey was to establish for design and assessment purposes a set of
near-minimum background sound levels that reasonably represent ambient levels within the site
area as a function of wind speed.
Using the 90th percentile of the Wintertime L90 data (bracketed by wind speed) does exactly this.
This method reflects an approach that recognizes low community background sound levels above
which the NYSDEC impact threshold of 6 dBA is assessed.
L90 Sound Levels, Bracketed by Wind Speed (in dBA)
Wind Speed (at 10 m) 0 to 1 1 to 2 2 to 3 3 to 4 4 to 5 5 to 6 6 to 7 7 to 8 8 to 9

m/s m/s m/s m/s m/s m/s m/s m/s m/s
CTA Recommended
backgrounds:
Winter, 90th percentile of 21.9 22.7 22.6 23.9 27.6 29.4 33.6 37.4 41.4
L90 sound levels1 (27.9) (28.7) (28.6) (29.9) (33.6) (35.4) (39.6) (43.4) (47.7)
(Corresponding NYSDEC
impact threshold)
Hessler Recommended
Background:
22.1 24.7 27.4 30.0 32.6 35.3 37.9 40.5 43.2
Winter, Hessler Regression1
(28.1) (30.7) (33.4) (36.0) (38.6) (41.3) (43.9) (46.5) (49.2)
(Corresponding NYSDEC
impact threshold)
Amount by which Hessler
winter background exceeds
CTA recommended
0.2 2.0 4.8 6.1 5.0 5.9 4.3 3.1 1.8
background and the
corresponding NYSDEC
impact threshold
1
Data collected December 14, 2007 through December 30, 2007
(4) The L90 is defined as the sound level exceeded 90 percent of a monitoring period. Comment 4 of
Cavanaugh Tocci Associates May 14, 2010 letter (Review of Report No. 1829-082108-C)
specifically states that the L90 is the “lowest level typically occurring,” not the sound level that
“typically occurs” as mentioned in the June 21, 2010 Hessler Associates letter.
(7) There is no conclusive relationship between the L90 sound level and wind speed, as discussed in
our May 14, 2010 letter. Even when site-wide sound data are averaged and plotted, only 65% of
the variation in the L90 sound levels may be attributed to wind speed; this attribution occurs at
even lower percentages when the regression lines for individual sound measurement positions are
analyzed. For individual sound measurement positions, approximately 50% of the time a change
in the level may be attributed to a wind-induced event at a given wind speed.
We agree with Hessler Associates that the evaluation of wind turbine noise impacts should be on the basis
of measured wintertime background sound levels. However, use of the 90th percentile of the measured
wintertime L90 sound levels at each integer wind speed is more appropriate than the regression used by
Hessler because of the wide scatter in sound level data at each integer wind speed. In addition, Hessler’s
004287
Mr. Kris D. Dimmick, Bernier Carr & Associates, P.C Page 3
July 15, 2010
Response to Hessler 6-21-2010 Letter
area-wide averaging of sound level underestimates background sound levels in quieter areas, leading to an
underestimate of wind turbine noise impact in those areas. Our recommended method for determining
background sound level leads to sound level criteria lower than those determined by Hessler Associates.
The Planning Board may wish to consider instituting a resolution process to address complaints if any
should occur during operation of the completed facility. This process would likely involve evaluating
wind turbine sound levels and methods of noise abatement as appropriate.
We hope that this assists the Town in responding in their best interest. Let me know if you or the Town
of Cape Vincent wishes to discuss it.
Yours sincerely,
CAVANAUGH TOCCI ASSOCIATES, INC.
Gregory C. Tocci William J. Elliot

F:\Users\WJE\Projects\2007\07362 - Cape Vincent Wind Farm\Review (Phase II)\Response to Hessler 6-21-10 Letter
(WJE)(GCT)f.doc
004288
Tel: 315.654.2210
July 23, 2010
Mr. Kris D. Dimmick

327 Mullin Street
Watertown, NY 13601
Dear Mr. Dimmick:
St. Lawrence Windpower, LLC (SLW) is in receipt of the July 15, 2010 letter from
Cavanaugh Tocci Associates, Incorporated (CTA) to you summarizing the results of
CTA’s review of SLW’s June 21, 2010 letter responding to comments on sound issues
pertaining to the St. Lawrence Wind Farm Project. This letter sets forth SLW’s
understanding of the resolution of the issues addressed in the CTA letter.
In light of the CTA letter, SLW proposes that the appropriate resolution of the difference
of opinion between SLW’s sound consultant and CTA with respect to the determination
of background noise levels would be a requirement to adopt and implement a noise
complaint resolution procedure with respect to the project. SLW has proposed a noise
complaint resolution plan as Appendix C 11.0 of the proposed FEIS. Based upon the
CTA letter, and the prior comments and responses with respect to these issues, SLW
believes that inclusion of the complaint resolution plan fully resolves the comments that
have been made by CTA.
For purposes of completeness of the record with respect to sound issues, however, it is
important to provide an additional response to the issues addressed in numbered
sections (3) and (7), and the third to last paragraph of the CTA letter. To the knowledge
of SLW and its sound consultant (Hessler Associates, Inc.), the method suggested by
CTA for determining background sound levels has not been utilized in any other
environmental impact statements prepared for wind energy projects in New York. In
contrast, the method utilized by Hessler Associates has been utilized for the noise
assessment in approximately 19 environmental impact statements prepared with
respect to wind energy projects in New York (among many others in other states) and
has been accepted by the lead agencies, and their consultants, in all of the those cases.
Some example New York projects where this assessment methodology was used and
where the environmental impact assessment is now in the public domain include the
Chateaugay, Marble River, Ripley-Westfield, Roaring Brook, Wethersfield and
Centreville wind projects. Given that, the methodology suggested by CTA must be
considered a minority opinion, which has not been accepted as normal or standard
practice with respect to noise impact assessment in New York (or, to the knowledge of
Hessler Associates, anywhere else in the country).
004289
We trust that this letter further clarifies the record, and will enable prompt acceptance of
the FEIS by the Planning Board. If you have questions or require additional information,
please let us know.
Sincerely,
Tim Conboy
Copy to: Mr. Rich Edsall - Planning Board Chairman, Town of Cape Vincent
Todd Mathes, Esq. – Town of Cape Vincent Planning Board Attorney
Rich Cogen, Esq. – Attorney for SLW
File
004290
004291
004292
004293
004294
004295
Notice of Proposed Construction or Alteration - Off Airport Page 1 of2
f , -_, ./;,,\.'!aliu'·"
p,cJ nl',:;t"Ei CIon
Notice of Proposed Construction or Alteration - Off Airport

Project Name: ACCIO-000130424-09 Sponsor: Acciona Energy
Details for Case: T37 0608.002
Case Status
ASN: 2009-WTE-10293-0E Date Accepted: 10/07/2009

Status: Accepted Date Determined:
Letters: None
Documents: None
Construction / Alteration Information Structure Summary
Notice Of: Construction Structure Type: Wind Turbine

Duration: Permanent Structure Name: T370608.002
if Temporary: Months: Days: FCC Number:
Work Schedule - Start: Prior ASN: 2008-WTE-321l-0E

Work Schedule - End:
State Filing: Not filed with State
Structure Details Common Frequency Bands
Latitude: 44° 9' 53.76" N Low Freq High Freq Freq Unit ERP ERP Unit
Longitude: 76° 14' 2.95" W

Specific Frequencies
Horizontal Datum: NADS3
Site Elevation (SE): 295 (nearest foot)
Structure Height (AGL): 397 (nearest foot)
Requested Marking! lighting: White Paint/Synchronized Red Lights
Other:
Recommended Marking/Lighting:
Current Marking! Lighting: N/A New Structure
Other:
Nearest City: Cape Vincent
Nearest State: New York
Description of Location: Turbine 1 of 11 reflling. These
turbines are part of larger 53 wind
turbine farm.
Description of Proposal: All turbine structures are white.
https://www.oeaaa.faa.gov/oeaaa/external/eFiling/locationAction.jsp?action=showLocatio... 10/7/2009
004296
Notice of Proposed Construction or Alteration - Off AirpOli Page 1 of2

Details for Case: T38
Case Status
ASN: 2oo9-WTE-10298-0E Date Accepted: 10/07/2009

Letters: None
Documents: None
Construction I Alteration Information Structure Summary

Duration: Permanent Structure Name: T38
if Temporary: Months: Days: FCC Numl>er:

Work Schedule - Start: Prior ASN: 2oo8-WTE- 3212-0E
Longitude: 76° 13' 49.51" W

Horizontal Datum: NAD83
Requested Marking/Lighting: White paint Only
Other:
Current Marking/Lighting: NtA New Structure
Other:

Description of Location: Turbine 2 of 11 refiling. These
turbines are part of larger 53
wind turbine farm.
https://www.oeaaa.faa.gov/oeaaa/extemal/eFiling/locationAction.jsp?action=showLocatio... 10/7/2009
004297
Notice of Proposed Construction or Alteration - Off Airport Page 1 of
/-\(!

Case Status

letters: None
Documents: None

Work Schedule - Start: Prior ASN: 2008-WTE-3213-0E
Structure Details Common Frequency Bal1ds

latitude: 44° 10' 32.57" N Low Freq High Freq Freq Unit ERP ERP Unit
longitude: 76° 13' 34.13" W

Site Elevation (SEl: 295 (nearest foot]
Structure Height (AGl): 397 (nearest foot)
Requested Marking flighting: White Paint/Synchronized Red Lights
Other:
Recommended Marking/lighting:
Current Marking/lighting: N/A New Structure
Other: .:::=J
Description of location: Turbine 3 of 11 refiling. These

turbines are part of larger S3 wind
turbine farm.
Description of Proposal: All turbine structures white.
rttps:llwww.oeaaa. faa. gov/oeaaalexternalieFiling/locationAction.jsp?action=showLocatio... 101712009
004298

Case Status
ASN: 2009-WTE-l0297-0E Date Accepted: 10/07/2009

Letters: None
Documents: None

Latitude: 44° 10' 20.25" N low Freq High Freq Freq Unit ERP ERP Unit
Longitude: 76° 13' 22.57" W

Requested Marking/Lighting: White Paint Only
Other:
Current Marking/Lighting: N/A New Structure
:==J

wind turbine farm.
https:llwww.oeaaa.taa.gov/oeaaalexternal!eFiling/locationAction.jsp?action=showLocatio... 1017/2009
004299
f
J\ ci n!s! B v·

Case Status

Letters: None
Documents: None


Low Freq High Freel Fl'eq Unit ERP ERP Unit
Latitude: 44° 10' 9.55" N
Longitude: 76° 13' 17.21" W

Structure Height (AGL): 397 (nea,-est foot)
Requested Marking / Lighting: White Paint Only
Other:
OMu: ]

wind turbine farm.
https:l/www.oeaaa.faa.gov/oeaaa/external!eFiling/locationAction.jsp?action=showLocatio... 101712009
004300

Project Name: ACcrO-ooo 130424-09 Sponsor: Acciona Energy
Case Status

Letters: None
Documents: None

Duration: Permanent Structure Name: Til

Longitude: 76° 16' 21.82" W

Requested Marking/lighting: White Paint/Synchronized Red Lights
Other:
Recommended Marking/lighting:
Current Marking/lighting: N/A New Structure
Other:
turbine farm.
https:llwww.oeaaa.faa.gov/oeaaalextemalieFiling/locationAction.jsp?action=showLocatio... 101712009
004301
Notice of Proposed Construction or Alteration - Off Airport Page 10f2
Notice of Proposed Construction or Alteration - Off Airp10rt

Project Name: ACcrO-ooo 130424-09 Sponsor: Acciona Energy

;:;,un
Case Status
ASN: 2009-WTE-I0290-0E Date Accepted: 10/07/2009

Letters: None
Documents: None



Latitude: 44° 7' 41.20" N Low Freq High Freq Freq unit ERP ERP Unit
Longitude: 76° 15' 14.74" W

Horizontal Datum: NI\D83
Requested Marking/Lighting: White Paint/Synchronized Red Lights
Other:
J

turbine farm.
Description of Proposal: All turbine structures are wllite.
https:llwww.oeaaa.faa.gov/oeaaa/externalleFiiling/locationAction.j Sp ?action=showLocatio... 10/7/2009
004302

Project Name: ACCIO-000130424-09 Spomior: Acciona Energy
Case Status

Letters: None
Documents: None


State filing: Not filed with State
Structure Details Common frequency Bandls
Longitude: 76° 14' 56.97" W

Requested Marking/Lighting: White Paint/Synchronized Red Lights
Other:
Current Marking/ Lighting: N/A New Structure
Other: -=--=--=--=J-J
turbine farm.
Description of Proposal: Ail turbine structures are white.
https:llwww.oeaaa.faa.gov/oeaaalexternal/eFiling/locationAction.jSp?action=showLocatio... 101712009
004303

Project Name: ACcrO-ooo 130424-09 Sponsor: Acciana Energy
Case Status
Letters: None
Documents: None
Construction ( Alteration Information Structure Summary

Duration: Permanent Structure Name: Tt7

Structure Details Common Frequency Bandls

latitude: 44° 8' 41.91" N Low Freq High Fr@Q Freq Unit ERP ERP Unit
longitude: 76° IS' 5.36" W

Horizontal Datum: NADS3
Structure Height (AGl): 397 (nearest foot)
Requested Marking/lighting: White Paint/Synchronized Red lights
Other:
Other:
turbine farm.
004304
1 (; _ }\


Project Name: ACClO-000130424-09 Sponsor: Acciona Energy
Case Status

Letters: None
Documents: None

if Temporary: Months: Days: fCC Number:

State filing: Not filed With State
Longitude: 76° 15' 56.44" W

Other:
Recommended Marking/ Lighting:
Other: L ---J

Description of Location: Turbine 10 of 11 refiJing, These
wind turbine farm.
004305
c'; :rCiI /'::,;'1II[)"


Case Status
letters: None
Documents: None



Latitude: 44° 9' 21.02" N low Freq High Freq Freq Unit ERP ERP Unit
Longitude: 76° 13' 54,79" W

Other:
Other: :==J
wind turbine farm.
https://www.oeaaa.faa.gov/oeaaa/extemal/eFiling/locationAction.jsp?action=showLocatio... 10/712009
004306
XMap® 6
ACCIONA ENERGY/ 08-N-0608.002

St. Lawrence Wind Farm
Lighting Plan Revised 10-07-09
Data use subject to license. TN Scale 1 : 50,000

0 ¼ ½ ¾ 1
NM
© DeLorme. XMap® 6. MN (12.8°W) km
0 ½ 1 1½ 2
www.delorme.com 1" = 4,166.7 ft Data Zoom 12-0
004307
ACCIONA ENERGY
ST. LAWRENCE WIND FARM
08-N-0608.002
Cape Vincent, NY
Latitude Longitude Ground Recommended Previous Study Current FAA Study

Turbine NAD83 NAD83 AMSL Lighting Number Number
1 44-06-33.45 76-19-51.20 314 SFRL 2008-WTE-3175
2 44-06-27.38 76-19-37.97 311 NONE 2008-WTE-3176
3 44-06-45.02 76-19-28.87 322 NONE 2008-WTE-3177
4 44-06-40.95 76-19-16.68 319 SFRL 2008-WTE-3178
5 44-07-08.31 76-18-51.10 301 NONE 2008-WTE-3179
6 44-06-57.92 76-18-44.08 309 SFRL 2008-WTE-3180
7 44-07-11.62 76-18-28.14 286 NONE 2008-WTE-3181
8 44-07-21.09 76-18-38.52 288 SFRL 2008-WTE-3182
9 44-07-32.46 76-17-05.30 284 SFRL 2008-WTE-3183
10 44-08-19.51 76-16-42.34 328 SFRL 2008-WTE-3184
11 44-07-40.20 076-16-21.82 285 SFRL 2009-WTE-8482 2009-WTE-10291
12 44-07-51.35 76-16-03.74 290 NONE 2008-WTE-3186
13 44-07-44.29 76-15-48.78 281 SFRL 2008-WTE-3187
14 44-07-41.20 076-15-14.74 282 SFRL 2009-WTE-8483 2009-WTE-10290
15 44-07-59.26 76-15-07.57 283 SFRL 2008-WTE-3189
16 44-08-28.06 076-14-56.97 295 SFRL 2009-WTE-8484 2009-WTE-10289
17 44-08-41.91 076-15-05.36 295 SFRL 2009-WTE-8485 2009-WTE-10288
18 44-08-29.29 76-15-47.18 323 SFRL 2008-WTE-3192
19 44-08-37.93 76-16-09.47 340 NONE 2008-WTE-3193
20 44-08-45.95 76-16-36.61 322 NONE 2008-WTE-3194
21 44-08-44.94 76-16-58.05 310 SFRL 2008-WTE-3195
22 44-09-00.97 76-16-53.54 290 SFRL 2008-WTE-3196
23 44-09-07.51 76-16-15.82 314 SFRL 2008-WTE-3197
24 44-08-51.43 076-15-56.44 335 NONE 2009-WTE-8486 2009-WTE-10295
25 44-09-21.02 076-13-54.79 312 NONE 2009-WTE-8487 2009-WTE-10294
26 44-09-20.73 76-15-35.28 304 SFRL 2008-WTE-3200
27 44-09-02.36 76-15-05.39 300 NONE 2008-WTE-3201
28 44-09-00.88 76-14-46.59 298 SFRL 2008-WTE-3202
29 44-09-14.68 76-14-56.33 301 NONE 2008-WTE-3203
30 44-09-28.15 76-15-06.07 302 SFRL 2008-WTE-3204
31 44-09-07.55 76-14-05.22 306 SFRL 2008-WTE-3205
32 44-09-08.71 76-12-59.75 301 SFRL 2008-WTE-3206
33 44-09-13.63 76-13-21.23 310 NONE 2008-WTE-3207
34 44-09-26.76 76-13-30.06 323 SFRL 2008-WTE-3208
35 44-09-37.87 76-13-48.75 320 NONE 2008-WTE-3209
36 44-09-42.07 76-14-16.88 312 SFRL 2008-WTE-3210
37 44-09-53.76 076-14-02.95 295 SFRL 2008-WTE-3211 2009-WTE-10293
38 44-10-18.64 076-13-49.51 295 NONE 2008-WTE-3212 2009-WTE-10298
39 44-10-32.57 076-13-34.13 295 SFRL 2008-WTE-3213 2009-WTE-10292
40 44-10-20.25 076-13-22.57 328 NONE 2008-WTE-3214 2009-WTE-10297
41 44-10-09.55 076-13-17.21 328 NONE 2008-WTE-3215 2009-WTE-10296
42 44-09-56.35 76-13-09.37 330 SFRL 2008-WTE-3216
43 44-09-37.09 76-12-26.93 319 SFRL 2008-WTE-3217
44 44-10-30.59 76-12-34.28 340 SFRL 2008-WTE-3218
45 44-10-10.64 76-11-43.62 325 SFRL 2008-WTE-3219
10/7/09 9:09 PM
004308
ACCIONA ENERGY
08-N-0608.002
Cape Vincent, NY
Latitude Longitude Ground Recommended Previous Study Current FAA Study

Turbine NAD83 NAD83 AMSL Lighting Number Number
46 44-10-28.27 76-11-32.01 332 SFRL 2008-WTE-3220
47 44-10-43.07 076-11-19.78 328 SFRL 2008-WTE-3221 2009-WTE-8488
48 44-11-01.01 76-11-36.81 321 SFRL 2008-WTE-3222
49 44-10-46.91 76-11-54.81 328 NONE 2008-WTE-3223
50 44-10-55.71 76-12-15.21 321 NONE 2008-WTE-3224
51 44-10-50.56 76-12-42.44 320 SFRL 2008-WTE-3225
52 44-11-03.52 76-12-27.71 319 NONE 2008-WTE-3226
53 44-11-14.49 76-12-13.79 310 SFRL 2008-WTE-3227
All Turbine Structures are White.

SFRL - Simultaneously Flashing Red Lights
NONE - Unlit/White Paint Only
Turbine Height - 397 feet AGL
Re-filed Turbine-08-26-09
Re-filed Turbines-10-07-09
10/7/09 9:09 PM
004309
004310
004311
004312
004313
004314
004315
004316
004317
004318
004319
004320
004321
004322
004323
004324
004325
004326
004327
004328
004329
004330
004331
St. Lawrence
Wind Farm
P. O. Box 660· ] 22 South Point Street· Cape Vincent, New York 136]8
315-654-22] 0
August 13, 2007
Chairman Edsall
Town of Cape Vincent Planning Board
Dear Mr. Edsall,
St. Lawrence Windpower and BP Alternative Energy have met today, August 13,2007,
to commence discussion on the possibility of sharing a proposed transmission line
connecting the wind energy projects proposed by the two companies to the transmission
grid.
Thank you,

Todd R. Hopper
Manager
)
M.
GJi Madden
1M
siness Developer
BP Alternative Energy N.A., Inc.
004332
004333
JOINT APPLICATION ADDENDUM
(Application #6-2228-00587/00001)
ST. LAWRENCE WIND FARM PROJECT (SLW)

____________________________________________________
Jurisdictional NYS DEC Wetland and Adjacent Wetland Areas
The SLW project has been designed to avoid locating facilities in New York State Department of
Environmental Conservation (NYS DEC) GIS mapped (polygon) wetlands. Field wetland
surveys were conducted to determine the limit of NYS DEC Wetland and Adjacent Wetland
Areas with Region 6 representatives on May 6th, 2009. Five locations where the SLW proposed
facilities would be located within or adjacent to NYS DEC Wetlands were evaluated. Two of
these locations are situated in the proposed wind farm area as shown on Figure 2 Sheet 14 of 28
and Sheet 19 of 28. Sheet 14 of 28 depicts NYS DEC ST-6 (SLW designation Wetland W11-T1)
and Sheet 19 of 28 depicts NYS DEC ST-9 (SLW designation W34). However, after the site
visit, and through further investigation, SLW has made some slight moves of cable runs and
turbine work space to eliminate the impacts within these Adjacent Areas (please see Sheets 14,
and 19, or 28). There are also three areas associated with the proposed overhead transmission
line that are associated with NYS DEC Wetland CV-1 (Sheet 1&2 of 12), UV-4/UV-5 (Sheet of
5 of 12), and X-5 (Sheet 12 of 12). See large format Figures 2 and 3 provided in the Joint
Application for the SLW Project to associated match lines to other detail sheet panels and the
overall location of these NYS DEC Wetlands to the project area.
Two (2) NYS DEC Wetland Adjacent Areas (herein AAs) will be affected by the construction of
facilities for the SLW project. NYS DEC Wetland AAs associated with the overhead
transmission line will be affected by installation of poles along the existing abandoned railroad
bed (see Figure 3 - sheets 1&2 of 28, and sheet 5 of 28). The third potential Wetland AA (see
Figure 3 - sheet 12 of 12) is along the overhead transmission route but will not be affected; i.e.
transmission poles will be located outside of the boundary of the AA of NYS DEC wetland X-5.
Existing Adjacent Area Conditions

NYS DEC ST-9 (Figure 2 - Sheet 14 of 28)
The DEC field-determined wetland adjacent area of NYS DEC ST-9 (also shown as W34) is
primarily managed for agricultural use (currently a hay field). The Wetland AA includes field
hedgerows and constructed farm drainages. The portion of Wetland AA that is not currently
under crop management is characterized as shrub habitat with a sparse number of tree saplings.
The dominant shrub observed in this area is gray dogwood (Cornus rugosa) with some
honeysuckle, hawthorn and Spiraea spp. observed. The existing site is generally level field, with
Page1of7
004334
micro-topography gradients created to convey drainage to the hedgerows and ditches. Through
small revisions in the siting of cable runs, construction will occur outside of the AA.
NYS DEC ST-6 (Figure 2 - Sheet 19 of 28)
The DEC field-determined wetland NYS DEC ST-6 (W11) AA is currently managed as
agricultural crop land; primarily corn and hay crop rotation. The land is level and is devoid of
any type of woody vegetation. Through small revisions in the siting of the turbine work space,
construction will occur outside of the AA.
NYS DEC CV-1 and NYS DEC U-4/U-5 (Figure 3 - Sheets 1&2 of 12, and Sheet 5 of 12
respectively)
NYS DEC CV-1 (OT1) and NYS DEC U-4/U5 AAs are located along an existing utility corridor
consisting of an elevated abandoned railroad bed right-of-way. There is an existing buried water
line located primarily in the center of this railroad bed. The railroad bed traverses in a
northwesterly/southeasterly direction over level topography. The wetlands observed in adjacent
areas are a result of slow drainage or persistent standing water conditions.
The railroad bed was constructed of fill and stone with established drainage ditches constructed
on both sides at the base of the railroad bed to store, and in some locations, convey rainfall
runoff from the railroad bed. There are culverts and stone bridges along this 8.3-mile railroad
bed installed to convey drainage between both sides of the elevated railroad bed. The railroad
bed is maintained periodically to prevent shrub and tree sapling growth. Due to the construction
material in the railroad bed and routine maintenance, it is dominated by grass species. The
drainage ditches have been delineated as Federal wetlands because they are hydraulically
connected to natural wetlands. Honeysuckle has pioneered in some railroad bed side-slope areas.
Dominate species observed in the ditches include Parasol Whitetop (Doellingeria umbellata),
Woolgrass (Scirpus cyperinus), Silky dogwood (Cornus amomum and Carex spp.) The ditches
support very little tree growth, and the wetlands adjacent to these ditches have an overstory
consisting of primarily successional Green Ash (Fraxinus pennsylvanica) and Red Maple (Acer
rubrum), along with some Silver Maple (Acer saccharinum).
NYS DEC X-5 (Figure 3 - Sheet 12 of 12)
NYS DEC X-5 is a cattail marsh adjacent to the Chaumont River. The Wetland Adjacent Area
consists of an old field dominated by a dense woody shrub community. As previously stated,
proposed transmission poles will be constructed outside of the AA.
Page2of7
004335
Evaluation of NYS Adjacent Area Effects
NYS DEC CV-1 and NYS DEC U-4 Wetland Adjacent Area Effects
The construction in NYS DEC jurisdictional field determined Wetland AAs on the existing
abandoned railroad bed right-of-way will involve the installation of eleven (11) single poles.
Construction equipment will traverse along the railroad bed to access the structure locations (see
Figures 3 - Sheets 1&2 of 12, and Sheet 5 of 12 for associated NYS DEC CV-1 and NYS DEC
U-4). Appropriate erosion controls will be installed at each pole workspace area to prevent
disturbed soils from eroding into drainage ditches along the railroad bed. During construction
access along the railroad bed, the existing stone based railroad bed road is not expected to be
adversely effected.
Existing sapling and shrubs that have established themselves on the side-slope along the railroad
bed will be removed to provide workspace for pole installations. Selective removal of potential
“hazard” or “danger trees” will also be necessary to facilitate construction and prevent limbs and
trees from falling on the new transmission line conductors or wires. There are no “line pulling”
workspace areas necessary in the Wetland Adjacent Areas.
Construction vehicles and equipment will be used to set single pole structures. Actual installation
of the poles will occur in a linear fashion along the railroad bed, with crews completing the
excavation, setting, backfilling, seeding and stabilizing phases of construction for each single
structure before relocating and commencing construction on the next structure. Excavation for
the poles will be performed with the use of auger or excavator. Disturbance and temporary soil
stockpiling will be confined to a workspace area of approximately 1,200 square feet on the
railroad bed. After completion of the pole installations, crews will install above-ground hardware
and rollers for conductor “stringing”. After the line has been pulled through the conductor
rollers, the conductor will be “clipped” into insulated hardware. Disturbed railroad bed areas will
be permanently stabilized with either crushed stone or erosion control “mat”, and grass seed will
be applied to prevent side-slope erosion. A qualified Environmental Monitor will be retained
during construction and restoration activities to ensure that Best Management Practices are
implemented.
Hazard or Danger Tree Removal

Tree clearing adjacent to the transmission line will be limited to “hazard” or “danger trees”
associated with the electric transmission line wires. “Danger trees” adjacent to the transmission
line that pose a threat to the reliability of the overhead transmission line include trees that could
fall or strike the conductors and take the transmission line out of service. These trees will be
selectively cut by hand (i.e., non-mechanized clearing) to avoid the use of heavy equipment
access in wetlands, and prevent adverse effects to wetland or wetland AAs. The felled trees will
Page3of7
004336
be limbed and the slash material will be left on site; no chipping will occur in NYS DEC
Wetlands or AAs.
Right-of-Way Maintenance Plan

The long-term Right-of-way Vegetation Management Plan for this transmission line will consist
of a routine 5-year cycle involving selective removal of deciduous and coniferous tree sapling
species that may colonize on the railroad bed, and the selective removal of deciduous and
coniferous “danger trees” adjacent to the line. Shrubs growing on the sides of the railroad bed
will not be maintained; instead, they will be left for vegetative cover for wildlife. Although
invasive species will be removed and herbicide treated, desirable native shrub species will not be
removed so as to encourage their growth along the sides of the railroad bed to encourage wildlife
use and help in managing deciduous sapling tree growth. Cut deciduous trees will be treated with
an herbicide approved by the NYS DEC.
Summary of Effects of work in the Wetland Adjacent Areas (Part 663 § 663.5 -
Standards for Issuance of Permits and Letters of Permission)
The proposed work activity in AAs described herein will not substantially alter or impair the
natural functions or benefits of the associated NYS DEC Wetlands. Overall, siting of the
proposed transmission line in Wetland AAs is compatible with compatibility criteria enumerated
in Part 663 and in subdivision 663.4(d) and 663.5. Specifically, these facilities have been sited
to: avoid the loss of NYS DEC Wetlands and Federal wetlands; evaluate all practical alternatives
for avoiding wetlands and AAs; to the extent feasible, the proposed facilities have been located
in previously disturbed areas with minimal effects on adjacent wetland areas; and, the facilities
have been sited so as to minimize the degradation adjacent area functions and benefits.
Furthermore, the proposed facilities will be located in previously altered AAs (an existing
railroad bed and infrastructure corridor). The proposed overhead transmission line has been
located along a previously cleared infrastructure corridor, thereby spanning wetlands minimizing
construction impacts, and minimizing aesthetic effects of associated NYS DEC wetlands.
The proposed cutting of vegetation along the railroad bed will be selective and performed by
hand, and will not affect adjacent forest habitat or convert unaltered forested habitat to another
habitat type. The proposed cutting will not eliminate or destroy vegetation such that the functions
and benefits of the associated NYS DEC Wetland are significantly adversely affected.
Site-Specific Environmental Practices to Protect State Wetland and Adjacent Areas
During construction activities, an Environmental Monitor will monitor construction activities in

Wetland AAs to ensure NYS Best Management Practices (BMPs). A draft SWPPP for the
Page4of7
004337
Project is included in this submittal. Erosion controls will be installed along the base of the
railroad bed in the pole workspace areas to prevent erosion and sedimentation in adjacent
wetland ditches. Upon competition of construction activities, any disturbance will be re-graded
to pre-existing conditions, seeded and stabilized. With the implementation of these BMPs and
monitoring, the effect to the Wetland AAs will be minimal.
Endangered and Threatened Species Utilizing Wetland Areas, including

Wetland Adjacent Areas
Several species of threatened and endangered species may potentially utilize wetland and
wetland adjacent areas of the SLW project. These species include Blanding’s turtle and Indiana
bat.
Blanding’s Turtle
As reported in the Investigation and Evaluation of Potential Blanding’s Turtle Habitat at the St.
Lawrence Windpower Project, written by Professor Glenn Johnson of Riveredge Associates,
there are several areas within and adjacent to the Project that may qualify as suitable habitat for
the Blanding’s Turtle. This report was conducted based on the Project’s initial 96-turbine layout.
SLW proposes to assess these habitats in relation to the Project’s revised 53-turbine layout. In
addition, SLW will provide DEC with blown-up maps of the area(s) and discuss potential for
avoidance of impacts to the turtle. In addition, the Project proposes to adhere to the
recommendations of Professor Johnson, as they still relate to the revised layout, specifically
including:
1) Roadways, lay down and other staging areas, to the extent possible, be sited away from
potential nesting areas and the travel corridors between these potential nesting areas and
five potential Blanding’s turtle wetlands (ST-6, OT 3, OT 7, OT 9, and OT 10). If it is
unavoidable to re-site roads and staging areas, barriers and culverts should be installed to
either prevent movement to or facilitate movement across these features. Site-specific
recommendations include:
a) NYSDEC Wetland ST-6 – install silt fence along County Route 9 and County
Route 8. In particular, install silt fence in early May of the year of construction
and associated installation or maintenance activity at Turbines 60, 61, and 68.
The ground edge of the fence should be buried at least 3 inches below the surface.
The fence should extend from County Route 8 at a point between construction
activity and ST-6 north and then west to McKeever Road. Similarly, silt fence
Page5of7
004338
should extend from County Route 8 at a point between construction activity south
and then west to Mason Road. Silt fence should remain in place until
construction and clean-up activities are complete. Silt fence should be inspected
for repair or replacement periodically, especially prior to and during Blanding’s
turtle nesting activity (June).
b) Wetland OT 3 –avoid direct impact to turtle habitat such as vegetation damage or

interruption of water flow.
c) Wetland OT 7 – install silt fence along the railroad bed to isolate this wetland
from construction activity, in the manner described above.
d) Wetland OT 9 - install silt fence along the railroad bed to isolate this wetland
e) Wetland OT 10 - install silt fence along the railroad bed to isolate this wetland
2) Consider creating or enhancing potential nesting habitat around selected turbine

placements and equipment staging areas. Turbines 60, 61, and especially 68 will be
situated closest to potential Blanding’s wetland habitat and these turbine sites may
provide nesting habitat. Site-specific guidelines for nest site creation or enhancement can
be provided.
3) Ultimately, if feasible, avoid using County Routes 8 and 9 to enter the Project Area from
the south as an access route during construction phases and for subsequent maintenance
and operation of wind turbines. Similarly, avoid Wilson Road and Hell Street for these
purposes, although Blanding’s turtles have not been documented to occur in this area.
Swamp Road is located in the Cape Vincent Wind Project area, but may be used for
Overhead Transmission line construction or to bring turbines and other equipment to the
St. Lawrence Wind Farm. It is essentially a causeway across a large wetland that
constitutes potential Blanding’s turtle habitat. Increases in traffic volume along this road
will likely negatively impact wetland-dependent wildlife by increasing mortality,
particularly amphibians and reptiles, during key dispersal periods. We recommend
avoiding or minimizing the use of these roads at these times. If the use of these roads is
unavoidable, we recommend that use be restricted during the critical nesting period
Page6of7
004339
(June) when turtles are most likely to cross roads. In addition, barriers (silt fence) should
be installed to direct the movements of nesting turtles in a manner that limits the potential
for road mortality.
4) Develop a short management plan to clearly outline the mitigation measures to be

implemented during construction and operation of the St. Lawrence Wind Project to
reduce any potential impact to Blanding’s turtles or their habitat.
In addition, as part of the Project’s construction Environmental Monitoring and Compliance

Plan, SLW proposes to have a biologist on staff during construction that is knowledgeable of the
Blanding’s turtle and is empowered with “stop work” authority, if impacts are identified that
were previously unrecognized.
Indiana Bat
SLW has been in consultation with the U.S. Fish and Wildlife Service and NYSDEC for the past
year and a half regarding potential impacts to the Indiana bat. SLW has identified areas outside
the Project where the Indiana bat utilizes wetland areas as a summer maternal roosting site. The
SLW Project has offered to cut trees during the wintering months, to avoid impacts to roosting
Indiana bats. No other construction impacts are foreseen that may impact the Indiana bat’s direct
mortality.
Although Indiana bat roosting habitat has been identified outside the Project, studies show that
the Indiana bat has utilized parts of the Project area for foraging. SLW has developed a complete
Biological Assessment, which is in the draft stage and has been shared with the agencies. SLW
will continue to work with the U.S. Fish and Wildlife Service and DEC to further develop ways
to avoid, minimize and potentially mitigate impacts to the Indiana bat. SLW will adhere to the
decisions made in the Biological Opinion that the U.S. Fish and Wildlife Service presents, in
addition to studying the effects post-construction.
Page7of7
004340
004341
004342
004343
Permanent wetland
fill in W22
5,898.1 sq. ft. 4
w22
w22
3
2
w2
w22
w22
Temporary wetland
impact to W22
11,923.6 sq. ft.
W19
Permanent wetland
fill in W24-T
137.7 sq. ft.
Permanent wetland W
24
fill in W45 W24
-T
92.5 sq. ft.
W45
W24
Note:
1 USGS Quad maps and aerial photography used
as a visual reference only. The wetland boundaries
W43 Temporary wetland are GPS Geo- referenced on USGS Quad maps.
See map feature legend sheet St. Lawrence Wind
impact to W24-T Farm Project Wetland Delineation Map Figure 2 Map
130.7 sq. ft. Legend Sheet.
Temporary wetland 0 62.5 125 250 375 500 '
impact to W45
330.2 sq. ft.
PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
Feb. 2010 SHEET 1 OF 28
CHECKED BY: SPD
004344
Permanent wetland
fill in W22
5,898.1 sq. ft. 4
w22
w22
3
2
w2
w22
w22
Temporary wetland
impact to W22
11,923.6 sq. ft.
W19
Permanent wetland
fill in W24-T
137.7 sq. ft.
Permanent wetland W
24
fill in W45 W24
-T
92.5 sq. ft.
W45
W24
Note:
1 USGS Quad maps and aerial photography used
W43 Temporary wetland are GPS Geo- referenced on USGS Quad maps.
impact to W24-T Farm Project Wetland Delineation Map Figure 2 Map
130.7 sq. ft. Legend Sheet.
Temporary wetland 0 62.5 125 250 375 500 '
impact to W45
330.2 sq. ft.
PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS FIGURE 2

DATE: AERIAL
CHECKED BY: SPD Feb. 2010 SHEET 1 OF 28
004345
W18
Temporary wetland
Permanent wetland impact to W18
fill in W18 3,925.0 sq. ft.
W18-T1
962.0 sq. ft.
Note:
USGS Quad maps and aerial photography used
are GPS Geo- referenced on USGS Quad maps.
Farm Project Wetland Delineation Map Figure 2 Map
W32
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004346
W18
Temporary wetland
Permanent wetland impact to W18
fill in W18
W18-T1
3,925.0 sq. ft.

962.0 sq. ft.
Note:
W32
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET

DATE: AERIAL
CHECKED BY: SPD Aug. 2009 SHEET 2 OF 28
004347
Permanent wetland
Temporary wetland fill in W18-T2
impact to W18-T2 61.0 sq. ft.
217.5 sq. ft.
7
W33
8 Note:
W18

-T2

Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
W18

DATE: SHEET 3 OF 28
CHECKED BY: SPD Feb. 2010
004348
Permanent wetland
Temporary wetland fill in W18-T2
impact to W18-T2 61.0 sq. ft.
217.5 sq. ft.
7
8 W33
W18
Note:
-T2

Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
W18

DATE: AERIAL
wetland
004349
W54
W54
54
W
Temporary wetland
impact to W54 9
161.0 sq. ft.
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
SHEET 4 OF 28
004350
W54
W54
54
W
Temporary wetland
impact to W54 9
161.0 sq. ft.
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET

DATE: AERIAL
004351
T1
O
PROPOSED T2
O
SUBSTATION
AND O & M AREA
OT20
TEMPORARY
WORK AREA AND
PARKING
T1
O
0
T2
O
Note:
Legend Sheet.
0 62.5 125 250 375 500 '
Temporary wetland ST. LAWRENCE WIND FARM

impact to W54 PROJECT
161.0 sq. ft.
WETLAND IMPACT
DETAIL SHEET
W54
W54 DRAWN BY: MS
DATE: FIGURE 2
SHEET 5 OF 28
54

W
004352
T1
O
PROPOSED
SUBSTATION
AND O & M AREA
T2
O
OT20
TEMPORARY
WORK AREA AND
PARKING T1
O
0
T2
O
Note:
Legend Sheet.
0 50 100 200 300 400 '
Temporary wetland ST. LAWRENCE WIND FARM

impact to W54 PROJECT
161.0 sq. ft.
WETLAND IMPACT
DETAIL SHEET
W54
W54 DRAWN BY: MS FIGURE 2
DATE: AERIAL
54

W
004353
Note:
Legend Sheet.
0 65 130 260 390 520 '
57
W
W5
7
PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
SHEET 6 OF 28
55
W
W
56
Temporary wetland
impact to W55
725.9 sq. ft.
10
W2
7
W2
7
004354
Note:
Legend Sheet.
0 62.5 125 250 375 500 '
57
W
W5
7
PROJECT
WETLAND IMPACT
DETAIL SHEET
DATE: AERIAL
55
W
W
56
Temporary wetland
impact to W55
725.9 sq. ft.
10
W2
7
W2
7
004355
Permanent wetland
fill in W59
161.3 sq. ft. Temporary wetland
W59
impact to W59
180.7 sq. ft.
-1
OT
13
12
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004356
Permanent wetland
fill in W59
W59
impact to W59
180.7 sq. ft.
-1
OT
13
12
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET

DATE: AERIAL
004357
W 47
8
W4
Temporary wetland
impact to W48
746.5 sq. ft
Permanent wetland
fill in W48
300.0 sq. ft.
Temporary alteration
to streambed W26-T2
361.8 sq. ft.
and 10' of bank
Permanent alteration 6
w2
to streambed W26
453.6 sq. ft.
and 40' of Bank - T2
26
W
Temporary wetland
impact to W26
26
W
impact to W49
w 26 642.1 sq. ft.
Temporary wetland
impact to W26-T3
20
1,360.8 sq. ft.
W 49
3
6- T
22
W2
W 25
W5
W23-T
Note:
5
as a visual reference only, the wetland boundaries
Legend Sheet
0 60 120 240 360 480 '
POND 21
PROJECT
L
WETLAND IMPACT
T7
DETAIL SHEET
DRAWN BY: MS
FIGURE 2
DATE:
SHEET 8 OF 28
23

W
004358
W 47
8
W4
Temporary wetland
impact to W48
746.5 sq. ft
Permanent wetland
fill in W48
300.0 sq. ft.
to streambed W26-T2
361.8 sq. ft.
and 10' of bank
Permanent alteration
to streambed W26 6
w2
453.6 sq. ft.
and 40' of Bank
- T2
26
W
to streambed W26
26
W
impact to W49
w 26 642.1 sq. ft.
Temporary wetland
impact to W26-T3
20
1,360.8 sq. ft.
W 49
3
6- T
22
W2
W 25
W5
W23-T
Note:
5
Legend Sheet.
0 60 120 240 360 480 '
POND 21
PROJECT
L
WETLAND IMPACT
T7
DETAIL SHEET

DATE: AERIAL
23

W
004359
W34-T
11
Permanent wetland
fill in W34-T11
548.5 sq. ft.
Temporary wetland
impact to W34-T11
725.7sq. ft.
PO
ND
Temporary wetland
impact to W35
24 1,731.8 sq. ft.
W61
5
W3
18
Note:
19 See map feature legend sheet St. Lawrence Wind
Legend Sheet.
0 62.5 125 250 375 500 '
20
W

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
004360
W34-T
11
Permanent wetland
fill in W34-T11
548.5 sq. ft.
Temporary wetland
impact to W34-T11
725.7 sq. ft.
PO
ND
Temporary wetland
impact to W35
24 1,731.8 sq. ft.
W61
5
W3
18
Note:
Legend Sheet.
0 62.5 125 250 375 500 '
20
W

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
004361
5
W3
18
Temporary wetland
impact to W35
1731.8 sq. ft.
Note:
Legend Sheet.
0 62.5 125 250 375 500 '
12
PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
Feb. 2010 SHEET 9A OF 28
CHECKED BY: SPD
004362
5
W3
18
Temporary wetland
impact to W35
1,731.8 sq. ft.
Note:
Legend Sheet.
0 62.5 125 250 375 500 '
12
PROJECT
WETLAND IMPACT
DETAIL SHEET

DATE: AERIAL
CHECKED BY: SPD Feb. 2010 SHEET 9A OF 28
004363
-T
4
3
W
17 Temporary wetland
W
34 impact to W34-T7
5
-T 6 306.8 sq. ft.
T7
-T
6 -T
34
34
4-
73
W
W
-TW
16
34
W
Temporary wetland
impact to W34-T8
W 519.4 sq. ft.
8
34
-T
-T
34
12
W
Temporary wetland
impact to W34-T5
impact to W34-T6
3,594.3 sq. ft.
8
-T
34
W
ND
PO
PO
ND
W34-T9
Temporary wetland
impact to W35
1, 731.8 sq. ft.
5
W3
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

W35

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004364
-T
4
3
W
17 Temporary wetland
W impact to W34-T7
34
-T
5
6 306.8 sq. ft.
T7
-T
6 -T
34
34
4-
73
W
W
-TW
16
34
W
Temporary wetland
impact to W34-T8
W 519.4 sq. ft.
8
34
-T
-T
34
12
W
Temporary wetland
impact to W34-T5
impact to W34-T6
3,594.3 sq.ft.
8
-T
34
W
ND
PO
PO
ND
W34-T9
5
W3
Note:
Legend Sheet.
Temporary wetland
impact to W35 0 62.5 125 250 375 500 '
1,731.8 sq. ft.

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004365
w5
8
15
53
W
Temporary wetland W
53
impact to W53
258.1 sq. ft.
14
W-
53
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
-1
DRAWN BY: MS
FIGURE 2
OT
DATE:
13 CHECKED BY: SPD Feb. 2010
SHEET 11 OF 28
004366
w5
8
15
53
W
Temporary wetland W
53
impact to W53
258.1 sq. ft.
14
W-
53
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
-1

OT
DATE:
13 CHECKED BY: SPD Feb. 2010
AERIAL
SHEET 11 OF 28
004367
51
26
Temporary wetland
impact to W51-T
W5
193.2 sq. ft.
T1-
50
W
40
W
Permanent wetland Note:

fill in W26-T1 as a visual reference only. The wetland boundaries
91.1 sq. ft. See map feature legend sheet St. Lawrence Wind
Legend Sheet.
0 45 90 180 270 360 '

Temporary wetland
1
6-T impact to W26-T1
W2
215.2 sq. ft.
23 ST. LAWRENCE WIND FARM
PROJECT
WETLAND IMPACT
DETAIL SHEET
W47
DRAWN BY: MS
DATE: FIGURE 2
004368
51
26
Temporary wetland
impact to W51-T
W5
193.2 sq. ft.
T1-
50
W
40
W
Permanent wetland Note:

fill in W26-T1 as a visual reference only. The wetland boundaries
91.1 sq. ft. See map feature legend sheet St. Lawrence Wind
Legend Sheet.
0 62.5 125 250 375 500 '

Temporary wetland
1
6-T impact to W26-T1
W2
215.2 sq. ft.
23 ST. LAWRENCE WIND FARM
PROJECT
WETLAND IMPACT
DETAIL SHEET
W47
DATE: AERIAL
004369
W13-T
29
W
13
28
-T
42
W3
W
W
41
Permanent wetland
42
fill in W42-T W
136.9 sq. ft.
Temporary wetland
Temporary wetland
impact to W42-T
impact to W41
251.6 sq. ft.
1,267.5 sq. ft.
12
-T
34
W
Permanent wetland
fill in W34-T10
362.1 sq. ft. 27
Temporary wetland
impact to W34-T12
526.4 sq. ft.
Temporary wetland
impact to W34-T10
1,252.8 sq. ft.
W
34
-T
10
Note:
Legend Sheet.
0 60 120 240 360 480 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004370
W13-T
29
W
13
28
-T
42
W3
W
W
41
Permanent wetland
42
fill in W42-T W
136.9 sq. ft.
Temporary wetland
Temporary wetland
impact to W42-T
impact to W41
251.6 sq. ft.
1,267.5 sq. ft.
12
-T
34
W
Permanent wetland
fill in W34-T10
362.1 sq. ft. 27
Temporary wetland
impact to W34-T12
526.4 sq. ft.
Temporary wetland
impact to W34-T10
1,252.8 sq. ft.
W
34
-T
10
Note:
Legend Sheet.
0 60 120 240 360 480 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004371
Temporary wetland
impact to W34-T1
48.6 sq. ft.
W3
4-
W34-T
T1
28
W34
W
41
42
W
Temporary wetland
impact to W41
1,267.5 sq. ft.
12
-T
34
W
Temporary wetland
impact to W34-T2
97.3 sq. ft.
2
-T
34
Temporary wetland
W
impact to W34-T12
526.4 sq. ft.
Temporary wetland
3
impact to W34-T3
-T
34
151.4 sq. ft.

W
Temporary wetland
impact to W34-T4
W 400.7 sq. ft.
34
-T
4 Temporary wetland
impact to W34-T5
469.5 sq. ft.
17
Note:
5

6
-T
-T
6

34
34
-T
W are GPS Geo- referenced on USGS Quad maps.

W
34
34 W See map feature legend sheet St. Lawrence Wind

-T
7
W
-T
6 Farm Project Wetland Delineation Map Figure 2 Map

34
Legend Sheet.
W
0 62.5 125 250 375 500 '

Temporary wetland
impact to W34-T6
3,594.3 sq. ft.
PROJECT
Temporary wetland
impact to W34-T7 WETLAND IMPACT
306.8 sq. ft. DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
004372
Temporary wetland
impact to W34-T1
48.6 sq. ft.
W3
4-
W34-T
T1
28
W34
W
41
42
W
Temporary wetland
impact to W41
1267.5 sq. ft.
12
-T
34
W
Temporary wetland
impact to W34-T2
97.3 sq. ft.
2
-T
34
Temporary wetland
W
impact to W34-T12
526.4 sq. ft.
Temporary wetland
3
impact to W34-T3
-T
34
151.4 sq. ft.

W
Temporary wetland
impact to W34-T4
W 400.7 sq. ft.
34
-T
4 Temporary wetland
impact to W34-T5
469.5 sq. ft.
17
Note:
5

6
-T
-T
6

34
34
-T
W are GPS Geo- referenced on USGS Quad maps.

W
34
34 W See map feature legend sheet St. Lawrence Wind

-T
7
W
-T
6 Farm Project Wetland Delineation Map Figure 2 Map

34
Legend Sheet.
W
0 62.5 125 250 375 500 '

Temporary wetland
impact to W34-T6
3594.3 sq. ft.
PROJECT
Temporary wetland
306.8 sq. ft. DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
004373
W13-T
30
W
13
W
52
Temporary wetland
impact to W52
W 357.1 sq. ft.
51
Note:
Legend Sheet.
26 0 62.5 125 250 375 500 '

PROJECT
Temporary wetland
WETLAND IMPACT
W5
impact to W51-T DETAIL SHEET

1-
193.2 sq. ft.

T
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004374
W13-T
30
W
13
W
52
Temporary wetland
impact to W52
W 357.1 sq. ft.
51
Note:
Legend Sheet.
26 0 62.5 125 250 375 500 '

PROJECT
Temporary wetland
WETLAND IMPACT
W5
impact to W51-T DETAIL SHEET

1-
193.2 sq. ft.

T
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004375
25
W16
Temporary wetland
impact to W16-T1
905.2 sq. ft.
1
6-T
W1
Permanent wetland 31
impact to W16-T1
151.7 sq. ft.
Temporary wetland
impact to W16-T2
238.7 sq. ft.
Note:
Legend Sheet.
W16-T2
0 62.5 125 250 375 500 '

PROJECT
Temporary wetland
DETAIL SHEET
W3
48.6 sq. ft.

4-
T1
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
34-T
004376
25
W16
Temporary wetland
impact to W16-T1
905.2 sq. ft.
1
6-T
W1
Permanent wetland
impact to W16-T1
151.7 sq. ft.
31
Temporary wetland
impact to W16-T2
238.7 sq. ft.
Note:
Legend Sheet.
W16-T2
0 62.5 125 250 375 500 '

PROJECT
Temporary wetland
DETAIL SHEET
W3
48.6 sq. ft.

4-
T1
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
34-T
004377
W9
W9
9
W
w46
W9
W9
W9
37
Permanent wetland
fill in W10
771.3 sq. ft.
Temporary wetland
impact to W10 W10
0
2,096.4 sq. ft. W1
0
W1
0
W1
36
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004378
W9
W9
9
W
w46
W9
W9
W9
37
Permanent wetland
fill in W10
771.3 sq. ft.
Temporary wetland
impact to W10 W10
0
2,096.4 sq. ft. W1
0
W1
0
W1
36
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET

DATE: AERIAL
004379
34
7
W1
7
W1
35
Temporary wetland
impact to W17
2,317.8 sq. ft.
Note:
W16

Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004380
34
7
W1
7
W1
35
Temporary wetland
impact to W17
2,317.8 sq. ft.
Note:
W16

Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004381
W1
Temporary wetland
1 -T
impact to W11-T
127.5 sq. ft.
32
W1
1
34
33
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
004382
Temporary wetland
impact to W11-T
W1
127.5 sq. ft.
1 -T
32
W1
1
34
33
Note:
Legend Sheet.
0 70 140 280 420 560 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
004383
4
W1
40
39
5
W1
41
W60
0
W6
Temporary wetland
impact to W60
211.3 sq. ft.
Note:
Legend Sheet.
0 62.5 125 250 375 500 '
w46
PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004384
4
W1
40
39
5
W1
41
W60
0
W6
Temporary wetland
impact to W60
211.3 sq. ft.
Note:
Legend Sheet.
0 55 110 220 330 440 '
w46
PROJECT
WETLAND IMPACT
DETAIL SHEET

DATE: AERIAL
004385
4
W1
5
W1
41
42
W17
-T
w9
Temporary wetland
impact to W9
w9
553.0 sq. ft.
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
W9
W9
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004386
4
W1
5
W1
41
42
W17
-T
w9
Temporary wetland
impact to W9
w9
553.0 sq. ft.
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
W9
W9
DATE: AERIAL
004387
43
1-T
W1
Temporary wetland
impact to W11-T
127.5 sq. ft.
W1
1-T
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
W1
DATE: FIGURE 2
1
CHECKED BY: SPD
004388
43
1-T
W1
Temporary wetland
impact to W11-T
127.5 sq. ft.
W1
1-T
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET

W1
DATE: AERIAL
Feb. 2010
1
CHECKED BY: SPD SHEET 22 OF 28
004389
51
W1
Permanent wetland
fill in W31 W
31
W7 3,658.6 sq. ft.
44
W31
Temporary wetland
impact to W31
8,917.5 sq. ft.
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

4

W1
PROJECT
WETLAND IMPACT
DETAIL SHEET
40 DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004390
51
W1
Permanent wetland
fill in W31 W
31
W7 3,658.6 sq. ft.
44
W31
Temporary wetland
impact to W31
8,917.5 sq. ft.
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

4

W1
PROJECT
WETLAND IMPACT
DETAIL SHEET
40 DRAWN BY: MS
DATE:
FIGURE 2
AERIAL
004391
53
POND
W3
W6
50
52
51
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

W7

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
FIGURE 2
DATE:
SHEET 24 OF 28
004392
53
POND
W3
W6
50
52
51
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

W7

PROJECT
WETLAND IMPACT
DETAIL SHEET

DATE: AERIAL
004393
46
45
Note:
W1

Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
ry wetland
004394
46
45
Note:
W1

Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET

DATE: AERIAL
004395
W8
5
W
53
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004396
Culvert to be installed in an area of stormwater surface W8
sheet flow. There is no stream or ditch bed and bank
at this location; this upland is surrounded by a
cultivated agricultural field.
5
W
53
Note:
Legend Sheet.
0 62.5 125 250 375 500 '

PROJECT
WETLAND IMPACT
DETAIL SHEET

DATE: AERIAL
004397
T
W44-
48
Culvert to be installed in an area of
sheeting surface flow, No bed and bank
observed in location, surrounding area is
a cultivated agricultural field of upland
crop species.
W4
W8
5
W
Note:
PO as a visual reference only. The wetland boundaries
Legend Sheet.
0 62.5 125 250 375 500 '

W6
PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
CHECKED BY: SPD
004398
T
W44-
48
Culvert to be installed in an area of stormwater surface
sheet flow. There is no stream or ditch bed and bank
at this location; this upland is surrounded by a
cultivated agricultural field.
W4
W8
5
W
Note:
PO as a visual reference only. The wetland boundaries
Legend Sheet.
0 62.5 125 250 375 500 '

W6
PROJECT
WETLAND IMPACT
DETAIL SHEET

DATE: AERIAL
004399
2
W
47
Note:
Legend Sheet.
0 62.5 125 250 375 500 '
49
PROJECT
WETLAND IMPACT
DETAIL SHEET
DRAWN BY: MS
DATE: FIGURE 2
004400
2
W
47
Note:
Legend Sheet.
0 62.5 125 250 375 500 '
49

PROJECT
WETLAND IMPACT
DETAIL SHEET

DATE: AERIAL
004401
004402
Joint (Wetlands) Permit Application
ACOE File No. 2009-00590
Section 7.0
7.0 COMPENSATORY MITIGATION & RESTORATION PLAN
(Rev. April 19, 2010)
SLW proposes compensatory mitigation for the unavoidable fill (loss) of 0.31 acres of wetlands
and for the conversion of forested wetlands to scrub-shrub and herbaceous wetlands. SLW
proposes the following compensatory wetland plan: create compensatory forested and
scrub/shrub wetland area, manage invasive plant species and noxious weeds, and monitor the
development of the created wetland and managed areas to achieve the wetland mitigation goals
proposed.
7.1 Compensatory Wetland Mitigation Goals
Background
In accordance with U.S. Army Corps of Engineers-Regulatory Branch (USACE) mitigation
guidance, SLW proposes compensatory mitigation for the unavoidable permanent fill of 0.31
acres of wetlands at a 3:1 ratio. Most of the proposed fill is located in narrow wetland drainage
corridors consisting of emergent and scrub-shrub wetland located contiguous to agricultural
fields. TRC’s assessment of the primary functional values of these wetlands includes runoff
conveyance, minor flood water attenuation, and potential sediment/toxicant retention. A few
wetlands in the project access and connector cable corridors have more well-developed
vegetative structure and diversity or habitat characteristics, providing wildlife habitat corridors
between fields. In general, the wetlands in the project area have limited wildlife habitat value,
due to the relatively small overall area of these wetlands, their proximity to active agricultural
fields, and their lack of diverse or dense vegetation.
Mitigation Goals
In consideration of these limited functional values, the compensatory wetland goal is to replace
and enhance the flood storage capacity, water quality, and wildlife habitat value attributes of the
proposed wetlands to be filled. SLW proposes to compensate the loss of these functions with the
establishment of 3:1 wetland replacement ratio, or 1.1 acres, and to consolidate the replacement
or compensatory area in one location contiguous to a more functionally valuable natural wetland
in order to ensure compensatory success. This compensatory wetland approach also affords
practical construction of the replacement wetland and creates a suitable opportunity to enhance
the wildlife habitat functional attributes of the compensatory wetland, including creating a
compensatory wetland area dominated by tree and scrub/shrub species with dense emergent
herbaceous species. Details on the value of this planting plan, specific vegetation planting and
density are provided in Section 7.4.8. SLW also proposes to manage invasive species and
noxious weeds on the mitigation site to the extent possible in an area already dominated by many
non-native and invasive species. The site specific mitigation goals and invasive species control
are enumerated in Section 7.6.3.
7.2 Compensatory Wetland Site Selection
TRC evaluated five sites for suitability as the Project compensatory wetland area. A summary of
the criteria used for site evaluation and a description of the potential mitigation sites are provided
as follows.
7-1
Rev. May 17, 2010
004403
Five sites were selected for evaluation as compensatory wetland areas with basic requirements
for success considered. In accordance with ACOE mitigation guidance, these sites were chosen
based on the following selection criteria:
x locate in the same sub-watershed as the filled wetlands with similar hydrogeomorphic,
ecological landscape features, and functions and values (try and duplicate features of
“reference” wetlands or enhance connectivity with natural upland landscape elements
(Gwin et al. 1999);
x locate with natural and adequate variable hydrological sources/conditions (including

locating sites near existing wetlands or are “marginal” wet areas that do not meet all three
wetland criteria, or where sites were previously wetlands);
x locate where soils and heterogeneous topographic gradients are available and will require
minimal construction grading to achieve appropriate planting elevation, depth, soil type
and seasonal timing; and,
x consider the opportunities and constraints concerning equipment access for construction
and maintenance, agreeable landowners, subsurface conditions, and groundwater quantity
and quality.
The wetland compensatory site selection evaluation criteria used for the compensatory wetland
mitigation plan are summarized as follows.
7.2.1 Wetland Hydrodynamics/Hydrology
The proposed wetland impacts resulting from the project occur in two different hydrologic unit
codes (HUCs). The two affected HUCs are the Upper St. Lawrence watershed HUC number
04150301 and the Chaumont-Perch watershed HUC number 04150102. Approximately 74% of
the proposed wetland impacts will occur in the Chaumont-Perch watershed. All of the proposed
mitigation sites are located in the Chaumont-Perch watershed. All the sites selected exhibit the
potential for utilizing available surface hydrology and have the potential to provide sediment
removal, flood storage, and nutrient uptake, while also being contiguous to existing wildlife
habitat. Two of the potential sites would expand the riparian zone habitat of Kents Creek,
providing stream shading, and increase the buffer zone from the current farming activities
occurring on the proposed mitigation sites.
7.2.2 Soils and Topography
As described in section 4.1, the Project is located in the physiographic basin of the St. Lawrence
River. Based on the Jefferson County Soil Survey and observations in the field in the Project
study area, the soil parent material includes both glacial lake and marine sediments (USDA,
NRCS, 2006). As a result, the wetlands in the project area and nearby “reference” wetlands are
associated with similar geomorphic soils formations. The soils in the potential mitigation sites
have fairly silty content and the wetlands in the project area all have surface hydrology driven by
these poorly drained soils and relatively level topography. Regional groundwater does not
7-2
004404
appear to significantly influence the hydrology of reference wetlands; thus, they were not
available for consideration at the wetland mitigation sites. The relatively large natural wetland
complexes that do exist in the project area are located south of the proposed wind farm (see
Figure 2), and in two large wetland areas crossed by the proposed electric transmission corridor
(see Figure 3). These larger wetland complexes are also NYSDEC mapped state wetlands
located to the south of the proposed wind farm and have the greatest potential to provide
groundwater influenced hydrology. The following potential mitigation sites were evaluated with
respect to wetland hydrodynamics (surface and groundwater), soils, and topography.
7.2.3 Compensatory Wetland Site Evaluations
7.2.3.1 Mitigation Site A
Mitigation Site A is located in an open agricultural field contiguous to Wetland W-33, a forested
wetland containing a“PFO1C” NWI Wetland. The NRCS mapped soil at the site is Kingsbury
silty clay; this soils series consists of very deep, somewhat poorly drained soils formed in
lacustrine or marine sediments. The current vegetation of the site consists of herbaceous
vegetation, which changes with the management of the field. This site is located approximately
1,600 feet northwest of DEC Wetland V-1 and would not be hydrologically connected to this
DEC wetland. The nearest FEMA mapped floodplain area is located in the DEC Wetland and is
approximating 2,000 feet away from Mitigation Site A. Mitigation Site A would be contiguous
to the existing mapped NWI wetland.
7.2.3.2 Mitigation Site B
Mitigation Site B is located in an agricultural field adjacent the abandoned railroad ballast, south
of the proposed substation site, and would be hydrologically connected to wetland OT-20. NRCS
soil series mapping indicates that the area has Kingsbury silty clay, consisting of very deep,
somewhat poorly drained soils formed in lacustrine or marine sediments. The site has been
periodically farmed, suggesting it may be marginally wet depending on rainfall and weather
conditions. The nearest DEC Wetland (DEC Wetland V-1) is located approximately 850 feet
south of Mitigation Site B. The nearest FEMA mapped floodplain area is also located south of
Mitigation Site B and is associated with the DEC Wetland. The nearest NWI wetland is east of
Mitigation Site B and is a “PFO/SS1E” wetland. Mitigation Site B would be contiguous and
hydrologically connected to this NWI wetland.
7.2.3.3 Mitigation Site C
Mitigation Site C is also located in an open agricultural field, north of the abandoned railroad
ballast, and would be hydrologically connected to Wetland OT-1. Soil mapping in this area is
Covington silty clay, a hydric soil. It has been described by the NRCS as having very deep and
poorly drained soils formed in calcareous clayey glacio-lacustrine or glacio-estuarine deposits on
glacial lake plains. These soils are found on broad plains, depressions, and drainage ways. The
vegetation of the site consists of herbaceous vegetation, which changes, with the management of
the field. Mitigation Site C is located approximately 600 feet north of DEC Wetland V-1. The
nearest FEMA mapped floodplain area is associated within the DEC wetland and is
7-3
004405
approximately 550 feet away from Mitigation Site C. The nearest NWI wetland is
approximately 500 feet northeast of Mitigation Site C and is a “PFO/SS1E” NWI wetland. This
NWI wetland is associated with Wetland OT-1.
7.2.3.4 Mitigation Site D
Mitigation Site D is located in an agricultural field along the west bank of Kents Creek. This
portion of Kents Creek is mapped as an NWI “PSS1A” wetland and the proposed mitigation site
would be hydrologically connected to this riverine system. NRCS soil mapping indicates the
series in this area is Rhinebeck silt loam. These are a very deep, somewhat poorly drained soils
formed in glacio-lacustrine sediments having a high clay and silt content. The vegetation of the
site consists of herbaceous vegetation cover, which changes with the management of the
agricultural field. The nearest FEMA mapped floodplain area is associated with Kents Creek and
is about one mile downstream. The nearest DEC Wetland is “ST-10” and is approximately 2,300
linear feet northeast of the mitigation site and is associated with Kents Creek. Mitigation Site D
would be contiguous to the riparian corridor of Kent’s Creek.
7.2.3.5 Mitigation Site E
Mitigation Site E is also located in an agricultural field along the west bank of Kents Creek. The
soil mapping in this area is also Rhinebeck silt loam. The vegetation of the site consists of
herbaceous vegetation, which changes with the management of the field. The nearest FEMA
mapped floodplain area is the same FEMA floodplain area associate with Mitigation Site D and
is located about 1.5 miles downstream Kents Creek. Mitigation Site E is located approximately
450 feet southwest of DEC wetland “ST-10” which is the nearest mapped DEC wetland. This
site is located approximately 500 feet northeast of a “PSS1A” NWI; the same wetland associated
with Mitigation Site D. Mitigation Site E would also expand the riparian wildlife corridor of
Kents Creek.
7.2.4 Compensatory Wetland Site Ranking and Selection
The five compensatory mitigation sites shown on Figure 7-1 were evaluated for their potential
use in creating wetland habitat to compensate for the permanent wetland fill associated with the
SLW Project. Potential mitigation sites were evaluated and ranked for the selection of a
“preferred” wetland mitigation site according to the following parameters, in order of priority:
x Approximately one acre of non-forested upland in close proximity to existing wetland
(hydric soils) or streams;
x Sites with existing or suitable terrain that minimizes the need for significant excavation
and access road construction;
x Close proximity to suitable hydrological sources (surface or groundwater) to support
“hydric” conditions once excavated;
x Low topographic gradients that minimizes the need for grading upland soils to adjacent
wetland grades;
x Land not suitable for agricultural use;
x Available land, i.e., willing seller for conservation restriction; and,
x Sites without invasive species;
7-4
004406
W23 17
W34-T5
W29 19
5 W2
W2
9 W28 W5 0
W34
-T6
W28
18
16
W35 -T9 W34-T8
27
34
27
W
W36
W
W
9-T
W2
10
-T2
W38 W30
CV-2
ST-10
E
ST-10
59 15
W
D
w5
8
W38 CV-2
12 W
53
W39-T
1
13
W53
OT-1
W54 53
W-
9 OT20
W3 OT1
9 B C CV-1
W
OT
54
20
OT1
Proposed Transmission Corridor
OT2
OT3 OT5
8
V-1 OT6
OT5
T2
-
18
W
W
33 A
V-1
7 V-1
18
LEGEND:
W
Note:
are GPS Geo- referenced on USGS Quad maps. OT 7
6
WETLAND BOUNDARY AND DESIGNATION 0 490 980 1,470 1,960 Feet
W24
(Wetland Boundary Beyond the
Project/Wetland Assessment Area)
WETLAND BOUNDARY AND DESIGNATION
(Wetland Boundary within Project/Wetland
Assessment Area)
NYS DEC WETLAND PROJECT
NWI WETLANDS
WETLAND COMPENSATORY
MITIGATION SITE PLAN
W16-T1 NARROW/LINEAR WETLAND CONTIGUOUS
BEYOND WETLAND ASSESSMENT AREA
DRAWN BY: MS
DATE: FIGURE 7.1
PROPOSED MITAGATION SITE April 2010 QUAD
CHECKED BY: SPD
004407
Each potential mitigation site has been evaluated with respect to the suitability parameters
outlined above. The evaluations are summarized as follows (see individual Mitigation Site Plans
attached as Figures 7-1A Site A through Site E).
Mitigation Site A
Mitigation Site A is adjacent to a National Wetland Inventory (NWI) forested wetland. The soils
mapped in the area are mapped as Kingsbury Silty Clay, a non-hydric soil. The source for the
appropriate hydrological conditions would be primarily from surface runoff from the
surrounding landscape. The surface runoff source may not be adequate to support hydric
conditions without a large parcel of land surrounding the compensatory wetland at this site. This
location is flat in nature, and would require some grading and soil removal. Construction access
is convenient because the area is near a turbine and buried cable site where access will already be
constructed. The field surrounding Mitigation Site A consists of various crop grasses including
the invasive species reed canary grass (Phalaris arundinacea). This site would involve some loss
of active cropland; however, the property owner may be willing to sell the land or leasing the
development rights.
Mitigation Site B
Mitigation Site B is adjacent to a linear wetland located along an abandoned railroad ballast. The
soils mapped in the area are Kingsbury Silty Clays, and are non-hydric. The source for the
appropriate hydrological conditions would primarily be from surface runoff from the
surrounding landscape. The surface runoff source may not be adequate to support hydric
conditions without a large parcel of land surrounding the compensatory wetland. Mitigation Site
B is also flat in nature, and would require some grading and soil removal. There is no existing
access available to the site, which makes construction access a key factor; this would require
additional temporary road construction and an additional wetland crossing as the access would
be from the elevated railroad ballast during the work on the SLW project transmission corridor.
The field surrounding Mitigaiton Site B consists of various crop grasses including the invasive
species reed canary grass (Phalaris arundinacea). The site is currently managed as active
cropland. The Property owner may not be interested in selling the land or leasing the
development rights.
Mitigation Site C
Mitigation Site C would entail an expansion of the linear wetland located along the abandoned
railroad ballast. The soils mapped in the area are Covington silty clay, a hydric soil. The source
for the appropriate hydrological conditions would be primarily from surface runoff from the
surrounding landscape, which may be sufficient on these soil conditions. This location is also
flat and would require some grading and soil removal. There is no existing access available to
Mitigation Site C, requiring additional temporary road construction and an additional wetland
crossing if access came from the elevated railroad ballast during the work on the transmission
corridor. The field on the south side of the railroad ballast consists of various crop grasses,
including the invasive species reed canary grass (Phalaris arundinacea). The construction of
Mitigation Site C in this location would impact cropland managed by the landowner, although its
location along the length of an existing field helps minimize the loss of agricultural land. The
Property owner may not be interested in selling the land or leasing the development rights.
7-6
004408
Mitigation Site D
Mitigation Site D is adjacent to a National Wetland Inventory (NWI) wetland associated with
Kents Creek. The soils mapped in the area are a combination of Rhinebeck Silt loam, a non-
hydric soil, and a hydric, Fluvaquents-Udifluvents complex. The source for the appropriate
hydrological conditions would be from surface runoff for the surrounding landscape, and the
high flow and overflow of Kents Creek. Mitigation Site D is relatively flat but would require
some grading of the existing landscape. However, removal of soil in the location may not be
required and regrading may be sufficient. Construction access is convenient because the area is
near a proposed turbine site, although an additional temporary access road to Mitigation Site D
would need to be constructed. The field surrounding Mitigation Site D consists of various crop
grasses including the invasive species reed canary grass (Phalaris arundinacea). The
construction of Mitigation Site D would impact the amount of cropland being managed by the
landowner; therefore the Property owner may not be interested in selling the land or leasing the
development rights. An advantage of Mitigation Site D is that it would also expand and improve
the riparian zone along Kents Creek with the vegetation buffer that it would create. The tree
plantings would also provide shade cover near Kents Creek. The riparian zone improvement
would also improve the wildlife corridor associated with Kents Creek.
Mitigation Site E
Mitigation Site E would provide an expansion of a wetland associated with Kents Creek. The
vegetation plantings proposed for the compensatory wetland would also provide shade cover to
the stream and improve the water quality. The riparian zone improvement would also improve
the wildlife corridor associated with Kents Creek. The soils mapped in the area are Rhinebeck
silt loam, a non-hydric soil. The source for the appropriate hydrological conditions would be
from the combination of: surface runoff and the surrounding landscape; stormwater
runoff/diversions to the mitigation site; and the high flow and overflowing of Kents Creek.
Mitigation Site E is situated adjacent to the floodplain of Kents Creek. Regrading of soil in this
area, instead of significant removal of soil, may be suitable at this location. This combined with
available hydrology for the compensatory wetland makes Mitigation Site E advantageous.
Access to the site would entail entrance from a local road and would require no additional road
building or wetland crossings. The field surrounding Mitigation Site E consists of various crop
grasses including the non-native species Reed canary grass (Phalaris arundinacea). The
construction of Mitigation Site E would impact the amount of cropland managed by the
landowner; however it is located along the length of an existing field. The property owner has
indicated an interest in leasing the development rights for the land.
Mitigation Site Ranking Summary

All the mitigation sites have sufficient site parameters; however, there are advantages and
disadvantages to each site. When evaluating all physical parameters involved with choosing the
suitable mitigation site, Site E appears to be the most suitable. A breakdown of the advantages
and disadvantages of the sites is summarized as follows.
7-7
004409
x Site A
o Poor hydrologic source;
o the site is exposed to nearby seed source for invasive species;
o will have low construction cost with no additional road construction or wetland
crossings needed;
o may interfere with management of the remaining agricultural field; and
o has a willing property owner/seller.
x Site B
o The available hydrologic source may be inadequate for a compensatory wetland;
o has fairly high construction cost, with construction of new access roads and
probable wetland crossing involved;
x Site C
o The available hydrologic source appears to be adequate for compensatory
mitigation;
o invasive species observed are approximately 100 ft. from mitigation site;
o has fairly high construction cost, with construction of new access roads and
probable wetland crossing;
o will have minimal impact to management of remaining crop field; and
x Site D
o The available hydrologic source appears to be adequate for compensatory wetland
mitigation;
o will potentially improve riparian corridor and water quality of Kent’s Creek;
o will have fairly low construction cost with some additional temporary road
construction required;
o has a reluctant property owner/seller.
x Site E
oThe available hydrologic source appears to be adequate for mitigation;
owill improve and riparian corridor and water quality of Kent’s Creek;
othe site does have the potential for invasive species to invade the mitigation area;
owill have low construction cost with minor additional road construction or
wetland crossings needed;
o will have minimal impact to management of remaining crop field; and
7-8
004410
Recommendation
TRC recommends that Mitigation Site E be the wetland mitigation site chosen for the SLW
project, primarily because it has the best source of hydrology (water) and because there is a
willing property owner/seller.
The Mitigation Site E is located on the edge of an agricultural field along the west bank of Kents
Creek. The NRCS identifies the soils as Rhinebeck silt loam. These are a very deep, somewhat
poorly drained soils formed in glacio-lacustrine sediments having a high clay and silt
content. The vegetation of the site consists of herbaceous vegetation, which changes with the
management of the field. The nearest FEMA mapped floodplain area is located about 1.5 miles
downstream on Kents Creek. Mitigation Site E is located approximately 450 feet southwest of
DEC wetland “ST-10,” which is the nearest mapped DEC wetland. This site is located
approximately 500 feet northeast of a “PSS1A” NWI. Mitigation Site E will expand the riparian
wildlife corridor of Kents Creek, provide stream shading, and increase the buffer zone from the
current farming activities occurring on the proposed mitigation site.
7.3 Summary of Proposed Wetland Compensatory Mitigation
SLW proposes the following mitigation for the impacts to wetlands resulting from the Project:
1) The establishment of approximately 1.1 acres of compensatory wetlands (a 3:1 ratio of

permanently filled wetlands) created from an upland area in the Project area adjacent to an
existing wetland area bordering Kents Creek (Mitigation Site E);
2) The restoration of 0.87 acres (38,034 sq. ft.) of temporary impacted wetlands for the
installation of connector cable and temporary access; and
3) The management of invasive species and noxious weeds within the compensatory
wetland area.
7.4 Wetland Construction Plan
7.4.1 Mitigation Site Plans and Profiles
A mitigation plan and details depicting the approximate mitigation area boundaries and planting
specifications, including location, quantities, densities, and species necessary to establish a
forested scrub/shrub wetland at the mitigation site, are provided in Figure 7-2a and 7-2b -
Proposed Wetland Mitigation Area Plans. The plans show an approximate 1.1 acre wetland
compensatory area adjacent to an existing wetland located along Kents Creek. The boundary of
the existing adjacent and “reference” wetland as shown of Figure 7-2a was estimated through the
use of aerial photography, NYSDEC and NWI wetland mapping, and FEMA floodplain
mapping.
Prior to construction of the compensatory wetland, the existing wetland along the north bank of
Kents Creek will be delineated and GPS located. In addition, the seasonal groundwater elevation
of the wetland and existing vegetation will be characterized. The adjacent topography (contours)
7-9
004411
004412
will then be surveyed with horizontal and vertical datum control. Following field investigations,
the boundaries of the mitigation area will be determined along natural contours and breaks in
slope, and located on the final Figure 7-2a and 7-2b - Proposed Wetland Mitigation Area Plan.
Final drawing details of the mitigation plan will be added to these plans following the wetland
delineation and contour mapping, including subsoil and final grade specifications, topsoil
thickness, surface drainage requirements, and any necessary field adjustments to the proposed
planting plan.
7.4.2 Mitigation Site Construction Sequence
Construction planning for the compensatory wetland will commence once the Project access
roads have been completed, and before completion of all the wind turbines at the SLW
Windpower Project. Prior to commencement of work, a pre-construction meeting will be held to
familiarize contractors with the design and permitting requirements for the compensatory
wetland mitigation. The meeting will be convened by a wetland scientist familiar with the
requirements of the Project plans and the conditions issued by the ACOE. The Project wetland
scientist (or environmental monitor) will be present onsite during the construction to monitor the
work and to ensure compliance with requirements of the wetland replacement plans and permits.
The following is the construction sequence that will be followed:
x Prior to construction activities, the project wetland scientist/environmental monitor will

convene a meeting of wetland construction personnel to identify construction
expectations and environmental permit requirements.
x At the start of wetland construction activities, the limits of the wetland mitigation area
and adjacent existing wetlands will be marked in the field using brightly colored flagging
and then located via GPS.
x Erosion and sedimentation controls will be installed as depicted on project plans or as

directed by the environmental monitor.
x The area will be cleared and grubbed of all sapling and shrub vegetation.
x Excavation and rough grading may proceed following the inspection of all erosion and
sedimentation control barriers at the site and approval by the environmental monitor.
Excavation of material from each mitigation area will proceed until a rough grade
approximately 8-12” below proposed grading depicted on project plans is achieved.
x Excess subsoil excavated from mitigation areas will be properly managed within an
upland area outside of the mitigation area or hauled offsite.
x Following rough grading, an approximate 8-inch layer of topsoil will be placed within the
wetland mitigation area to achieve final grades depicted on the grading plans. Every
attempt will be made to segregate and stockpile the suitable wetland topsoil removed
from the proposed wetland fill area for the Project access roads to be used at the wetland
7-11
004413
Joint (Wetlands) Permit Application
ACOE File No. 2009-00590
Section 7.0
compensatory site. The topsoil will be supplemented with composted organic material
that is free of weed seeds. The soil amendment will have an organic material content of
at least 15%. Off-site soils should be friable, natural loam, free of subsoil, clay lumps,
brush, stones or other deleterious material larger than two inches. Additionally, it will be
required that the contractor demonstrate that off-site soil did not originate from a location
containing invasive species. Topsoil will be spread using heavy equipment. During
placement care will be taken to not compact the newly placed soils.
x Low-weight-to-surface area equipment (e.g. bobcat) will be used to create an irregular

surface with depressions that mimic small “pit and mound" topography as shown on the
“pit and mound” grading detail to be provided with the final wetland mitigation plan to
assist in creating saturated patches to resist the invasion and dominance of reed canary
grass (Phalaris) and other invasive species.
x The wetland mitigation area will be prepared prior to seeding by scarifying the surface
(i.e., disking or raking) to a depth no greater than 6”. Large rocks or course woody
debris encountered during the scarification process will be left on-site to provide wildlife
cover.
x The mitigation area will be planted with woody plants and other herbaceous plants as
shown on the Table 7-1 - Wetland Plant List for Compensatory Wetland Area Plan and
on Figures 7-2a and 7-2b. Pending availability of these plants, reasonable substitutes
may be made.
x Seed each area with a wetland seed mix at the rates indicated in Section 7.4.8 below.
Following seeding, the area will be mulched with straw or other acceptable mulches
certified free of invasive weed seeds.
x Inspect all installed erosion and sedimentation measures, repair as necessary, and install
barriers to prevent intrusion into the mitigation site.
The fundamental compensatory wetland plan is described as follows.
7.4.3 Grading, Soils, and Hydrology
The compensatory wetland site will be excavated and graded appropriately to create sufficient
depth and persistent wetland hydrology to accommodate the proposed compensatory wetland
area (approximately 1.1 acres). This grading will be conducted adjacent to existing reference
wetlands (the existing wetland bordering Kents Creek) to facilitate similar hydrologic conditions
influenced by soils and topography, and to receive floodwater when Kents Creek floods its
banks. The soil drainage class, depth to water table, and frequency of inundation of the soils
mapped to occur in these locations by the USDA Natural Resources Conservation Service are
indicators of hydrologic conditions suitable for constructing the compensatory wetlands. Surface
runoff is the primary source of soil saturation for the mitigation site. Proposed grades throughout
the created wetland will be designed to capture this surface drainage. Other suitable hydrologic
parameters observed in the reference wetland will be considered with respect to establishing
grading and soil depths at the wetland replacement site. These include: proximity to existing
wetlands, landscape position, evidence of soil saturation or inundation displayed by soil texture
7-12
Rev. May 17, 2010
004414
and coloration, presence of mottling or redoximorphic features, and the abundance of
hydrophytic vegetation.
7.4.4 Wetland Construction
Prior to construction, erosion controls will be installed in appropriate areas to protect adjacent
wetlands. A tracked excavator will be used at the compensatory wetlands site to create the basin
or depression necessary to store water, and to create somewhat irregular or small “pit and
mound” topography characteristic of natural wetlands. Total relief between the bottom of the
pools and the tops of the mounds will be no more than one vertical foot. Sub-grades will be
excavated eight to 12 inches below final grade to accept backfill with a corresponding thickness
of wetland topsoil. This thickness of topsoil is representative of the corresponding “A” horizon
in other undisturbed wetlands adjoining the replacement wetlands. As previously described, to
the extent feasible, hydric or wetland soil stockpiled from the wetlands to be filled will be
salvaged and spread over the surface of the replacement wetland. As necessary, this will be
supplemented with suitable organic-rich topsoil augmented with composted soil obtained locally.
After application of the topsoil to sub-grades, the constructed wetland footprint will blend in
with contours of adjacent undisturbed slopes. Along the transition area between the upland and
replacement wetland boundary, at least a 3:1 upland slope will be maintained.
7.4.5 Wetland Planting Plan
Reference Wetland Plants and Habitat

TRC evaluated the wetland data sheets for the Project (see Attachment B of the Joint
Application), including the palustrine scrub/shrub and forested wetlands (e.g. Wetland W31,
Wetland W41, and W43) and a list of wetland trees species for Jefferson County (USDA, NRCS.
2010) to establish the proposed compensatory wetland plant list and planting plan. The dominant
wetland tree species found in the project area include: Ironwood (Carpinus), Black willow (Salix
nigra), Green ash (Fraxinus pennsylvanica), American elm (Ulnus americana), and Red maple
(Acer rubrum). Shrub species in the Project area wetlands include: Silky dogwood (Cornus
amomum), (Lonicera spp.), Gray-stemmed dogwood (Cornus racemosa), and Red-osier
dogwood (Cornus stolonifera).
Wetland Compensatory Habitat Value Rationale

Given the extent of emergent wet meadow wetlands in the project area, many of which are
dominated by non-native Reed canary grass (Phalaris arundinacea) or surrounded by Reed
canary grass in the project area, and because the Project will involve converting approximately
14,781 square feet of forested wetland to emergent wet meadow and scrub/shrub vegetation in a
proposed connector cable corridor that traverses a forested area, SLW proposes to plant the
compensatory wetland area (1.1 acres) with forest species and a shrub species understory. In
addition, because of the extent of the existing Reed canary grass in adjacent wetland areas and
ditches in the project area, we propose planting a dense scrub/shrub border transition area at the
upland (agricultural field edge) to create more shade to discourage the spread of Reed canary
grass into the compensatory wetland area. This area will also be densely planted with
commercially available herbaceous stock and supplemented with an herbaceous wetland seed
mix, including annual rye grass in an attempt to rapidly populate all bare soil areas in an effort to
7-13
004415
minimize the early colonization of Reed canary grass into the compensatory wetland. The
herbaceous seed mix will be applied with a hydroseed application to further promote rapid
germination. The proposed 1.1 acres of compensatory wetland includes approximately 0.7 acres
of forested wetland (at a 2:1 ratio to converted wetland) and approximately 0.4 acres of
scrub/shrub and herbaceous wet meadow species (at a 1:1 ratio of filled wet meadow.)
Plant Quantity or Density

The primary goal for the compensatory wetland is flood storage and, to a lesser extent wildlife
habitat. Appropriate woody planting densities vary according to consideration of the functional
goals of the compensatory wetland, and planting densities may require adjustment depending on
field conditions such as micro-topography (pit and mound characteristics). Nearby forested
“reference” wetlands were also observed to facilitate the determination of an appropriate average
density.
SLW proposes a variety of plant species at an average density of at least 375-400 woody stems
(trees and shrubs) per acre. In addition, commercially available herbaceous stock will be planted
in densities not less than the equivalent of 3 feet on center for species which spreads with
underground rhizomes and 2 feet on center for species which form clumps. Herbaceous wetland
species stock are listed in Table 7-1 - Wetland Plant List for Compensatory Wetland Area Plan
and on Figures 7-2a and 7-2b. Actual species planted from this list will depend on commercial
availability, as approved by the project wetland scientist.
Table 7-1
WETLAND PLANT LIST
for
COMPENSATORY WETLAND AREA PLAN
Region 1
Quantity
Symbol Common Name Scientific Name Indicator
(stems)
Status
Maples
See
Figure 7-2a 50 Red Maple Acer rubrum FAC
“ 50 Silver Maple Acer saccharinum FACW+
Alders/Viburnums
“ 25 Speckled Alder Alnus rugosa FACW+

“ 25 Arrowwood Viburnum dentatum FACW+
Dogwoods
“ 50 Silky dogwood Cornus amomum FACW

Red Osier dogwood Cornus sericea ( or
“ 50 stolonifera) FACW+
Willows
“ 50 Black willow Salix nigra FACW+

“ Meadow willow* Salix petiolaris OBL
Others Shrubs and Tree Species
“ 25 Yellow birch Betula alleghaniensis FAC

“ 25 Iron wood or Muscle wood Carpinus caroliniana FAC
7-14
004416

ST. Lawrence Wind FEIS I

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FINAL ENVIRONMENTAL IMPACT STATEMENT

PROPOSED ST. LAWRENCE WINDPOWER PROJECT

1.1 State Environmental Quality Review Process

x FEIS acceptance by the Cape Vincent Planning Board

1.2 List of Required Permits and Approvals

Table 1-1 (Sheet 1 of 2)

Table 1-1 (Sheet 2 of 2)

NYSOPRHP (SHPO) Cultural Resources Consultation.

FAA Notice of Construction and Aviation Lighting Plan.

2.0 PROJECT MODIFICATIONS AND SUPPLEMENTAL INFORMATION

2.1 Revised Project Layout/Details

x Elimination of WTG 38 in response to a

2.2 Environmental Setting, Impact Analysis and Mitigation Measures

x Elimination of WTG 38 in response to a

2.2 Environmental Setting, Impact Analysis and Mitigation Measures

Surface Waters and Wetlands

2.2.1.2 Revised Impact Analysis

Surface Waters and Wetlands

2.2.1.3 Supplemental Mitigation Measures

Surface Waters and Wetlands

and overflowing of Kent’s Creek. The

2.2.2 Ecological Resources

Threatened and Endangered Species

and overflowing of Kent’s Creek. The

2.2.2 Ecological Resources

Threatened and Endangered Species

Sub-Station/ Collector Construction

2.2.2.2 Revised Impact Analysis

Threatened and Endangered Species

2.2.2.3 Supplemental Mitigation Measures

Threatened and Endangered Species

Exhibit 2.2.2 – Proposed Grassland Bird Conservation Easement

2.2.3.2 Revised Impact Analysis

Octave Band Center

Sound Related Health Impacts

In December 2009, a report was published by a panel composed of professionals of varied

“In epidemiology, initial case reports and uncontrolled observations of disease

The panel concluded that:

2.2.3.3 Supplemental Mitigation Measures

2.2.4 Shadow Flicker

2.2.4.2 Revised Impact Analysis

2.2.4.3 Supplemental Mitigation Measures

2.2.5 Transmission Line

Exhibit 2.2.6 – Plan View of Proposed Transmission Owner Interconnection Substation

Exhibit 2.2.7 – Profile View of Proposed Transmission Owner Interconnection Substation

x Provide construction plans and specifications for DANC’s approval;

2.2.5.2 Revised Impact Analysis

2.2.5.3 Supplemental Mitigation Measures

2.2.6 FAA/NTIA (Communications)

2.2.6.2 Revised Impact Analysis

2.2.6.3 Supplemental Mitigation Measures

2.2.7.2 Revised Impact Analysis

2.2.7.3 Supplemental Mitigation Measures

ROW Impacts to Non-

Utility Pole Impacts

Unanticipated Discoveries Plan

Revised Complaint Resolution Plan

Spill Prevention, Control, and Countermeasure Plan (SPCC)

Draft Wildlife Protection Plan (WPP)

Draft Outline of Construction Environmental Monitoring Plan

FAA Final Lighting Plan

3.0 COMMENT MATRIX

It is difficult to assess this SDEIS with a highly inaccurate description of the