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WPEG Comment Letter to PSC Re: Article 10

WPEG Comment Letter to PSC Re: Article 10

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Published by pandorasboxofrocks
Wind Power Ethics Group Comment Letter to PSC Re Article 10
Wind Power Ethics Group Comment Letter to PSC Re Article 10

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Published by: pandorasboxofrocks on May 30, 2012
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05/30/2012

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May 24, 2012Honorable Jaclyn A. Brilling, SecretaryNew York State Board on Electric Generation Siting and the EnvironmentEmpire State PlazaAlbany, NY 12212-1350Dear Secretary Brilling,
RE: In the Matter of the Rules and Regulations of the Board on Electric Generation Sitingand the Environment
 
HISTORY
: WIND POWER ETHICS GROUP LLC was formed in 2006 due to the fact thattwo industrial wind turbine developers proposed over 250 wind turbines in our small town of Cape Vincent which is five miles along Lake Ontario and fifteen miles along the St LawrenceRiver. At the time our Town and Planning Boards consisted of officials with wind turbine leases.They appeared to make decisions based on their self interest, rather than what might be best forthe entire community. Our organization financially invested in studies, educational presentationsand awareness for the concerned public regarding all aspects of wind turbine development. Todo this we investigated and researched the information that was provided by the wind turbinecompanies. As a result of these efforts an increased number of citizens have voted into officenon-conflicted board members who are making decisions for the best interest of the wholecommunity. We believe in
home rule
and feel that our town and planning boards should not beleft out of the future planning for any energy development in Cape Vincent.
COMMENTS REGARDING THE DRAFT REGULATIONS:
 Local laws:
First, we ask that the applying local substantial laws continue to be the default position. Thewind developers are asking that locally laws be preempted entirely. We remind you that theactual language passed by the legislature and governor was clear that the local laws would beapplied unless "unduly burdensome". The applicants should bear the burden of proving locallaws are burdensome. New York State is historically a
home rule
state and each municipality hascarefully developed its own laws for its unique area.
1000.15 Acceptance of a Certificate 
(a) Upon issuance of a final decision by a Board granting a Certificate, an applicant shall,within 30 days after the issuance of such decision, file either a written unqualified acceptance of the Certificate or a petition for rehearing, but not both.
We ask that this paragraph be amendedto include the municipality has the right to ask for a rehearing also. We find it an unfairadvantage that an applicant has more rights than the local municipality.
 
 Public Involvement:
The NY Power Act clearly states the Chair shall make decisions in consultation with the Boardexclusive of the ad hoc members. Considering all the rhetoric about public involvement it seemsimportant that the decisions be made by a vote including the ad hoc members. The fact that thead hoc members are not required for a quorum is additional injury to real public involvement andshould be necessary for a quorum. Siting Board meetings should take place within themunicipality where a project is proposed.This comment period has only been 60 days and some of the time the PSC web page carrying thedraft regulations has been offline. Town Boards meet only once a month and this time period isinadequate to carefully consider issues that will have a lasting impact on their communities. A 30day extension to this comment period is requested.
Socioeconomic Effects:
 
One issue we experienced firsthand was weighing the possible benefits of a development againstthe losses. Currently the draft regulations only consider the benefits such as jobs, PILOTS,secondary industries, and so forth. It is obvious that virtually every development has somenegative impact on the involved local community. We ask that an economic analysis include theentire effects; not just the benefits.
 Noise Issues:
Sound studies have been a huge issue in our community. The developers sound studies haveshown a large discrepancy with two independent sound studies. Developer studies havecompletely ignored the issue of low level sound vibration and it is clear communities need to beprotected from damaging sounds and vibrations. We would like a cap on sound: 5 dba aboveambient as recommended by the DEC or not more than 35dba at non participating property lines.Measuring low level vibration should also be a requirement especially as more and more data isavailable demonstrating harmful effects of low level vibration(C weighting) and sound ingeneral.
Wildlife Protection:
Ornithologists take the position that bird and bat studies should continue for three years toaccount for seasonal variation. Applicants should be expected to present verifiable wildlifestudies to protect the local wildlife. The 86 wind turbine complex on Wolfe Island, Canada, justtwo miles away from Cape Vincent in the St. Lawrence River has some of the recorded highestbird kills in the world. Documented reports show the short eared owls moved away from theturbines, the osprey immigrated into Cape Vincent and 15 red tailed hawks were killed within thewind turbine development area. Valid studies take time, the regulations should make sure studiesare at least a year in length at the very minimum.

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