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Final Environmental Impact Statement

Hounsfield Wind Farm

Town of Hounsfield
Jefferson County, New York

Lead Agency:
New York State Department of Environmental Conservation
Division of Environmental Permits
625 Broadway, 4th Floor
Albany, New York 12233
Steven Tomasik
518-486-9955

Project Sponsor:
Upstate NY Power Corp
950-A Union Road, Suite 20
West Seneca, NY 14224

Prepared by:
American Consulting Professionals of New York, PLLC
70 Niagara Street, Suite 410
Buffalo, NY 14202

Date of Acceptance by Lead Agency: December 23, 2009

1.0
Introduction.......................................................................................................... 1-1
1.1
Proposed Action............................................................................................... 1-1
1.2
Project Need and Benefits................................................................................ 1-2
1.3
In-water and Mainland Transmission Facilities............................................... 1-8
1.4
Location ........................................................................................................... 1-9
1.5
Project Area ..................................................................................................... 1-9
1.6
Construction Schedule and Phasing............................................................... 1-10
1.7
Project Sponsor .............................................................................................. 1-10
1.8
SEQR Process and Chronology ..................................................................... 1-11
1.8.1
Application............................................................................................. 1-11
1.8.2
Lead Agency Determination .................................................................. 1-11
1.8.3
Public Scoping ....................................................................................... 1-12
1.8.4
Draft Environmental Impact Statement and Public Comment .............. 1-12
1.8.5
Final Environmental Impact Statement ................................................. 1-12
1.9
Methodology for FEIS Preparation................................................................ 1-13
1.10 Required Permits and Approvals ................................................................... 1-13
1.11 Project Consultation....................................................................................... 1-16
1.12 Project Components that have Changed Since the DEIS............................... 1-17
1.12.1
Borrow Pit.............................................................................................. 1-17
1.12.2
Woody Mulch Area................................................................................ 1-18
1.12.3
Sediment Basins..................................................................................... 1-18
1.12.4
Worker Parking and Staging Areas on the Mainland ............................ 1-19
1.13 Clarifications of Project Components............................................................ 1-20
1.13.1
Water Intake Pipe................................................................................... 1-20
1.13.2
On Island Fuel Storage........................................................................... 1-21
1.13.3
Project Design........................................................................................ 1-22
2.0
Resource Characterization, Impact Assessment and Mitigation.......................... 2-1
2.1
Topography, Geology and Soils ...................................................................... 2-1
2.2
Land and Land Use .......................................................................................... 2-2
2.3
Agricultural Resources..................................................................................... 2-4
2.4
Water Resources .............................................................................................. 2-4
2.4.1
Surface Water........................................................................................... 2-4
2.4.2
Sediment .................................................................................................. 2-5
2.4.3
Wetlands .................................................................................................. 2-5
2.4.4
Groundwater ............................................................................................ 2-7
2.5
Wildlife and Habitat......................................................................................... 2-7
2.5.1
Flora and Fauna........................................................................................ 2-7
2.5.2
Rare, Threatened and Endangered Species............................................ 2-10
2.5.3
Avian Species......................................................................................... 2-11
2.5.4
Bats ........................................................................................................ 2-17
2.5.5
Post-Construction Monitoring Plan ....................................................... 2-17
2.5.6
Fish and Aquatic Species ....................................................................... 2-17
2.6
Visual Resources............................................................................................ 2-19
2.7
Archaeological and Historic Resources ......................................................... 2-24
2.8
Socioeconomics ............................................................................................. 2-27
2.9
Public Safety .................................................................................................. 2-28
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2.10 Microwave Beam Interference....................................................................... 2-28


2.11 Blasting Issues ............................................................................................... 2-28
2.12 Decommissioning .......................................................................................... 2-29
2.13 Mandated FAA Lighting................................................................................ 2-29
2.14 Air Resources................................................................................................. 2-29
2.15 Noise .............................................................................................................. 2-31
2.16 Alternatives .................................................................................................... 2-33
2.17 Coastal Zone Consistency.............................................................................. 2-33
2.18 Cumulative Impacts ....................................................................................... 2-35
2.19 Transmission Line.......................................................................................... 2-36
3.0
Response to Comments........................................................................................ 3-1
Topic: Project Description ........................................................................................... 3-1
Topic: Purpose Need and Benefits.............................................................................. 3-4
Topic: General Description........................................................................................ 3-12
Topic: Project Design ................................................................................................ 3-13
Topic: Construction ................................................................................................... 3-26
Topic: Permits and Approvals ................................................................................... 3-29
Topic: Ownership....................................................................................................... 3-29
Topic: Topography, Geology and Soils ..................................................................... 3-31
Topic: Land Use......................................................................................................... 3-32
Topic: Agricultural Resources ................................................................................... 3-39
Topic: Surface Water ................................................................................................. 3-39
Topic: Marine Sediment ............................................................................................ 3-42
Topic: Wetlands ......................................................................................................... 3-43
Topic: Wildlife and Habitat ....................................................................................... 3-48
Topic: Flora and Fauna .............................................................................................. 3-53
Topic: Avian Species ................................................................................................. 3-55
Topic: Bats ................................................................................................................. 3-76
Topic: Post Construction Monitoring Plan ................................................................ 3-78
Topic: Fish and Aquatic Species................................................................................ 3-80
Topic: Visual Resources ............................................................................................ 3-85
Topic: Archeological and Historic Resources ........................................................ 3-100
Topic: Socioeconomics............................................................................................ 3-104
Topic: Blasting......................................................................................................... 3-105
Topic: Decommissioning ......................................................................................... 3-105
Topic: FAA Lighting ............................................................................................... 3-106
Topic: Noise............................................................................................................. 3-107
Topic: Alternatives................................................................................................... 3-111
Topic: Coastal Zone Consistency ............................................................................ 3-115
Topic: Cumulative Impacts...................................................................................... 3-119
Topic: Cumulative Impacts Visual ....................................................................... 3-121
Topic: Transmission Line ........................................................................................ 3-122
Topic: Other ............................................................................................................. 3-129
Topic: Environmental Impact of the Upstate Power Transmission Line Article VII
Application Exhibit 4............................................................................................... 3-133
Topic: Bat Report..................................................................................................... 3-135
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Topic: Visual Resource Assessment........................................................................ 3-135


Topic: Ecological Resources Report........................................................................ 3-136
Topic: Invasive Species Control Plan ...................................................................... 3-138
Topic: Appendix B: Conceptual Design Report for Selected Infrastructure
Improvements on Galloo Island, Water Intake Structure and Pipeline ................... 3-140
Topic; SPCC ............................................................................................................ 3-141
Topic: Diurnal Bird Movement ............................................................................... 3-148
Topic: Breeding Bird Survey ................................................................................... 3-149
Topic: Avian Risk Assessment ................................................................................ 3-150
Topic: Spring 2008 Radar Survey Report................................................................ 3-153
4.0
Comments Received on DEC Permits ................................................................. 4-1
5.0
References............................................................................................................ 5-1

List of Figures (Following Text)


Figure 1.0-1 Site Location
Figure 1.1-1 Project Layout
Figure 1.1-2 Revisions to Project Layout
Figure 2.5.3-1 Project Layout Showing Southern Grasslands
Figure 2.7-1 Project Layout with Archaeological Sites
Figure 2.18-1 - Cumulative Vegetative Viewshed
Figure 3.0-1 Property Ownership
Figure 3.0-2 Wehle Development Plan
Figure 3.0-3 Project Layout with 230kV Transmission Line
Figure 3.0-4 Distance between Proposed Transmission Line and Wehle State Park
Figure 3.0-5 Calcareous Shoreline
Figure 3.0-6 Radar survey table

Tables
Table 1.5-1: Area Occupied by Permanent Project Features........................................... 1-9
Table 1.10-1: Anticipated Permits and Approvals......................................................... 1-14
Table 2.2-1: Total Acreage of Permanent Impacts from Project ..................................... 2-3
Table 2.2-2: Total Acreage of Temporary Impacts from Project .................................... 2-3
Table 2.5-1 Permanent Impacts to Habitat ...................................................................... 2-9

Appendices
Appendix A
Appendix B
Appendix C
Appendix D
Appendix E
Appendix F
Appendix G
Appendix H
Appendix I
Appendix J
Appendix K
Appendix L
Appendix M
Appendix N
Appendix O
Appendix P
Appendix Q

Comments of the DEIS


Spill Prevention, Control and Countermeasures Plan
Mined Land Reclamation Plan
Conceptual Blasting for Offloading Facility
Conceptual Wetlands Mitigation Plan
Pale Swallow-wort Control Plan
Blandings Turtle Trapping and Nesting Survey Report
Bird Reports
Post Construction Monitoring Plan
Additional Visual Simulations
Cultural Resources Reports
Revised On-shore Blasting Plan
Air Quality Analysis
Noise Reports
Coastal Management Program federal Consistency Assessment Form
Exhibit E-3 of the Article VII Application
Agency Correspondence

Hounsfield Wind Farm


Final Environmental Impact Statement

1.0 Introduction
This Final Environmental Impact Statement (FEIS) has been prepared for the proposed
project known as the Hounsfield Wind Farm (the Project). The FEIS has been prepared
in accordance with the State Environmental Quality Review Act (SEQRA)
Environmental Conservation Law (ECL 8-0101 et seq,; 6 NYCRR Part 617) and its
implementing regulations on behalf of the SEQR Lead Agency, the New York State
Department of Conservations (NYSDEC).

This FEIS consists of the DEIS (by

reference), revisions and supplements to the text of the DEIS, a summary of the public
comments made on the DEIS and responses to those comments, and additional studies or
reports compiled since the issuance of the DEIS.
This FEIS is organized into several sections. Section 1 presents the description of the
project as it is currently proposed including any changes and clarifications to the project
since the DEIS; Section 2 summarizes the impacts and mitigations proposed based on
issues raised by public comments and the resulting project modifications. Section 3
contains the comments submitted during the public comment period and responses to
those comments. Section 4 presents comments and responses submitted during the public
comment period for permits associated with the project that were submitted to NYSDEC.
Supplemental data presented to respond to comments are provided in appendices
following the report. As stated in the DEIS, the Project is a utility scale commercial wind
farm to be located on Galloo Island (Project Site), in the Town of Hounsfield, Jefferson
County, New York and is depicted in Figure 1.0-1 Site Location. The Project is
proposed by the Upstate NY Power Corp (Upstate Power) of West Seneca, New York.
1.1

Proposed Action

The Action involves the permitting/approvals and physical activities related to the
construction and operation of the island-portion of the wind powered electric generation
facility on Galloo Island, which consists of 84 wind turbine generators (WTG), capable
of generating up to 252 megawatts (MW) of power at peak capacity, and related support
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facilities (see Figure 1.1-1 Project Layout). Specifically, the key Project elements on
Galloo Island and being reviewed as part of the SEQRA process include:
Construction and operation of 84 WTG. The proposed WTG will be a 3.0 MW
generator with a 90 meter blade rotor diameter and a hub height of 80 meters, for
a total maximum height of 125 meters (410 feet) from blade tip to ground.
Installation and operation of associated 34.5 KV electrical collection system (ECS)
connecting all WTG to an on-island electrical substation. The ECS will be both
above ground and below ground.
Construction of 17.01 miles of private service roads (up to 38 feet wide) between
each WTG.
Construction of a woody mulch area for clearing activities.
Construction of sediment basins for erosion and stormwater control.
Construction of a temporary dock.
Construction of a potable and fire protection water intake pipe.
Construction and operation of a temporary borrow pit for road aggregate.
Construction of one permanent meteorological tower, approximately 80 meters in
height.
Construction of operation and maintenance facilities.
Construction of a temporary rock crushing facility and concrete batch plant.
Construction of permanent and temporary housing facilities for construction,
operation and maintenance staff.
Construction of a potable water treatment system.
Construction of a sewage treatment system.
Construction of an auxiliary power generating system.
Construction of a closed loop geothermal heating and cooling system for permanent
residential facilities.
Construction of a permanent slip channel and offloading/storage area.
Construction of a helicopter pad and garage.
1.2

Project Need and Benefits

Since the DEIS was published in February 2009, the need for renewable energy
generation projects has been identified by a number of New York State electricity and
energy policy-makers. New Yorks energy future will increasingly rely on local in-state
renewable energy sources to promote fuel diversity and energy security, reduce
greenhouse gas (GHG) emissions, and particularly reduce NOX, SOX and CO2
emissions, improve environmental and public health, and support New Yorks green
economy.

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Draft State Energy Plan


In August 2009, the New York State Energy Planning Board issued the 2009 Draft State
Energy Plan (State Energy Plan). The State Energy Plan sets forth a vision for a
robust and innovative Clean Energy Economy that will stimulate the economy, create
jobs, and meet the energy needs of residents and businesses.(State Energy Planning
Board, 2009)

The State Energy Plans policy objectives include (1) maintaining

reliability (2) supporting energy systems that enable the State to significantly reduce
GHG emissions (3) stabilizing energy costs and improving economic competiveness (4)
reducing health and environmental risks associated with the production and use of energy
and (5) improving the States energy interdependence and fuel diversity by developing
in-state energy supply resources. The State Energy Plan recognizes that wind energy
projects will play an instrumental role in meeting the policy and goals of the State Energy
Plan and specifically in meeting the objectives mentioned above. In addition, the State
Energy Plan underscores the importance of developing in-State renewable energy
projects in order for the State to meet these goals and objectives by stating:
Production and use of in-state energy resources can increase the reliability and security
of energy systems, reduce energy costs, and contribute to meeting climate change and
environmental objectives. To the extent that renewable resources and natural gas are able
to displace the use of higher emitting fossil fuels, relying more heavily on these in-state
resources will also reduce public health and environmental risks posed by all sectors that
produce and use energy. Additionally, by focusing energy investments on in-state
opportunities, New York can reduce the amount of dollars exported out of the State to
pay for energy resources. By re-directing those dollars back into the State economy, New
York can start to increase its economic competitiveness with other states that are less
dependent on energy supply imports to support their local economies. (Page 36, State
Energy Planning Board, 2009).
Regarding renewable energy sources such as wind, the Energy Plan states that When
compared with carbon-intensive fossil fuel resources, renewable resources generally have

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significantly lower negative impacts on public health and the environment, and contribute
less to climate change. (Page 36, State Energy Planning Board, 2009).
The Hounsfield Wind Project, as a wind farm located on an unpopulated island several
miles from the mainland, is in a unique position to assist the State in meeting each of the
policy objectives listed in the State Energy Plan while minimizing potential
environmental impacts and impacts of local concern typically associated with windpowered electric generating facility siting and development in New York State. As a
large wind project, the Project will help New York achieve a reliable energy system by
diversifying the States generation mix. (Policy objective #1). As recognized by the State
Energy Plan, adding to the States renewable mix can provide further diversity.(State
Energy Planning Board, 2009) A diverse fuel mix can help avoid the impacts to prices
and availability of energy due to weather conditions, economic events, or disruptions in
the supply chain. The Project proposes to add a nameplate capacity of 252 MW of windpowered electricity to the States electrical grid. The Project will represent the second
largest wind powered electric generating facility in New York State, and as such will play
a significant role in diversifying the States energy mix.
In addition, the Project will result in significant reductions in GHG emissions compared
with the use of fossil fuels for electricity generation, consistent with policy objective #2.
Wind projects are desirable and promoted by many State and Federal policies due to their
low GHG and other dangerous contaminants (NOX, SOX, PM) emissions. Related to
this, the State Energy Plan states that a decrease in emissions of contaminants will
reduce the likelihood of both health and environmental impacts.

This can be

accomplished through a shift to cleaner carbon based fuels or non-carbon based energy
sources across all energy sectors. (Policy Objective #4). (State Energy Planning Board,
2009) The Hounsfield Project, utilizing the wind rather than a carbon based energy
source, will have a positive effect in reducing GHG and dangerous contaminant
emissions thereby reducing public health and environmental risks consistent with Policy
Objective #4.

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Policy objective #3 can be achieved by the Project because a diversified fuel mix is likely
to lead to less volatile electricity prices and therefore lower rates for consumers. The
diversification of the fuel mix also has the benefit of increasing energy security consistent
with Policy Objective #5. As noted in the State Energy Plan, reliance on outside energy
sources creates economic opportunities in exporting regions at the expense of New York.
The Project will assist in increasing New York State-based energy generation. In addition
to being a local source of renewable energy, the Hounsfield Project will also provide
benefits to the State and local economy through, among other ways, a PILOT agreement
totaling approximately $2.14 million annually.
In addition, the Draft State Energy Plan lists the following benefits of renewable energy
resources, such as the Hounsfield Wind Project (Issue Brief, Renewable Energy
Assessment, page 2):
Reduce the net retail price of electricity. Renewable electricity resources reduce the net
retail price of electricity paid by all ratepayers. In 2018, the average statewide retail price
of electricity is projected to be 0.06 to 0.16 cents per kWh lower than it would otherwise
be without the implementation of RPS-supported renewable resources, representing an
annual bill savings to ratepayers of $93 to $262 million. The estimated net retail price
impact includes a reduction in the wholesale commodity price of electricity of 0.26 cents
per kWh, netted against the estimated retail price increase of 0.1 to 0.2 cents per kWh,
due to the collection of ratepayer funds to pay the price premium for the purchase of
renewable energy under the RPS and backing out of the more expensive, less efficient
fossil fuel-fired units (State Energy Planning Board, 2009).
Help achieve environmental goals. Renewable resources reduce the need for electricity
generated by fossil fuel-fired sources. In 2018, it is projected that the electricity
generation displaced due to the availability of new renewable resources will be 65
percent natural gas and oil, 7 percent coal, and 28 percent imports from other states.
(State Energy Planning Board, 2009). Less generation from fossil fuel-fired units results
in lower emissions of air pollutants, which means that fewer emission reduction measures

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will be needed to achieve statewide and regional emission caps and that the cost of
compliance with emission caps will be reduced. The renewable resources needed to meet
the 30 percent RPS goal in 2015 are projected to reduce expenditures for carbon dioxide
(CO2) allowances by about $82 million per year (State Energy Planning Board, 2009).
Create jobs, income, and economic development opportunities. The direct economic
benefits of renewable energy include the creation of short-term and long-term jobs,
increased capital investment, increased tax revenues for local governments, and increased
revenue for landowners. Data from the first three RPS solicitations indicate that Main
Tier projects supported by the RPS program are expected to produce direct economic
benefits of more than $25 per MWh over the average 20-year life of a project, compared
to the average price premium of less than $18 per MWh (generally paid under 10-year
contracts) (State Energy Planning Board, 2009). In 2008, it was estimated that the Main
Tier facilities from the first three solicitations had produced 2,947,000 MWh, which
represents 30 percent of the Main Tier target under the Service Commissions Order
Approving Renewable Portfolio Standard Policy (2004 Order); the benefit-cost ratio for
these three solicitations is estimated to exceed six-to-one. By 2015 the total economic
benefits of the RPS Program, which include the macroeconomic ripple effects of
injecting incremental income into the State economy over 20 years, are estimated to be
$4.2 billion for the first three Main Tier solicitations and $12.5 billion for the fully
expanded 30 percent RPS Program.
Reduce energy imports. Renewable energy helps to reduce the reliance on fossil fuels
imported from outside the State and/or the nation, thereby increasing the security of
energy supplies.
Reduce price volatility of fossil fuels. Renewable energy contributes to the reduction of
energy price volatility in the long-term. Because the production cost for renewable
energy remains stable throughout unpredictable fossil fuel price fluctuations, renewable
resources can provide cost-effective options for managing the risks associated with fossil
fuel use.

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Reduce negative health impacts. As detailed in the Health Issue Brief appended to the
Draft State Energy Plan, increasing the amount of energy generated by renewable
resources such as solar, wind, and hydropower will, in general, decrease the health risks
associated with energy use. Many renewable resources emit no air pollutants at the site of
electricity generation, or produce relatively low emissions when compared to fossil fuels,
especially with respect to pollutants like particulate matter, nitrogen oxides, sulfur
dioxide, and mercury, which can have negative health impacts.
Executive Order No. 24
On August 6, 2009, Hon. Governor David A. Paterson signed Executive Order No. 24
setting a goal to reduce GHG emissions in New York State by 80 percent below the
levels emitted in 1990 by the year 2050. The Executive Order also created a Climate
Action Council with a directive to prepare a draft Climate Action Plan by September 30,
2010. The Climate Action Plan will assess how all economic sectors can reduce GHG
emissions and adapt to climate change, as well as identify the extent to which such
actions support New Yorks goals for a clean energy economy. According to Executive
Order No. 24, Climate change is the most pressing environmental issue of our time. By
taking action, we send a signal that New Yorkers will do our share to address the climate
crisis and we will do it in a way that creates opportunities for innovation and
entrepreneurship to flourish. (Executive Order 24. 2009)
As mentioned above, the Project is consistent with a policy of reducing GHG emissions.
Moreover, it is likely that the Climate Action Plan will rely on the development of
renewable energy sources, such as wind, in order to reduce GHG emissions while
continuing to ensure the reliable future supply of electricity and energy for New York.
Public Service Commission RPS Mid-Course Report
On October 26, 2009, the New York Public Service Commission issued a Mid-Course
Report on the Renewable Portfolio Standard program. The purpose of the Report is to
summarize the results of the RPS program and evaluate whether it should continue and
whether any modifications are required. The Report notes that the State Energy Policy is
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evolving and specifically mentions the policy initiatives promoting energy efficiency and
the development of a clean energy economy by creating a demand for in-State
renewable energy technologies and services. In addition, the Report notes that it is in
the public interest to expand renewable energy investments in New York. (See Report
at page 5). The Report continues that it is equally important to evaluate the adverse
environmental implications of not supporting the expansion of these valuable
resources. Moreover, the Report concludes that the Main Tier of the RPS (the tier in
which the Project would fall), provides significant environmental benefits, does not
result in large rate increase, improves generation resource diversity, provides a number of
difficult to quantify benefits, and has a potential to act as a hedge against wholesale
electricity price swings. The Main Tier RPS program is, therefore, in the public interest
and should be continued.

In fact, the Report concludes that the Main Tiers

environmental benefits (if monetized) in combination with its price suppression effects
more than offset its cost. (NYSDPS, 2009)
2009 NYISO Report
In addition, in a report issued in June 2009, the NYISO looked at the impact of Plug-in
Hybrid Electric Vehicle technology on grid operations and electricity system planning
and concluded that, in general, the production profile of wind resources in New York
correlates very well with off-peak charging of PHEVs, creating the potential for a
synergy between wind generation and transportation energy needs. (NYISO, Alternate
Route: Electrifying the Transportation Sector, June 2009)
1.3

In-water and Mainland Transmission Facilities

In addition to the activities associated with the Project identified above, the transmission
of the electricity will require construction and operation of a major electric transmission
line together with interconnection facilities (substations) and other related facilities,
linking Galloo Island with the New York State power grid.

The construction and

operation of this major transmission line, between Galloo Island and the point of
interconnection in the Town of Mexico, New York, is subject to the review jurisdiction of
the New York State Public Service Commission (PSC) under Public Service Law (PSL)
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Article VII (See Case No. 09-T-0049).

The construction of the major electric

transmission line is a Type II action under SEQRA (6 NYCRR 617.5(c) (35)) not
subject to SEQRA review (6 NYCRR 617.5(a)). The evaluation of the potential impacts
from the construction and operation of the transmission line are not included in the EIS
for the wind farm. However, these potential impacts will be fully discussed in the Article
VII proceeding.
1.4

Location

The Project is located on Galloo Island in the Town of Hounsfield, Jefferson County,
New York Figure 1.0-1. Galloo Island is located in the eastern basin of Lake Ontario
approximately 12 miles south of the head of the St. Lawrence River at Cape Vincent.
The 1,966 acre island is divided into seven parcels, owned by four separate owners. All
WTG, ECS, service roads and support facilities will occur on approximately 1,938 acres
currently owned by the Galloo Island Corporation.
1.5

Project Area

Project Features
It is anticipated that development of the permanent Project elements (WTG, ECS, service
roads, operations and maintenance facilities and other support facilities) will occupy a
total of approximately 158.66 acres or 8.07% of the Island. The remaining Project
property will remain undeveloped. Table 1.5-1 presents the breakdown of areas to be
used for permanent Project activity. Although a temporary use 2.06 acres of the laydown
area are currently forested and therefore are considered a permanent impact.
Additionally, the borrow pit will be regraded and reseeded when it is closed. However, it
will not be restored to its original topography and is therefore also conservatively
considered a permanent impact.
Table 1.5-1: Area Occupied by Permanent Project Features

PROJECT FEATURES
WTGs (includes pedestal and crane pad)
Service Roads
ECS Underground (cleared)
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AREA
(Acres)
16.982
95.989
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Final Environmental Impact Statement

ECS Aboveground (cleared)


Laydown Areas
Woody Disposal Area
On-island Substation
Gravel Borrow Pit
Slip Facilities Permanent
O&M Buildings, Residential and Support
Facilities
Helicopter Pad and garage
Wetlands Mitigation Area
TOTAL AREA

8.515
9.417
1.01
1.241
2.060
8.135
4.305
0.193
0.558
158.586

Temporary Features
Temporary Project features built for use only during construction include the temporary
dock facilities and the temporary concrete batch plant and will occupy approximately 141
acres and will be restored upon completion of Project construction.
1.6

Construction Schedule and Phasing

The general construction schedule has not significantly changed since completion of the
DEIS. Upstate Power anticipates a three year construction period, beginning in Fall 2010
and to be complete in Fall 2012.

The commencement of construction activities is

contingent upon obtaining all necessary permits and approvals, including but not limited
to those from the United States Army Corp of Engineers, NYSDEC and PSC (off-island
transmission line). Due to difficulties associated with working on Galloo Island during
winter months, it is anticipated that on-island construction work will only take place from
April through November during the construction phase of the Project.
1.7

Project Sponsor

The Project sponsor is Upstate NY Power Corp (Upstate Power) of West Seneca, New
York. It is a New York State electric corporation pursuant to the Transportation
Corporations Law, with the power of Eminent Domain. It is a public utility under both
federal and state law, operating under significant measures of federal and state regulation.
Among other things, it is subject to regulation by the FERC under the Federal Power Act,

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16 USC 24(c)(d) and will be subject to regulation as an electric corporation under the
State Public Service Law.
1.8

SEQR Process and Chronology

As stated in Section 1.0, the Project is subject to review under the State Environmental
Quality Review Act (SEQRA). The SEQRA Regulations (6 NYCRR Part 617) provide
guidance and a uniform process for regulatory agencies to follow in conducting an
environmental evaluation of a proposed project. Key milestones for the SEQRA process
conducted for the Project are described below.
1.8.1

Application

On November 20, 2007, the Town of Hounsfield Planning Board received an Application
for Site Plan Approval and a SEQRA Environmental Assessment Form (EAF) from
Upstate Power for development of the Project.
1.8.2

Lead Agency Determination

The Planning Board determined that the Project was a Type I Action under SEQRA.
Accordingly (pursuant to 6 NYCRR 617.6(b)(3)) on December 5, 2007 the Planning
Board circulated a Lead Agency Coordination Letter and EAF Part 1 to all anticipated
Involved Agencies. In this correspondence, the Planning Board indicated its desire to act
as Lead Agency for the purpose of a Coordinated SEQRA review of the Project. By
letter dated January 4, 2008 the NYSDEC advised the Planning Board of its desire to act
as Lead Agency.
The Lead Agency dispute was submitted to the Commissioner of NYSDEC in accordance
with the requirements of 6 NYCRR 617.6(b)(5). On April 24, 2008, the Commissioner
determined that based on the criteria set forth in 6 NYCRR 617.6(b)(5)(v) NYSDEC
should act as Lead Agency.

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1.8.3

Public Scoping

On May 21, 2008, the NYSDEC (pursuant to 6 NYCRR 617.7) determined that the
Project may have the potential for a significant adverse environmental impact on the
environment and that a Draft Environmental Impact Statement (DEIS) must be prepared.
At that time, the NYSDEC also required Public Scoping for the Proposed Action. Public
Scoping, under 6 NYCRR 617.8, is the process by which the Lead Agency, in
cooperation with the public and involved or interested agencies, identifies potentially
significant adverse impacts that should be considered in a DEIS. As part of the EIS
process and in accordance with 6 NYCRR 617.8, a Draft Scoping document was
prepared by Upstate Power and circulated to Involved and Interested Agencies and the
Public for review and comment.
Written comments on the Draft Scope for the Proposed Action were accepted until the
end of the business day on June 30, 2008. The Final Written Scope was issued by DEC
on September 22, 2008.
1.8.4

Draft Environmental Impact Statement and Public Comment

The DEIS was prepared in accordance with the content requirements outlined in 6
NYCRR 617.9(b). On February 27, 2009 the NYSDEC accepted the DEIS as adequate
for public review and published the Notice of Completion of the DEIS indicating the
document was available for review by agencies and the public. The public comment
period ran for 90 days until May 29, 2009. During this period a public hearing was held
on May 18, 2009 in Hounsfield, New York to allow for public comment. In addition to
the public hearing, the public and various local, state and federal agencies submitted
written comments to the Lead Agency regarding the Project.
1.8.5

Final Environmental Impact Statement

Issuance of the Notice of Completion of the Final Environmental Impact Statement


(FEIS) fulfils NYSDECs responsibilities as Lead Agency for SEQR review of the
project. After 10 days have elapsed following the Notice of Completion, any involved

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agency may rely on the SEQR record prepared by the Lead Agency and issue Findings
prior to rendering a discretionary agency decision related to this action.
1.9

Methodology for FEIS Preparation

Written comments on the DEIS were accepted by the Lead Agency though the close of
the public comment period on May 29, 2009. A transcript of the oral comments received
at the public hearing was provided to the Lead Agency. Twenty three written comments
were submitted to the Lead Agency and four commenters spoke at the public hearing. In
addition, written comments were received from the Department of Public Service, the
State Office of Parks, Recreation and Historic Preservation (OPRHP), the New York
State Department of State, the NYSDEC and the U.S. Fish and Wildlife Service
(USFWS) (See Appendix A of the FEIS). The comments, or relevant portions of the
comments were grouped by subject matter and organized by the corresponding section in
the DEIS. Comments that were unrelated to the subject matter presented in the DEIS or
not relevant to potential environmental impacts were not included. The substantive
excerpts of the organized comments were consolidated. Similar or repetitive comments
were grouped together. The summarized comments and corresponding responses are
presented Section 3.0 of this FEIS Response to Comments. Written comments and the
public hearing transcript are provided in Appendix A.
1.10 Required Permits and Approvals
The list of permits and approvals presented in the Table 1.6-1 of the DEIS has been
revised to reflect project changes as well as updated to show progress made in preparing
and submitting permit applications.
It is anticipated that the permits and approvals identified in Table 1.10-1 below include
all the agencies and authorities having some level of review or approval authority over
the Project. The Project Sponsor will be filing applications for the remaining approvals
as additional engineering and design details are prepared for the Project.

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Table 1.10-1: Anticipated Permits and Approvals

AGENCY
Federal Aviation Administration
United States Army Corps of Engineers

United States Army Corps of Engineers


Advisory Council on Historic
Preservation
US Fish and Wildlife Service
New York State Department of
Environmental Conservation
New York State Department of
Environmental Conservation

New York State Department of


Environmental Conservation
New York State Department of
Environmental Conservation

New York State Department of


Environmental Conservation
New York State Department of
Environmental Conservation

New York State Department of


Environmental Conservation

New York State Department of


Environmental Conservation

PERMIT / APPROVAL
Notice of Construction or Alteration pursuant to
49 USC 44718
Joint Application for an Individual Permit
Section 404 and Article 10 for Alternation to
Wetlands pursuant to 33 USC 1251.
National Environmental Policy Act
determination pursuant to 42 USC 4321
Consultation under Section 106 of the National
Historic Preservation Act - The Council has
been advised of the Project.
Consultation under Section 7 of the Endangered
Species Act.
Findings for the State Environmental Quality
Review Act pursuant to 6 NYCRR Part 617
Joint Application for Water Quality
Certification pursuant to 33 USC 1341 - The
application was deemed complete on November
4, 2009.
Joint Application for Wetlands Permit pursuant
to ECL Article 24 - The application was
deemed complete on November 4, 2009.
Joint Application for Protection of Water
Permit pursuant to ECL Article 15 - The
application was deemed complete on November
4, 2009.
Mining Permit The application was deemed
complete on November 4, 2009.
SPDES General Permit No. GP-0-08-001 for
Stormwater Discharges from Construction
Activities, pursuant to ECL Article 17 - The
application was deemed complete on November
4, 2009.
SPDES Multi-Sector General Permit for
Stormwater Discharges Associated with
Industrial Activity GP-0-06-002 for the borrow
pit, slip, concrete batch plant, helicopter pad
and any exterior vehicle maintenance areas.
Review and approval of Stormwater Pollution
Prevention Plan pursuant to ECL Article 17

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New York State Department of


Environmental Conservation

New York State Department of


Environmental Conservation
New York State Department of
Environmental Conservation
New York State Department of State
New York State Department of Health
New York State Department of Health
New York State Office of General
Services
New York State Office of Parks,
Recreation and Historic Preservation,
State Historic Preservation Office
Public Service Commission

Town of Hounsfield Planning Board

Town of Hounsfield Town Board


Jefferson County Planning Board
Jefferson County IDA
Sackets Harbor Central School District

SPDES Permit for Discharge of Treated


Wastewater pursuant to ECL Article 17 - The
application was deemed complete on November
4, 2009.
State Air Facility Permit pursuant to 6 NYCRR
201.
Registration for Petroleum Bulk Storage
pursuant to 6 NYCRR Part 614
Consultation for Coastal Zone Consistency
Review pursuant to 16 USC 1451.
Review and approval of the potable water
treatment system
Ministerial approvals for transient housing,
infirmary, food service, sewage treatment plant.
Lease of underwater lands
Consultation required pursuant to Section 106 Consultation with SHPO as the State
Preservation Officer for Section 106 purposes is
ongoing.
Certificate of Public Convenience and
Necessity pursuant to Section 68 of the PSL and
determination under Article VII of the PSL
Site Plan Review pursuant to Hounsfield
Zoning law.
Building Permits pursuant to Hounsfield Town
law.
Decommissioning Bond
Zoning Referral and recommendation pursuant
to Gen. Mun. Law 239-m
Financing/leasing and PILOT Agreement Negotiations with JCIDA are ongoing.
Approval of PILOT Agreement

Potential Jurisdiction:
New York State Department of
Environmental Conservation

Incidental Take Permit pursuant to ECL Article


11

The Applicant has submitted an application to the Jefferson County Industrial


Development Agency (the JCIDA) requesting the JCIDAs assistance with the Project.
Pursuant to and in accordance with Article 18-A of the New York General Municipal
Law (the IDA Act), it is contemplated that the JCIDA will acquire title to, or a
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leasehold interest in, the Facility and lease the Facility back to Upstate. Upstate will
operate the Facility during the term of the lease. At the end of the lease term, Upstate
will purchase the Facility from the Agency, or if the Agency holds a leasehold interest,
the leasehold interest will be terminated. In connection with the foregoing, the JCIDA
contemplates that it will provide financial assistance (the Financial Assistance)
to Upstate in the form of (i) sales and use tax exemptions in connection with the
construction of the Facility; (ii) mortgage recording tax exemption(s) in furtherance of
one or more financings undertaken to construct the Facility; and (iii) upon undertaking
deviation procedures required pursuant to the Act and the Agencys Uniform Tax
Exemption Policy (UTEP), a partial real property tax abatement to be memorialized
within a certain Payment-in-Lieu-of Taxes Agreement (PILOT Agreement).
The foregoing contemplated actions of the JCIDA remain subject to JCIDA board
approval, which will follow the adopting of SEQRA Findings by the NYSDEC and the
receipt of consenting resolutions from each of the County of Jefferson, Town of
Hounsfield, and Sackets Harbor Central School District.
1.11 Project Consultation
Since the publication of the DEIS additional consultation with public agencies has
occurred. A record of additional consultations is provided in the attached table.
Agency
New York State Office of Parks,
Recreation and Historic Preservation
New York State Department of
Environmental Conservation
New York State Office of Parks,
Recreation and Historic Preservation
New York State Office of Parks,
Recreation and Historic Preservation
Town of Hounsfield
New York State Office of Parks,
Recreation and Historic Preservation

Date of Consultation
April 8, 2009
June 8, 2009
June 23, 2009
August 27, 2009
November 12, 2009
December 18, 2009

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1.12 Project Components that have Changed Since the DEIS


The Project components identified as part of the project description in Section 1.1 above
were described in detail in the DEIS, with the exception of the borrow pit, woody mulch
area, stormwater sediment basins and worker parking and staging areas. Since the
publication of the DEIS various project components have been clarified based on
response to public and agency comments, and design required for various permit
submissions. In particular, the water intake pipe and the on-island fuel storage have been
refined. Most significantly, in response to comments from the PSC and in order to
accommodate the PSCs policy regarding setbacks from project components, the project
sponsor redesigned the layout of the project components, particularly the WTG layout,
the substation location and the ECS layout. The revised layout complies with the PSC
policy regarding 1.5 times tip height setback for all above ground structures and resulted
in a 1.1 times tip height setback from underground transmission facilities. This section
details the items that have changed or been added as a result of public and agency
comment.
1.12.1 Borrow Pit
The temporary aggregate borrow pit is a new feature of the Project. The impacted area
will be approximately 2.1 acres, with an additional 3 acres of affected land for
processing, stockpiles, loading area and sediment basins.

Only the two acres are

considered a permanent impact, the sediment basin is a temporary impact and calculated
with the other sediment basins. Figure 1.1-1 shows the location of the borrow pit. The
maximum depth of extraction will be 24 feet. The material extracted from the pit will be
used for access road construction. A mining permit application has been submitted to
NYSDEC and was deemed complete on November 4, 2009.
Upon completion of wind farm construction activities, the borrow pit will be reclaimed
per a Mined Land Use and Mined Land Reclamation Plan. Reclamation will include
removal of gravel-paved surfaces, including the access road, the stockpile and loading
area and the pad for the rock crushing equipment. All areas disturbed by the borrow pit
operations, including the access road, pit, stockpile and loading area, spoil area, earth
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Final Environmental Impact Statement

dikes and sediment basin will then be top soiled and seeded. The construction of the
borrow pit will also be subject to the terms of a Stormwater Pollution Prevention Plan as
part of the SPDES General Permit GP-0-08-001. The operation of the mine will also
require coverage of a SWPPP under a SPDES General Permit for Stormwater Discharges
Associated with Industrial Activity GP-0-06-002.
1.12.2 Woody Mulch Area
An approximately 1 acre woody mulch area has been sited on the southern end of the
island, as shown of Figure 1.1-1. This mulch area is collocated with a staging and
laydown area on the southern end of the island. Woody debris will be generated by the
clearing and grubbing performed during the construction phase of the project. All of the
debris, including roots, will be chipped and disposed of in the woody mulch area. The
debris will be collected from the work areas and brought to the disposal area on a least a
weekly basis or more frequently. It will be stockpiled there to be chipped and spread
over the area within the following week. The chipped vegetation will be spread in a layer
no greater than four feet thick, in order to reduce the potential for self-combustion. The
chipped vegetation, may ultimately be used as a soil amendment or as mulch if it meets
the appropriate specifications. In the absence of such uses, the chipped vegetation will
remain in place and the area will be allowed to revegetate naturally. This area will only
be used during construction however, because it is a wooded site the impact is considered
permanent.
1.12.3 Sediment Basins
Various sediment basins have been located on Galloo Island. They will be used to allow
sediment to settle out of runoff water during construction. In total they will impact
approximately 6.38 acres temporarily. These basins are a component of the stormwater
pollution prevention plan for construction of the Project. They are located adjacent to
various areas of disturbance including the laydown areas and the gravel borrow pit.
Following construction all of the basins will be removed. As the sediment basins are
removed, the area of disturbance will be returned to pre-construction contours and
reseeded.
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1.12.4 Worker Parking and Staging Areas on the Mainland


During consultation with the Town of Hounsfield an additional project component was
identified. During the construction phase of the project, long term worker parking and
shuttling to Galloo Island will be required during construction. Also the project sponsor
will require local space to stage some small goods prior to sending to the island.
Upstate Power has tentatively identified three facilities on the mainland that will be used
for various purposes/times to transport staff and small cargo during construction and
operation of the project. The three facilities are identified as the Madison Barracks
facility in the Village of Sackets Harbor, the Former RCR Property in the Town of
Henderson, and the Point Peninsula Parcel in the Town of Lyme.
Madison Barracks
The Madison Barracks facility is approximately 16 miles from Galloo Island. This
facility will be used as the primary location for staff and visitors to report to where a crew
boat would deliver them to and from Galloo Island. There is adequate parking on the
Madison Barracks site, south of Brady Road. The use of the existing parking near the
marina and the additional parking south of Brady Road will not require the modification
of the existing parking areas and therefore, no additional improvements will be
completed at this location. Small equipment and other parcels could also be deployed to
Galloo Island from the Madison Barracks facility. In the event of a medical emergency,
this facility would likely be the designated location for delivery to the mainland to allow
for ambulance transportation to the closest hospitals in the Watertown, New York area. It
should be noted that Upstate Power will employ strict control over the location of
contractor and visitor parking to ensure all staff vehicles are parked in the designated lot.
RCR Properties
The Former RCR Property is located approximately 15 miles from Galloo Island and is
equipped with a landing craft and a small barge. This would be the primary location for
shipment of small to medium sized equipment and cargo. The need for parking will be
minimal as the site will be used as an alternate crew boat and small barge location to load
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Final Environmental Impact Statement

dry goods or small equipment for transport to the island. As such, the existing parking
and building are adequate for this use. The existing at-grade docking facility and small
craft boat launch will remain in use.
Point Peninsula Property
The Point Peninsula Property is located approximately 9 miles from Galloo Island. The
use of the facility has been identified as loading/offloading point for small equipment into
a shallow draft barge that can land at the location. The small equipment would be of the
size typically transported in standard over-the-road trucks, such as portable generators or
air compressors. Major equipment would ship directly from an existing regional port (i.e
Port of Oswego or Port of Ogdensburg) to the slip channel facility on Galloo Island.
The primary location for small equipment delivery will be the RCR Property location in
Henderson Harbor. However, the Point Peninsula location would be utilized if small
equipment is needed and Henderson Harbor is ice bound. As use of this property would
be limited and infrequent, no on site improvements will be required for its continued use
as a small craft docking facility.
1.13 Clarifications of Project Components
1.13.1 Water Intake Pipe
Since the publication of the DEIS the design of the underwater water intake pipe was
reviewed in more detail, in particular in response to comments from the USFWS. The
water intake pipe consists of approximately 575 linear ft of 18-inch diameter ductile iron
pipe. Utilizing a design lake elevation of 243.3 ft (low water conditions), the pipe will be
buried in an excavated trench approximately three ft below lake bottom until it reaches a
water depth of 15 ft. Beyond this point the pipe can lay on the lake bottom. Optionally, if
determined necessary during installation, the exposed section of pipe will be mounded
with approximately three ft of rock fill.
At the inlet location, the pipe will be buried and terminated at a 6 ft diameter precast
concrete pipe section set vertically. The top of the precast section will be set at the 30-ft
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Hounsfield Wind Farm


Final Environmental Impact Statement

intake depth (Elevation 213.0 ft). An intake screen cap will be attached to the top of the
precast section to prevent debris, fish, and other organisms from entering the intake. The
cap will consist of a barrack frame which will support a finer screen with 2 mm
maximum openings. Currently, the selected material for the bar-rack frame is a
Hydrothane trash rack as manufactured by Hydrothane Systems. This is a non-metallic
material with durability, good flow characteristics, and proven resistance to frazil ice
development and marine growth (particularly zebra mussels).
The material for the finer screen will likely be an alloy material, chosen to minimize
corrosion and biological fouling. It will either be of woven mesh or wedge wire
construction. The proposed configuration will limit through-screen velocity for combined
fire protection and potable water maximum flows, to less than 0.5 fps. A chemical feed
line will likely also be routed inside the intake pipe and terminated within the intake
structure. This would allow for periodic treatment/removal of biological growth, should it
become a problem.
1.13.2 On Island Fuel Storage
To address comments received on the DEIS additional detail has been developed
regarding on-island fuel storage. The Project Sponsor will be applying for a Petroleum
Bulk Storage Registration from the DEC prior to construction.

The refined design

identified the following above ground storage tanks (AST) for use during construction on
Galloo Island.
Vehicle fueling island: 10,000-gallon diesel AST and a 6,000-gallon gasoline AST
Diesel Fuel Storage for Power Generation and Heating Systems: three 10,000-gallon
diesel ASTs
Slip fueling island: 8,000-gallon diesel AST and 2,000-gallon gasoline AST
Community Building Kitchen Stoves and Laundry: 20,000-gallon propane AST
Temporary Concrete Batch Plan: 550-gallon diesel AST
Helipad: 550-gallon diesel AST
Following Project construction the 550-gallon AST for the concrete batch plant would be
removed and two of the 10,000 gallon diesel ASTs for power generation would be

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Final Environmental Impact Statement

removed. The design and operation of the ASTs is described in the SPCC included as
Appendix B of this FEIS.
1.13.3 Project Design
The layout of the WTG, ECS and substation has been revised since the completion of the
DEIS in response to, among others, comments received from the DPS regarding the
setback of WTGs from other project components. The result of the layout changes has
been to further avoid or minimize impacts to the natural environment.
The revised layout of wind farm and support facilities is depicted in Figure 1.1-1. Project Layout. Specifically, the following changes have been made:
The substation has been moved to a location in the eastern end of the island, in the
area that is currently agricultural fields. This is being relocated from a forested
area.
WTG 1 and associated improvements have been relocated from NYS owned land
and placed on property owned by Galloo Island Corporation.
WTG 3 has been relocated to avoid a potential archeologically significant area.
4 WTGs have been shifted to be at least 1.5 tip height setback from any
aboveground transmission line components or the substation.
2 WTGs was shifted to allow for a 1.5 tip height setback from the back-up power
generation facilities.
22,000 linear feet of ECS were relocated to collocate with roads. This reduced
impacts to forested areas by 6,780.9 linear feet and 12.78 acres
Roads and laydown areas were adjusted to correspond with the new WTG layout.
Minor adjustments were made to the footprint of the temporary off-loading facility
to avoid a potential archeologically significant location.
Figure 1.1-2 Revisions to Project Layout displays the new layout over the layout
described in the DEIS. The benefits and impacts of this revised layout are described in
Section 2.0 of this FEIS.

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Final Environmental Impact Statement

2.0 Resource Characterization, Impact Assessment and Mitigation.


2.1

Topography, Geology and Soils

Characterization
The characterization of the topography, geology and soil of Galloo Island presented in the
DEIS is still valid. Therefore, no changes are required.
Impacts
Due to Project refinements there are two project components not discussed in detail in the
DEIS that will affect the topography of the Project Area, the borrow pit and the sediment
basins.
The borrow pit will be constructed on the northern end of the island proximate to WTG
71.

The area will be blasted to allow for the extraction of material to use in the

construction of the roads. The impacted area will be approximately 2.1 acres, with an
additional 3 acres of affected land for processing, stockpiles, loading area and sediment
basin. Figure 1.1-1 shows the location of the borrow pit. The maximum depth of
extraction will be 24 feet. This will change the topography of the area of extraction. A
NYSDEC mining permit application has been submitted with NYSDEC for this action.
Various (six) sediment basins have been located on Galloo Island. They will be used to
allow sediment to settle out of runoff water during construction and operation. In total
they will impact approximately 6.38 acres temporarily. These basins are a component of
the stormwater pollution prevention plan for construction of the Project. They are located
adjacent to various areas of disturbance including the woody mulch area, laydown areas
and the gravel borrow pit. Following construction all of the basins will be removed,. As
the sediment basins are removed, the area of disturbance will be returned to preconstruction contours and reseeded.
No significant impacts to the geology or soil of the island are anticipated.

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Final Environmental Impact Statement

Mitigation
To mitigate the potential impacts, the borrow pit will be reclaimed per a Mined Land Use
and Mined Land Reclamation Plan (Appendix C) at the end of construction. Specifically,
the area will be graded and seeded.

However, this will not return the area to

preconstruction contours and the area is therefore considered a permanent impact.


No mitigation is required for the minor topography changes from the borrow pit.
2.2

Land and Land Use

Characterization
The DEIS characterization of Galloo Island did not include two designations for the
Island. The properties owned by New York State along the southern tip of the island as
well as the area surrounding the former Coast Guard Station are designated State Wildlife
Management Areas. Currently, the areas are not actively managed by any state entity.
However, a Management Plan for the Lake Ontario Islands Wildlife Management Areas,
developed by DEC Region 6 Fish and Wildlife staff in 2002, states that limited habitat
management actions are being considered for the lighthouse and Coast Guard sites on
Galloo Island. On these sites, establishment of perennial wildlife food and cover will be
considered along with minor clearing and dressing to accommodate wildlife related use.
Additionally, Galloo Island is mentioned in both the 2006 and 2009 versions of the New
York Open Space Plan, in the Region 6, 7, 8 & 9 Priority Projects, Great Lakes Shoreline
and Niagara River. The 2009 Plan states Galloo Island, the largest undeveloped island
in Lake Ontario measuring approximately 3 miles by 1 mile or 1,934 acres is just
one of the undeveloped islands worthy of attention in its current undeveloped condition.
Impact
The designation of part of the island as a wildlife management area and the entire island
as part of the NYS Open Space Plan does not change the impact analysis provided in the
DEIS.

Nonetheless, DEC would need to take into consideration the construction,

operation, maintenance, and possible decommissioning of a commercial enterprise in any

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Final Environmental Impact Statement

future revisions to the DEC Region 6 Fish and Wildlife Lake Ontario Islands Wildlife
Management Area Management Plan (2002).
The layout of the WTG and associated improvements has changed since the publication
of the DEIS (See Section 1.11). The revised impact calculations are provided below.
Table 2.2-1: Total Acreage of Permanent Impacts from Project

PROJECT FEATURES
WTGs (includes pedestal and crane pad)
Service Roads
ECS Underground (cleared)
ECS Aboveground (cleared)
Laydown Areas
Woody Mulch Area
On-island Substation
Gravel Borrow Pit
Slip Facilities Permanent
O&M Buildings, Residential and Support
Facilities
Helicopter Pad and Garage
Wetlands Mitigation Area

AREA
(Acres)
16.982
95.989
10.181
8.515
9.417
1.01
1.241
2.060
8.135
4.305

Change from
DEIS
-1.678
+2.349
+1.9621
-14.945
-0.373
+1.01
-0.139
+2.060
+6.375
+0.045

0.193
0.558

-0.217
+0.288

Total

158.586

-3.18

Table 2.2-2: Total Acreage of Temporary Impacts from Project

Project Features

Area (Acres)

Staging Area
Laydown Areas
Concrete Batch Plant
Underground ECS
Overhead ECSs
Sediment Basin

37.64
93.23
2.32
1.51
0.0
6.38
Total

Change from
DEIS
-10.27
-8.24
-0.27
+0.94
-1.63
+6.38
141.081
-13.089

The new layout reduces impacts to the amount of total land of the island occupied as
compared to the layout in the DEIS.
Mitigation
In response to public comments regarding former use of the island, the project sponsor
agreed to allow safe harbor for boats during severe weather events. Boats would be

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Final Environmental Impact Statement

allowed to access both the North Pond area and Gill Harbor if there is a need for refuge
during a severe weather event.
The project sponsor also agreed to allow local fishing guides to use the portion of the
island adjacent to North Pond for fish bakes. This practice has been occurring for a
number of years and will be allowed to continue. However, as is currently the case, the
guides and guests will not be allowed to access the rest of the island and will be
responsible for providing their own equipment and removing it.
Because the change to land coverage since the DEIS is a minor decrease in the acres that
will be impacted by the project, no additional mitigation is required.
2.3

Agricultural Resources

Since the publication of the DEIS the impact to agricultural land has increased from
13.96 to 15.15 acres due to the relocation of the substation from forested to agricultural
land. However, since all agricultural activity will cease on the island there is no change
to the impact to the resource and therefore no additional mitigation is required.
2.4
2.4.1

Water Resources
Surface Water

Characterization
Since publication of the DEIS nothing has altered the characterization of surface water on
or adjacent to Galloo Island.
Impact
Nothing associated with the revised layout or project components results in changes the
potential impacts to surface water as presented in the DEIS.
Mitigation
New components of the project include the sediment basins that will be used during
construction. These will help to protect surface water quality by retaining runoff that

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Final Environmental Impact Statement

may have suspended sediment, and allowing the sediment to settle out prior to being
discharged to surface water.
A Conceptual Blasting Plan for Construction of the Galloo Island Offloading Facility has
been developed and included as Appendix D of this FEIS. During in-water construction,
turbidity controls will be utilized. These controls will consist of a floating turbidity
barrier in Lake Ontario that will surround the exaction area in the lake. The barrier
consists of a heavy duty mono-filament filter fabric tensioned, ballasted, and secured with
a series of heavy, galvanized steel tension cables, ballast chains, and anchor chains. This
system will help reduce any impacts from turbidity and also help, to some extent, to keep
fish from the blasting area.
2.4.2

Sediment

The project changes and public comments did not change the characterization or analysis
of impacts and mitigations for sediment. Therefore, no changes are required to this
section.
2.4.3

Wetlands

Characterization
Since the publication of the DEIS, the USACE has issued a preliminary jurisdictional
determination for the island. The Project Sponsor and USACE have agreed to find all
wetlands on the island as jurisdictional. This is the only change to the characterization of
the wetlands.
Impact
Since the publication of the DEIS, additional opportunities for avoidance and
minimization of impacts to wetlands were identified by the Project Sponsor. These
measures have reduced the amount of wetland impacts and the number of wetlands that
will be impacted.

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Final Environmental Impact Statement

The Project will have impacts on New York State regulated wetlands and wetland
buffers. These wetlands consist of a Class 3 Palustrine Emergent wetland (PEM), two
Class 3 Palustrine forested wetlands (PFO), and two Class 2 PEM wetlands. Wetlands A
(PEM and PFO), F (PEM), J (PFO), and Q (PEM) are regulated by the NYSDEC under
Article 24 of ECL.
Approximately 0.633 acres of State regulated wetland and buffer zone will be crossed by
overhead ECS with no vegetation removal. This figure is based on crossing length times
a 50-foot wide corridor.
Approximately 0.116 acres of state regulated wetland and stream will be affected by cut
and fill activities for access roads and culverts. The impacted areas are wetland A and
Stream A. The cut and fill impacts to be restored include 0.06 acres as follows:
0.024 acres in Wetland A/Stream A
0.029 acres in Wetland A converted to PEM
0.007 acres underground ECS in Wetland Q (PEM, Class 2) to be restored.
The ECS will affect 0.014 acres of state regulated wetland (Wetland A, PFO, Class 3).
This 0.014 acre area will be converted from forested to emergent wetland.
Cut and fill activities will affect 0.777 acres of wetland buffer zone in wetlands A/Stream
A, Wetland J (PFO) , and Wetland Q (PEM). Vegetation removal in buffer zones will
affect 1.048 acres.
In total 0.19 acres of State regulated wetland (including Stream A) and 1.825 acres of
adjacent areas will be affected by the construction activities on the island. This is
specifically a loss of 0.116 acres of wetlands, the conversion of 0.014 acres of wetlands
from one habitat type to another, 0.06 acres of temporary wetland impacts and 1.825
acres of impacts to wetland buffers. An additional 0.633 acres of wetlands will be
crossed without vegetation removal.
This is a reduction of the 0.6 acres of wetland fill and habitat change and 3.857 acres of
impact to wetland buffers proposed in the DEIS.

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Mitigation
In-kind mitigation is proposed for the wetland impacts. The amount of this mitigation
has changed since the DEIS. The location of the wetland mitigation area has not changed
and is shown on Figure 1.1-1 and the conceptual mitigation plan is included in Appendix
E.
In an effort to offset impacts to forested NYSDEC regulated wetland buffer, upland trees
will be planted immediately upgradient of the wetland creation site in an effort to
eventually provide a forested wetland buffer. The upland tree plantings will also serve to
enhance and restore the upland area surrounding the wetland creation site, this will total
approximately 2.26 acres. Approximately, 0.163 acres of emergent wetland and 0.395
acres of deciduous forested wetland creation are proposed to offset 0.19 acres of
permanent wetland impacts.
2.4.4

Groundwater

The project changes will not alter the analysis of impacts and mitigations for
groundwater. Therefore, no changes are required to this section.
2.5
2.5.1

Wildlife and Habitat


Flora and Fauna

Characterization
Since publication of the DEIS nothing has altered in the characterization of flora and
fauna on Galloo Island.
Impact
Following the publication of the DEIS a number of public and agency comments were
received related to the design of the ECS and the number of areas where it was not
collocated with roads. Comments were also received related to the location of the
substation in a forest habitat.

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The project sponsor revaluated the ECS and determined that there were a number of areas
where the ECS could be relocated to be collocated adjacent to the roads. There were also
a number of locations where it was possible to move the ECS out of forested areas to
open field locations. This reduced the overall impact because impacts to open fields will
only be where the poles are located as opposed to clearing a corridor through a forested
area. These changes reduced the overall impact from ECS from 31.68 acres to 18.70
acres. In particular, this change reduced impacts to forested areas by 12.78 acres.
Moving the ECS also reduced the fragmentation of forested areas by consolidating the
disturbances and moving them from the center of some ecological areas to the edges.
This reduction of fragmentation is another benefit of the revised layout.
Based on a number of concerns from agencies, in particular regarding maintaining a 1.5
tip height separation between towers and transmission structures as well as impacts to
forested areas that could be avoided, the substation was moved to a location on the
northern portion of the island in the agricultural field. This reduced impacts to forested
areas by 1.38 acres, however the new location of the substation and other project changes
results in an additional 1.19 acres of impact to potential grassland habitat that would
result from the reversion of agricultural land once it is no longer actively farmed.
The new location of the substation is on the edge of the northern grassland area in a
location that has been farmed. This site was not a nesting site as documented in the 2008
and 2009 Breeding Bird Studies and was not heavily utilized by winter raptors as
documented by the 2007-2008 and 2008-2009 Wintering Bird Studies. Other locations
that were evaluated for the substation site, such as adjacent to WTG 74, would have
required clearing danger trees from around the site and would have converted forested
areas to open field. The revised location also allowed the Project Sponsor to reduce the
length of the transmission line on the island.
In total the revised project design has the following impacts on habitat. The impacts have
been balanced among the habitat types on the island.

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Table 2.5-1 Permanent Impacts to Habitat

Total Acres

Agricultural Land

163.55

15.152

Percentage of
Acres Impacted
9.3%

Forested

613.05

66.477

10.8%

Developed

29.21

4.758

16.3%

Open Field

782.79

71.98

9.2%

Rock Shoreline

29.79

0.030

0.1%

Wetlands

349.93

0.19

0.1%

Ecological Area

Total

1968

Acres of Impact

158.586

8.1%

Mitigation
During the time since the publication of the DEIS the project sponsor has identified
several offset mitigations that would be appropriate for Galloo Island. In particular the
following mitigation strategies have been identified: pale swallow-wort control and a
mowing protocol in open areas and forest under-story beyond the project construction
footprint, to mitigate for the permanent loss of grassland habitat that would occur due to
development of the project. Within the construction footprint for the project, these
activities will be included in the construction specifications as Best Management
Practices.
The Pale Swallow-wort Control Plan is included as Appendix F of this FEIS. The plan
outlines the control methods that will be undertaken by the project sponsor during the
construction and operation of the wind farm. Generally, the goal of the plan is to reduce
the areal coverage of pale swallow-wort in open areas and forest under-story by 20% per
year each year for five years through the application of pesticides.

The plan also

identifies specific steps to limit the spread of pale swallow-wort and other invasive
species off of Galloo Island. This includes the sanitation of vehicles and worker boots
prior to leaving the island. By removing areas of pale swallow-wort and seeding with
appropriate vegetation the project will make more potential habitat areas available for

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mammal and avian that use open areas. The control of this invasive species will be a net
benefit to the environment from the project.
Another offset mitigation measure is the development and implementation of a mowing
protocol. In order to ensure that areas that are currently open space do not convert to
scrub shrub or forested areas the project sponsor will mow areas currently designated as
open field every three years. This will be done either before or after breeding bird
season. This will ensure open field areas are available to avian and other species that use
open field for breeding, feeding or nesting.
2.5.2

Rare, Threatened and Endangered Species

Characterization
An initial ecological survey conducted in July 2008 on Galloo Island found suitable
habitat for, but not the presence of, Blandings turtle. Wetlands F and Q were found to
provide suitable habitat for the turtle. Blandings turtle is listed by New York State as a
Threatened species and is also being considered for protection under the Federal
Endangered Species Act of 1973. NYSDEC requested additional field studies to assess
the potential occurrence and habitat use on Galloo Island by this species.
Stantec Consulting conducted this additional study using the Nesting Activity Survey
Protocol for Blandings Turtle (Emydoidea blandingii) provided by the NYSDEC. The
survey was conducted between June 6 and June 28, 2009. The survey included a
minimum of 300 trap nights in Wetlands F and Q. A copy of the survey report is provided
as Appendix G of the FEIS.
Blandings turtle nesting surveys were conducted with the following potential habitats
within 1000 meters of Wetland F: lakeshore, dirt roads, hayfield/agricultural land, and
maintained grassland/field. No observations of Blandings turtle nesting or conducting
overland movements to nest were observed. Since many of the soils around wetland F are
silts or clay, shallow, and rocky, nesting habitat suitability is considered to be relatively
low. No Blandings turtles were trapped within Wetland F.

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Nesting habitat around Wetland Q was also assessed. Surveys were conducted within the
following potential nesting areas within 1,000 meters of the wetland: lakeshore, dirt road,
and maintained grassland/field. Similar to Wetland F, no observations of Blandings
turtle nesting or conducting overland movements to nest were observed during the
survey. Wetland Q has even less of an extent and availability of surrounding potential
nesting habitat than Wetland F. Most of the habitat in the surveyed area was dense
maintained grassland/field, woodland, or wetland. Soils around Wetland Q at potential
nesting sites are of shallow to very shallow depth dominated by silts and clays. These are
of relatively low suitability for nesting. No Blandings turtles were trapped within
Wetland Q.
During the 21 nights of nesting surveys on Galloo Island in 2009, no Blandings turtles
were observed nesting nor were any individuals captured in traps. Based on the results of
nest surveys and trapping efforts, it seems unlikely that Blandings turtles currently
occupy Galloo Island.
Impact
No additional evaluation of impacts is required from the additional data, project changes
or public comments.
Mitigation
Since it is not likely that Blandings turtles occupy Galloo Island, no mitigation for this
species is required.
2.5.3

Avian Species

Characterization
Based on the findings of the 2008 bird studies conducted on Galloo Island the NYSDEC
asked the project sponsor to undertake some additional field work to supplement the base
of knowledge for the project. In particular additional field work was requested for the
wintering bird, diurnal and breeding bird information.

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2008-2009 Winter Bird Survey


This was a second baseline winter avian survey, primarily for raptors, conducted by Old
Bird, Inc., from November 12, 2008 through March 12, 2009. It follows a similar study
conducted on Galloo Island the previous winter. Diurnal and crepuscular visual surveys
for birds were attempted every 10-14 days. Information on whether the birds were
perched or in flight, their location, flight height and direction was recorded. This survey
is attached to the FEIS as Appendix H. The primary focus was on counting wintering
raptors but rough visual counts of waterfowl and documentation of landbirds were
included.
Similar to the previous years survey, most raptors observed were perched in trees along
the perimeter route. Small numbers of Rough-legged hawks were regularly noted flying
northeasterly or south westerly down the grassland corridor on the eastern side of the
island. They were typically at 50 meters above ground level or less. They were not
observed in the wooded interior of the island.

Red-tailed Hawks had a similar

distribution and behavior on the island as Rough-legged hawks but their numbers were
lower. Both of these species were found in lower numbers than observed in the previous
year survey.
Bald Eagles were also found in lower numbers than observed in the winter of 2007-2008.
A high daily count of three individuals was noted in 2008-2009 but at least five different
individual birds were noted. The winter 2008-2009 winter survey found high daily
counts of one American Kestrel, two Coopers Hawks, and two Northern Harriers. Two
Snowy Owls were observed. No Short-eared Owls were noted. Similar to 2007-2008,
Northern Raven and Northern Shrike were seen in small numbers throughout this survey.
Numbers of waterfowl were significantly lower during this survey than the 2007-2008
survey but the general species pattern seemed to be similar. Mallards and Black Ducks
comprised the majority of waterfowl in early winter with a transition to Aythya (a genus
of diving ducks) species, Goldeneye, and Long-tailed Duck as winter progressed. Most
waterfowl flight activity was over the water along the eastern end of the island. Very few

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were observed in transit over the island. Very few small passerine birds were documented
during the winter of 2008-2009. The only notable addition from 2007-2008 was the
White-winged Crossbill.
Overall, the second winter bird survey (2008-2009) supports the conclusion reached in
the 2007-2008 report that Galloo Island is involved with the winter raptor concentration
phenomenon that periodically occurs in the grasslands proximal to northeastern Lake
Ontario. As such, it supports the idea that the winter concentration of raptors on Galloo
Island has considerable variance from year to year. The surveys seem to indicate that the
New York State listed species, Northern Harrier and Short-eared Owl, are documented in
lower ratios than other nearby regions. There also appears to be significant annual
variation in winter season waterfowl numbers on Galloo Island.

Landbirds were

relatively scarce in both winter surveys.


2009 Breeding Bird Survey
This is a second breeding bird survey conducted on Galloo Island by Old Bird, Inc. over
six two-day periods from late May through mid-August of 2009. The survey was
specifically requested by the NYSDEC to focus on New York State (NYS) listed
grassland breeding bird species and was conducted using NYSDEC Region 6 Grassland
Survey Protocol. It follows a similar extensive breeding bird survey that was conducted
during spring and summer of 2008. A secondary purpose of the 2009 survey was to
conduct a second round of point counts at all proposed WTG sites to confirm species
abundance and distribution patterns documented in the 2008 survey. The survey included
breeding bird point count surveys, walking transects, and stationary observations. The
2009 breeding bird survey is attached to the FEIS as Appendix H.
No federally listed bird species were documented in the 2009 survey and no NYS listed
grassland birds were documented in 2009 except for those also noted in 2008, namely,
Northern Harrier and Upland Sandpiper. While there is potential breeding habitat on
Galloo Island for other listed grassland species (Short-eared Owl, Horned Lark, Sedge
Wren, Vesper Sparrow, Henslows Sparrow and Grasshopper Sparrow), the extensive
2009 survey did not find evidence of these other species. Other NYS listed species
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detected in the 2009 survey included the Pied-billed Grebe (Threatened), the Bald Eagle
(Threatened), the Common Loon (Special Concern), the American Bittern (Special
Concern) and the Coopers Hawk (Special Concern).
The additional bird surveys in 2009 produced evidence that Upland Sandpiper were
involved in breeding activity on Galloo Island. It was also noted that Northern Harriers
possibly nested on the island, but a location was not evident, however Northern Harriers
were documented foraging in the northern & southern grassland areas. Upland Sandpiper
activity consistent with nesting was observed in a native grassland area in the vicinity of
WTGs #2 and 3. In regard to other breeding birds, the 2009 survey indicated that most
species showed very similar patterns of abundance from 2008 to 2009. The number of
points where species were documented was again highest for Song Sparrow, House
Wren, Yellow Warbler, American Robin, Baltimore Oriole, and Eastern Kingbird.
Eurasian Starling and Red-winged Blackbird were not included in the list comparing
2008 and 2009 since these species had fledged young and had begun flocking by late
June.
2009 Diurnal Bird Movement Study
This was the second baseline diurnal bird movement study conducted on Galloo Island by
Old Bird, Inc. Eight diurnal bird movement surveys were undertaken on seven days from
late May through early July. The study, at the request of the NYSDEC, was conducted at
different regions of the island than had been reported in the 2008 survey, namely at the
northwest side of the island. The sampling protocol used for the 2009 survey was similar
to that used in the 2008 survey. The goal of the 2009 study was to assess avian flight
activity and flight characteristics including altitude and direction. Particular attention was
given to flight activity of Little Galloo Island colonial waterbirds (gulls, Double-Crested
Cormorant and Caspian Tern). The additional data provided by the 2009 Diurnal Bird
Movement Study showed passage rates over Galloo Island for Caspian Terns, Ring-billed
Gulls and Double-crested Cormorants as peaking in early June through early July. Five
additional survey points along the western side of the island were added and additional

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data gathered in 2008 from these five points was included in the 2009 report. The 2009
Diurnal Bird Movement Study is attached to the FEIS as Appendix H.
In addition to the diurnal movement surveys carried out in the breeding season that
targeted gull, cormorant, and Caspian Tern movements, a survey was conducted on the
morning of September 20, 2009 to observe diurnal morning flight of migrant passerines.
The data from the 2009 study confirms the avian flight patterns documented in the 2008
survey and supports the idea that these are annual patterns. This includes the passage
rates, flight altitudes, and temporal activity patterns of gulls, cormorants, and terns that
nest on nearby Little Galloo Island.
Impacts
The additional year of studies generally supported the findings of the DEIS and
supporting studies. Results of the 2009 Breeding Bird Survey indicate that the proposed
project layout has the potential to result in approximately 1.03 acres of permanent impact
to the grassland area of the approximately 34 acre area where Upland Sandpipers were
observed particularly in the area of proposed Turbine # 3, which is in close proximity to
the suspected Upland Sandpiper nesting area. This is a reduction from the original layout
that was proposed of 2.91 acres of impact to this area. Some of the roads and ECS were
relocated to avoid the area identified as sensitive habitat for Upland Sandpipers. The
presence of proposed project elements, particularly tall turbine structures, may result in
future avoidance of this nesting habitat by grassland bird species. Because the
understanding of avoidance behavior on the part of these species is incomplete at this
time, this potential will be confirmed through post-construction monitoring.
Data obtained during the 2009 Diurnal Bird Movement Study showing passage rates over
Galloo Island for Caspian Terns, Ring-billed Gulls and Double-crested Cormorants
peaking in early June through early July indicates that blade-strike mortality for these
species would be most likely during this time period. Because the understanding of such
impacts is incomplete at this time, these species will be included in the post-construction
monitoring plan described in Appendix I.
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Mitigation
Evidence of breeding activity by Upland Sandpiper and Northern Harriers, both statelisted threatened species, in the native grassland area in the vicinity of proposed WTG #1,
WTG #2, WTG #3, WTG #4, WTG #7 and WTG# 8, as shown on Figure 2.5.3-1 has
resulted in a DEC determination that the prisject sponsor must obtain a permit under
Article 11 of the Environmental Conservation Law (ECL) to address potential impacts of
the project to state-listed threatened and endangered species. The Article 11 process will
utilize data provided in studies prepared for the DEIS and FEIS to ensure that the Project
complies with ECL requirements. The Article 11 process may require additional
avoidance and minimization measurers, including re-location or removal of project
components such as turbines, access roads, ECS and other proposed areas of disturbance,
and

mitigation

for

residual

impacts,

including

long-term

management/improvement/protection of Upland Sandpiper habitat on the mainland, and


operational controls during the breeding seasons for Upland Sandpiper, Northern Harrier,
or other listed species, if these species are confirmed as utilizing this habitat following
construction of the project..
As noted above, to address concerns related to the potential for blade-impact mortality to
migrants such as Caspian Terns, Ring-billed Gulls and Double-crested Cormorants, these
species will be included in the post-construction studies. As with the other species subject
to these studies, if post-construction impacts are identified, DEC reserves the right to
require adaptive management strategies to avoid or minimize such impacts.
The introduction of red fox to Galloo Island is no longer proposed as a project mitigation.
New mitigations that were identified are pale swallow-wort control and a mowing
protocol in open areas and forest understory areas beyond the project development
footprint. These are discussed in Section 2.5.1 above. The goal of these mitigations is to
increase or maintain the habitat quality of open fields to offset loses of grassland habitat
associated with various components.
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2.5.4

Bats

The project changes will not alter the characterization or analysis of impacts and
mitigations for Bats. Therefore, no changes are required to this section.
2.5.5

Post-Construction Monitoring Plan

Since the publication of the DEIS a revised Post-Construction Monitoring Plan has been
proposed. The plan adheres to the Standard Post-construction Studies guidance as stated
in the Guidelines for Conducting Bird and Bat Studies at Commercial Wind Energy
Projects published by the NYSDEC dated August 2009. This is included as Appendix I
of this FEIS.
2.5.6

Fish and Aquatic Species

Characterization
Since the publication of the DEIS no new characterization of fish an aquatic species is
necessary.
Impacts
No new impacts to fish and other aquatic species were identified since the publication of
the DEIS. As a condition of DEC permits, an Aquatic Survey in conjunction with a
Detailed Geotechnical Investigation will be performed prior to the proposed blasting for
the construction of the Offloading Facility. These surveys/investigations will gather
important baseline data as to the current condition (prior to blasting or construction) and
this data will be needed by the Aquatic Ecologist performing the monitoring of the
blasting and excavation as well as by the Blaster In Charge in designing the Detailed
Blasting Plan.
Mitigation
The DEIS described measures that would be used during construction of in-water
structures and during excavation and blasting to minimize the impact on aquatic
organisms, especially fish. These included the fact that the selected site for offloading

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facilities was the site requiring the least amount of excavation, use of clean fill granular
fill materials, keeping filled areas to the minimum size needed, and timing of work and
blasting to reduce effects on fish spawning. Mitigation also included the development of
blasting plan to use techniques that reduce the effects of blasts on fish species, such as
charge size, use of granular stemming materials and timing of the blasts. A Conceptual
Blasting Plan for Construction of the Galloo Island Offloading Facility has been
developed and included as Appendix D of this FEIS. This plan has an exclusion zone
beyond which impacts to aquatic organisms will be minimal.
Since publication of the DEIS, some additional Best Management Practices have been
incorporated into the project features and construction techniques to minimize potential
adverse environmental impacts. To reduce impacts of in-water blasts on fish the
following measures will also be included as mitigation:
Continued excavation activities will be scheduled once water-borne rock excavation
begins. The noise of equipment, besides the blasting, on a continual basis will
keep passing fish at greater distances and reduce likelihood of spawning in the
vicinity.
Only daylight shots will be allowed.
Use of detonation cords will be limited.
A 25-millisecond (ms) delay interval be adhered between decks of the same hole
and large separations of holes with sequential separations of 9 ms or greater.
Sequential timing intervals of less than 9 ms will be avoided.
Retain detailed drilling records and require the contractor and initial blasting plan to
conform to all mitigation measures.
During in-water construction, turbidity controls will be utilized. These controls will
consist of a floating turbidity barrier in Lake Ontario that will surround the exaction area
in the lake. The barrier consists of a heavy duty mono-filament filter fabric tensioned,
ballasted, and secured with a series of heavy, galvanized steel tension cables, ballast
chains, and anchor chains. This system will help reduce any impacts from turbidity and
also help, to some extent, to keep fish from the blasting area.
In order to reduce entrainment and impingement of aquatic species (particularly fish) at
the intake head, the water intake structure is being placed at a depth of 30 feet and the
maximum intake velocity will be kept below 0.5 feet per second.
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2.6

Visual Resources

Characterization
In addition to the visual resource assessment provided in the DEIS, additional simulations
and assessment were conducted and included herein to respond to comments. Comments
were received regarding the potential visual impact of the project on state properties and
designated areas. In particular, concerns were raised regarding nighttime and daytime
impacts at Robert G. Wehle State Park, Westcott Beach State Park, Southwick Beach
State Park and the Sackets Harbor Battlefield State Historic Site. Additionally, the
project will be visible from the historic Madison Barracks complex in the Village of
Sackets Harbor. There was also a comment regarding whether or not the turbines could
be painted a blue-gray color, and whether that would reduce the potential visual impact.
Also, a comment was received regarding the potential visual impact to the area of Galloo
Island adjacent to the State Wildlife Management area that has a white shell beach. A
photo of this location was provided by the PSC and is titled Site 19 (see Appendix J).
Impacts
Given the location of Galloo Island wind farm, all coastal vantage points will view the
project from far background distance (5.6 miles and greater) Turbine structures will
decrease in visibility, clarity and perceived importance with increasing distance up and
down the coast. Generally, the viewshed analysis demonstrates that views of the Project
will be substantially limited to shoreline locations. Nonetheless, this project will result in
a change to the visual setting on the horizon from vantage points along the Lake Ontario
shore, including scenic and historic resources of statewide significance identified above.
As noted in the DEIS, the NYSDEC Visual Policy states, Aesthetic impact occurs when
there is a detrimental effect on the perceived beauty of a place or structure. Significant
aesthetic impacts are those that may cause a diminishment of the public enjoyment and
appreciation of an inventoried resource, or one that impairs the character or quality of
such a place. Proposed large facilities by themselves should not be a trigger for a
declaration of significance. Instead, a project by virtue of its siting in visual proximity to

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an inventoried resource may lead staff to conclude that there may be a significant
impact. (DEC Visual Policy, 2000)
The State Office of Parks Recreation and Historic Preservation identified concerns
regarding impacts on six parks Wehle State Park, Chaumont Boat Launch, Westcott
Beach, Sackets Harbor Battlefield, Stony Creek Boat Launch, and Southwick Beach.
These are located generally within the coastal areas, and potential views can be
categorized as far background distance. Of the six park locations identified, only five
were identified as having potential views of the wind farm (Stony Creek was not
identified in the viewshed analysis). One of the locations identified is a boat launch and
two others are beach locations. As noted in the DEC Visual Policy, simple visibility does
not result in a detrimental effect on the perceived beauty of the place.

Moreover,

significant visual impacts are only those that cause a diminishment of the public
enjoyment and appreciation of the identified resource or one that impairs the character or
quality of such a place. In addition, the static, clear day views of the WTG in the VRA
are likely a worst case analysis in that they focus the viewers attention on a single
depiction of the array under the most favorable atmospheric conditions for viewing.
They do not account for the distractions and ameliorating effects of less favorable
atmospheric viewing conditions, which are the predominant case in this region. In
addition, the simulated views do not account for the fact that in a real world kinetic
view there are numerous other distractions that will reduce/ameliorate impacts, including
movement of other landscape features including waves, trees, sailboats, cars etc. the
viewer him/herself, which will compete for the viewers attention and thereby further
reduce any potential impacts of the distant, background views of the WTG. In any event,
it is not anticipated that distant views to the wind farm will impair the use of these beach
or boat launch facilities as the use of these facilities is tied to recreational activities rather
than scenic vantage or viewpoints.
Regarding potential impacts to Wehle State Park, the visual analysis conducted by the
Project Sponsor identified that the wind farm is more than 5.6 miles away from the
closest point at Wehle and therefore is considered far distant background.

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potential visual impact at Wehle State Park is limited due to the small number of areas
where there is a direct, albeit distant, view to Galloo Island.
Although there will be some distant views of the wind farm from certain specific
locations within the Park, the potential visual impact is limited by the types of uses of the
Park (including hunting and hiking) and limited available locations for scenic views of
Galloo Island compared with the total size of the Park. Moreover, as indicated above, the
real life kinetic distractions for a viewer in this Park, in conjunction with generally less
than ideal atmospheric conditions will further obscure these distant, background views.
The last location identified in the comments of concern was regarding potential impacts
to the Sackets Harbor Battlefield. There will be no direct effect on the Battlefield site
and its uses as an interpretative location of the history of the War of 1812. However,
views of the Project will be visible from certain locations from the Battlefield based on
the simulations prepared as part of this DEIS/FEIS. Because the Battlefield is on the
National Register of Historic Places, these impacts are also discussed below under
Section 2.7. There are some locations from the Battlefield Park where the Project will be
visible in the distance, however, views of the water will remain unchanged. In addition,
many modern elements have already been introduced into the viewshed for example,
motorboats can be seen in the photos of current conditions prepared for the Project
application in addition to roads and roadside steel guard rails among others, thereby
minimizing the potential impact to the Battlefield.
As previously stated by the SHPO, the further minimization of visual impacts is not
feasible. WTG will not be in the foreground and impacts will not be significant. The
consideration of onsite-aesthetic screening (vegetative or other) would reduce the
visibility of the WTG but also have an adverse effect of reducing other scenic views that
are more prominent to the amenities of the Village of Sackets Harbor. Impacts to historic
properties have been minimized to the extent practicable and will further be off-set by
historic off-set projects though the Section 106 process.

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In addition to the comments regarding impacts on State Parks, other comments related to
potential nighttime views associated with FAA required lighting and alternative options
for camouflaging turbines.

In order to respond to these comments, a number of

additional photosimulations were done. In particular the following photosimulations


were completed from:
A simulation of turbines from Site 19
Nighttime simulations from Sackets Harbor Battlefield, Wehle State Park and
Eastern Ontario Waterway Access
Simulations of blue-gray turbines with FAA required white lights during a clear day
from Sackets Harbor Battlefield, Wehle State Park and Eastern Ontario Waterway
Access
Simulation of white turbines during a cloudy day from Sackets Harbor Battlefield,
Wehle State Park and Eastern Ontario Waterway Access
The simulations show that blue-gray turbines would provide some camouflage of the
turbines. However, the FAA required white lighting would increase the visibility of the
turbines making the potential visual impact nearly equivalent to, if not greater than the
currently proposed white turbines. Additionally, although the FAA circular regarding
lighting wind turbines does not prohibit blue-gray turbines, it is clear that white is the
preferred color in order to make the turbines visible to planes. The wind turbines should
be painted in bright white whenever possible, as the color itself acts as an effective
daytime early warning device. Other colors that were encountered, such as light gray or
blue, appeared to be significantly less effective in providing daytime warning. (FAA
2005). Therefore, since the potential visual impact is not significantly reduced and
because painting the turbines a blue-gray color is not preferred by the FAA thereby likely
complicating FAA approval, a blue gray color will not be included for the turbines
proposed for the Hounsfield Wind Farm.
The turbines will also have a red beacon on the top of some of the towers. These lights
will flash simultaneously as required by the FAA. As shown on the simulations of
various locations these lights will be visible from many of the same locations that will be
able to see the wind farm during the day. The lights will be distant features on the
horizon and not significantly visible. Moreover, the resource from where the nighttime

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lighting is most likely to be visible is from the Seaway Trail along portions of Route 3.
However, given the significant distance from the turbines, the need for clear atmospheric
conditions, and the speed a potential viewer is traveling along the road at night, it is
unlikely that the nighttime lighting will be within the viewers perception for any length of
time to be considered a significant adverse impact.
Additionally, although the nighttime lighting of the turbines will be visible from the
identified state parks, it is not anticipated that the nighttime lighting will detract from any
potential scenic views given the distance from the turbine locations and the current uses
of the identified state parks. These facilities are only open during daylight hours. Thus,
the use of nighttime lighting is not anticipated to result in a significant visual impact to
these resources.
Mitigation
The Project Sponsor has attempted to minimize visual impacts to the extent practicable
with layout and design considerations including assessing potential options for
camouflage or disguise including a review of different colors for the WTGs. However, as
the State Historic Preservation Office has pointed out, direct mitigation of the potential
visual impact from the Project is not feasible given the fact that elimination or relocation
of turbines for this unique island location will not reduce potential visual impacts.
According to NYSDECs Visual Policy, offsets should be employed in sensitive locations
where significant impacts from the proposal are unavoidable, or mitigation of other types
would be uneconomic and mitigation to be used is only partially effective. Offsets should
be employed when significant improvement can be expected at reasonable cost. Off-sets
of potential impacts to Robert G. Wehle State Park, Wescott Beach State Park and
Southwick Beach State Parks have been recommended by the New York State Office of
Parks, Recreation and Historic Preservation. These include:

improving access to areas already available to the public and expanding access to
more scenic areas of these parks.

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trail improvements, improvements to picnic areas along the scenic bluff, and
directional and interpretive signage.

The complete list of State Parks recommendations is included in the FEIS in the Agency
Correspondence section.
Additionally, enhancements to existing visual resources to offset the change in visual
setting at the Sackets Harbor Battlefield Historic Site and the Madison Barracks have
been recommended by the Town of Hounsfield and Village of Sackets Harbor, and
include:

Restoration of the cottage adjoining the Pickering-Beach Museum immediately


adjacent to the battlefield site and preservation of the museum collection.

Refurbishment of the Stone Hospital at Madison Barracks in the Village of


Sackets Harbor, which has a direct view to Galloo Island.

The complete list of the Town/Village recommendations are included in the FEIS in the
Agency Correspondence Appendix Q.
2.7

Archaeological and Historic Resources

Characterization
Since publication of the DEIS the project sponsor consultants completed a Phase 1B
Cultural Resource Investigation and a Historic Building Survey for a Ten-Mile APE (See
Appendix K).
The Phase IB Cultural Resources Investigation involved surface inspection and shovel
testing in selected portions of the project area designed to meet the requirements of the
SHPO. The investigation was designed to comply with the SHPO Guidelines for Wind
Farm Development Cultural Resources Survey Work (2006). The investigation was also
conducted according to the New York Archaeological Councils Standards for
Archaeological Investigations and additional SHPO guidelines. Only areas owned by
Galloo Island Corp were investigated. No prehistoric artifacts were found on Galloo
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Final Environmental Impact Statement

Island. Four historic sites were identified and all were associated with the discovery of
partial structures or foundations (See Figure 2.7-1).
The Historic Structure Survey for the 10-mile APE includes sections of the Towns of
Hounsfield, Henderson, Brownville, Lyme and Cape Vincent in Jefferson County, New
York. No direct survey work was done on Grenadier, Fox and Stony Islands due to
inaccessibility. The methodology of the survey was developed in consultation with
SHPO.
Impacts
On April 8, 2009, the State Historic Preservation Office (SHPO) sent a letter (Appendix
K) recommending that each of four indentified archeological sites be avoided, as they
may contribute to the ability to interpret the history of the island. If avoidance is not
feasible SHPO recommended that each site have a Phase II investigation. As discussed
below, the Project Sponsor has provided SHPO with a scope of work for the Phase II
investigation and is currently preparing plans to implement the work next spring.
A letter from the SHPO dated June 23, 2009 determined that approximately 238
resources listed or eligible for listing on the State or National Registers of Historic Places
with the survey area. Within the survey area, SHPO identified several key receptors
where visual impacts should be carefully assessed. These include the Galloo Island
Lighthouse Complex, the Sackets Harbor Battlefield, the Madison Barracks Complex,
and the Sackets Harbor Village Historic District. The SHPO indicated that the visual
assessment provided in the DEIS sufficiently assessed these resources. The SHPOs
assessment concluded that unlike previously evaluated wind farm projects, the
Hounsfield (Galloo Island) Wind Farm is sited on an island in the midst of open water,
creating a much higher visibility potential than mainland based projects where the
undulating topography and landforms in conjunction with a mature intervening landscape
help to break up the scale and density of the project. This exposes a significant amount of
recreational shoreline vistas and historic resources to the full expanse of the turbine field,
albeit at a distance of 10-13 miles. The Sackets Harbor Battlefield and Madison Barracks

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in particular use the largely unaltered viewshed and vista looking out to Galloo Island as
part of their historic museum programs. The visible turbine field will forever (or until any
decommissioning may occur) alter what has been a largely intact historic vista for more
than two centuries.
SHPO determined the undertaking will have an adverse effect on cultural resources. The
introduction of the sleek, ultramodern 410 foot tall kinetic wind turbines (up to 84
proposed) concentrated on the roughly 2,000 acres of Galloo Island will significantly
alter the historic viewsheds from the mainland, which have, remained largely unchanged
for centuries and have served as the backdrop for the architectural, cultural, recreational
and scenic tourism heritage of these communities.
SHPO also determined, in regards to historic structures, With regard to the historic
resources located on Galloo Island amidst the turbine field, there is no question that the
construction of 84 turbines spread out over the island's 4.5 mile length of largely
undeveloped pasture and grasslands will forever alter the isolated, intact setting of the
historic resources that now occupy the island. To date the tallest man made landmark on
the island is the National Register listed Galloo Island Lighthouse complex. The ca. 1857
stone tower stand 60 feet tall, which is significantly less than one-half of the length of a
single blade on a turbine unit (approx 147 feet). Given the unique circumstances
associated with this portion of the project (turbine field development) we see no
reasonable way in which the affects associated with the construction of these units on
Galloo Island can be avoided or minimized through layout alteration or unit number
reduction.
Mitigation
Based on the determination regarding archeological resources on the island, the Project
sponsor relocated WTG 3 to avoid one of the identified archeological sites. The laydown
areas associated with the temporary dock was relocated to avoid the edge of this area.
Another site would not have been impacted by ground disturbance. However, one of the
sites is at the site of the permanent slip. This site cannot be avoided and therefore a

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Phase II investigation will be conducted prior to construction. The methodology for this
Phase II investigation is included in Appendix K.
As stated in the SHPO letter dated June 23, 2009 direct impact mitigation of impacts to
architectural resources is not feasible and therefore was not further evaluated. Offset
mitigations were raised in both the public comment period and the discussions with the
Town of Hounsfield. Potential mitigation options that have been discussed are:
Stabilization of the former Coast Guard Station on Galloo Island
Rehabilitation of the Galloo Island Lighthouse
Renovation and restoration of Nation Register Listed (NRL) District Schoolhouse
#19 located in the Sulphur Springs Cemetery, Hounsfield, NY
Repair and restoration of the NRL Sulphur Springs Cemetery, Hounsfield, NY
Repair and restoration of Military Cemetery, Village of Sackets Harbor, NY
Upgrades to historic exhibits at the East Hounsfield Library, Hounsfield, NY
Production and installation of historic markers at historic locations in the Village of
Sackets Harbor and Town of Hounsfield, NY
Renovation and preservation of the Pickering Brach Cottage Museum, Hounsfield
NY
Restoration and preservation of historically significant exhibits for the Pickering
Beach Cottage Museum, Hounsfield, NY
Repair of the Sackets Harbor Bank Building, Sackets Harbor, NY
Rehabilitation and restoration of Stone Hospital, Sackets Harbor, NY.
This is a preliminary list of potential mitigation options, it is not likely that all of these
projects would be funded. Final mitigations will be negotiated through the Section 106
process for Historic Impacts during the USACE wetland permitting process. The final
list of mitigation measures will be negotiated between the SHPO, project sponsors and
the USACE.
2.8

Socioeconomics

Characterization
There are no changes to the socioeconomic characterization of the area.

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Impact
Since the publication of the DEIS the Project sponsor has increased the proposed PILOT
payment for the project to $8,500 per MW. That would be $2,142,000 per year to be split
between the Town, County and School District.
Mitigation
The increased PILOT amount is a project benefit and therefore, does not require
mitigation.
2.9

Public Safety

The project changes will not alter the analysis of impacts and mitigations to public safety.
Therefore, no changes are required to this section.
2.10 Microwave Beam Interference
The project changes will not alter the analysis of effects on microwave transmission.
Therefore, no changes are required to this section.
2.11 Blasting Issues
Characterization
The borrow pit, which is a new project component, will be blasted to extract material that
will be used in the construction of the roads on Galloo Island.
Impacts
The impacts from the construction of the borrow pit will be similar to those that were
anticipated for the construction of the WTG. A confined blast technique will be used to
avoid most potential impacts.
Mitigation
The DEC requested that the project sponsor incorporate DECs Guidelines for Evaluating
Mining Applications that Propose to Use Blasting Including Best Management Practices,
Division of Mineral Resources, June 2009. Due to the remote location some of the

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recommended measurers were not applicable, particularly those regarding, notification of


neighbors and some noise reduction measures. This revised blasting plan is incorporated
as Appendix L.
As discussed in Section 2.5.6 above a blasting plan was prepared for the offloading
facility. This plan is included as Appendix D.
2.12 Decommissioning
Based on the revised layout and other project changes, no revisions to the
characterization, impact or mitigations as presented in the DEIS is required.
2.13 Mandated FAA Lighting
Based on the revised layout the project sponsor revaluated the proposed turbine lighting
plan. No changes were required. The project sponsor also prepared visual simulations of
the nighttime lighting these are discussed above in Section 2.6, Visual Resources. No
additional review of characterization, impacts or mitigation is required.
2.14 Air Resources
Characterization
Following publication of the DEIS, the project sponsor conducted more detailed air
emissions calculations than those presented in the DEIS to assess the potential emissions
associated with construction and operation of the Project. These calculations reflected
additional information about construction and operation of the facility gathered after
preparation of the DEIS. This evaluation is included as Appendix M.
Impacts
Six general types of emission sources were identified from the proposed construction and
operations on Galloo Island:
Heating boilers
Hot water boilers
Power generators
Storage tank venting (diesel and gasoline)
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Kitchen and laundry equipment
Construction equipment and areas (including dust generation)
Each identified emission source was evaluated in regard to the NYSDEC regulations for
air sources; all but the generators were determined to be either exempt or trivial for
purposes of NYSDECs air permitting regulations.
The existing plan calls for using three 400-kilowatt power generators to provide power
during the construction of the wind farm. Two generators will provide sufficient power
to meet the highest normal anticipated electrical load. The third unit will be available for
use as a backup if one of the other two generators fails. In addition, the generators will
provide power in the unlikely event that the fire pumps are required.
The potential to emit from the generators was calculated assuming that all three units will
run at peak capacity for 24 hours a day, 365 days a year.

Under this extremely

conservative scenario, the generators would emit a maximum of 40 tons of NOx and 15
tons of CO annually. These emissions are well below the applicable major source
thresholds for these pollutants. Emissions from the remaining sources listed above are
expected to be minimal.
In practice, the generators will not operate throughout the year due to the shortened
construction season. A more likely scenario is that one generator would run continuously
(8,760 hours per year), and a second generator would run approximately 30% of the time
(2,657 hours per year), although the actual load would be distributed between the two
operating units. Under this scenario, the generators would produce 17 tons of NOx and
6.6 tons of CO per year.
The three generators will be maintained on-island during wind farm operations as a
backup source of power for facilities on the island. They will be used only if both the
wind turbines and power from the main power grid are unavailable, an extremely unlikely
scenario. Emissions from other sources remaining on the island during the operations
phase are expected to be minimal. Accordingly, total emissions associated with the
operations phase of project are expected to be minimal.

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It has been determined that the three generators are subject to emission standards set forth
at 40 CFR Part 60, subpart IIII, Standards of Performance for Stationary Compression
Ignition Internal Combustion Engines. As a result, they will require an air permit from
the NYSDEC.
Mitigation
No mitigation is required.
2.15 Noise
Characterization
During the public comment period noise impacts at the Town of Lyme were raised as a
potential issue of concern by several commenters. A concern was also raised about noise
effects on worker safety. The Town of Hounsfield also requested, during the site plan
approval process, analysis of the potential impacts to Stony Island. To respond to these
concerns, the project sponsor engaged a noise consultant to analyze the potential noise
impacts at all of these locations. These reports are enclosed as Appendix N.
Impact
A study was preformed of the sound effects from the wind farm on the nearest shoreline
locations including South Shore Road Extension in Lyme, Beach Road in Lyme, Flanders
Road in Lyme, Fox Island Road on Fox Island, and Pillar Point in Brownsville. Ambient
sound levels from a similar offshore wind project, the Cape Wind Project, were used to
estimate the Leq1 ambient sound levels at the five shoreline receptors. These data were
approved by the NYSDEC for use on this project. To ensure a conservative analysis, only
the quieter off-shore wind measurements from the Cape Wind project for an isolated
location with no boat or motor vehicle noise (Point Gammon, Yarmouth) were utilized.
The criteria used for the shoreline locations of the mainland were the NYSDEC
incremental sound guidelines and potential audibility.
To protect employees on the island, the consultant also studied the projects sound effects
on the outdoor environment at the workers residential buildings that will be built on
Galloo Island. The criterion for this employee effects portion of the study was the OSHA
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hearing conservation action level of 85 dBA. This is a conservative threshold since


hearing protection for workers is not required except when sound levels exceed 90 dBA.
Future sound levels from the Galloo Island wind turbines were calculated with the
Cadna/A acoustic model. Cadna/A is a sophisticated 3-D model for sound propagation
and attenuation based on International Standard ISO 9613. Predicted maximum sound
levels are conservative because: 1) The model was instructed to ignore foliage sound
absorption; 2) The model assumes partial reflection from soft ground surfaces which
typically absorb sound; 3) The model assumes Lake Ontario is a perfectly reflective
surface and ignores the effects of waves in scattering sound waves; 4) The acoustic model
assumes a ground-based temperature inversion, such as those that may occur on calm,
clear nights when sound propagation is most favorable, but wind turbine operation is least
likely; and 5) The turbine maximum sound power level includes a 2-dBA safety margin.
The studys conclusions are as follows:
The maximum predicted wind farm sound levels at the five closest shoreline
receptors are only 14.3 to 32.5 A-weighted decibels (dBA) and far below the
minimum ambient sound level of 50.7 dBA associated with the turbine design
wind condition (9 m/s wind speed at hub height).
The maximum increase in the ambient sound level at the shoreline is only 0.1 dBA
and well within the NYSDEC-recommended 6-dBA threshold.
Analysis of the broadband and octave band sound levels reveals that the wind farm
will not be audible at any shoreline location, and there will be no perceptible
infrasound or very low frequency sound from the Galloo Island wind farm.
The predicted maximum outdoor sound level at the worker housing area on Galloo
Island is 58.1 dBA and safely in compliance with the OSHA hearing conservation
action level of 85 dBA. An outdoor sound level of 58 dBA is typical for an urban
area and will not interfere with outdoor activities at the worker residential
buildings. A wind turbine outdoor sound level of 58 dBA is less than the 65 dBA
level that is typical for a conversation between two people standing a few feet
apart.
The maximum predicted wind farm sound level at Stony Island is only 40.6 Aweighted decibels (dBA) and far below the minimum ambient sound level of 50.7
dBA associated with the turbine design wind condition (9 m/s wind speed at hub
height).
The maximum increase in the ambient sound level at Stony Island is only 0.4 dBA
and well within the NYSDEC-recommended 6-dBA threshold.

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Analysis of the broadband and octave band sound levels reveals that the wind farm
will not be audible at Stony Island, and there will be no perceptible infrasound or
very low frequency sound from the Galloo Island Wind Farm.
Mitigation
Because the impacts to Galloo Island, Stony Island and mainland locations are within
acceptable thresholds, no mitigation is required.
2.16 Alternatives
During the public comment period a number of comments were submitted regarding
alternatives to the existing layout (See Section 3.0 for the comments). The Project
sponsor took into account many of the comments and developed a new alternative layout.
This layout moved the substation to the agricultural area, collocated roads and ECS and
avoided archeological areas. Upon further analysis the project sponsor determined that
this alternative layout reduced impacts without significantly affecting the ability of the
project to meet the project goals of developing a renewable energy source from the
unique wind resource on Galloo Island. This alternative was therefore selected as the
new preferred alternative. This new alternative is what is analyzed in this document and
any permit submissions. The new preferred alternative maintains 84 3.0 MW turbines on
Galloo Island for a total of 252 MW of maximum output.
See Sections 1.1 and 1.12-3 for additional detail regarding this alternative.
2.17 Coastal Zone Consistency
Since the publication of the DEIS a new Costal Zone Consistency evaluation was
prepared. This is now attached as Appendix O. Changes to the evaluation presented in
the DEIS are presented below:
Policy 7 Significant Coastal Fish and Wildlife Habitats Will Be Protected, Preserved,
And Where Practical, Restored So As To Maintain Their Viability As Habitats. The
Project is consistent with this policy. Since the publication of the DEIS, however, Upstate
Power has revised its Coastal Zone Assessment to account more fully for potential
impacts to nearby Significant Coastal Fish and Wildlife Habitats (SCFWHs) from the
wind farm. While the DEIS assessed the potential impacts to avian populations associated

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with nearby SCFWHs, the revised Coastal Zone Assessment stated that the wind turbines
will result in minor visual impacts to these nearby SCFWHs. However, because the
viability of these SCFWHs does not originate in the aesthetic nature of these resources,
the Project is consistent with Policy 7. The revised Coastal Zone Assessment is contained
in Appendix O.
Policy 23 Protect, Enhance, And Restore Structures, Districts, Areas Or Sites That Are
Of Significance In The History, Architecture, Archeology Or Culture Of The State, Its
Communities, Or The Nation. The Project is consistent with this policy. Since the
publication of the DEIS, however, Upstate Power has revised its Coastal Zone
Assessment to account more fully for potential visual impacts to the historic,
archeological and architectural resources located within or near the Sackets Harbor State
Historic Site. A visual simulation of the wind farm from this site was completed as part
of the DEIS. Within the visual simulation produced, the wind farm and other modern-day
elements, including guard rails, a paved road and motor boats, were visible. Since
modern-day elements are currently visible from the Battlefield, the introduction of wind
turbines at a distance of 14 miles from this location will not detract from the experiences
of visitors to the site. The revised Coastal Zone Assessment is contained in Appendix O.

Policy 25: Protect, Restore Or Enhance Natural And Man-Made Resources Which Are
Not Identified As Being Of Statewide Significance, But Which Contribute To The
Overall Scenic Quality Of The Coastal Area. The Project is consistent with this policy.
Since the publication of the DEIS, however, Upstate Power has revised its Coastal Zone
Assessment to account more fully for potential visual impacts to Robert G. Wehle State
Park, Westcott Beach State Park, Southwick Beach State Park, and Black Pond Wildlife
Management Area. While the turbines will be visible from each of these locations, the
visibility of the turbines will not cause the diminishment of public enjoyment and
appreciation visitors, who visit these parks to observe wildlife, hike or obtain some peace
and quiet. In addition, other modern elements, such as motorboats, roads and structures
are typically in the viewsheds of these parks. The revised Coastal Zone Assessment is
contained in Appendix O.
Policy 35: Dredging and Filling In Coastal Waters and Disposal Of Dredged Material
Will Be Undertaken In A Manner That Meets Existing State Permit Requirements, and
Protects Significant Fish And Wildlife Habitats, Scenic Resources, Natural Protective
Features, Important Agricultural Lands, And Wetlands. Excavation for the entrance
channel at the permanent offloading facility will occur to a depth of 14 feet below
ordinary low water (243.3 IGLD) rather than to a depth a depth of 14 feet below ordinary
high water. The area of excavation will be 36,000 square feet, rather than 32,000 square
feet as indicated in the DEIS. The revised Coastal Zone Assessment, contained in
Appendix O, clarifies the extent to which excavation will take place.

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2.18 Cumulative Impacts


Following publication of the DEIS, the New York State Department of Public Service
(DPS) staff submitted comments that the cumulative visual impact of the wind farm and
transmission line was not adequately presented. In response the project sponsor prepared
a map showing the vegetative cumulative viewshed of the transmission line and wind
farm (See Figure 2.18-1 Cumulative Vegetated Viewshed Analysis)
As shown on Figure 2.18-1, there is a portion of views from the Lake that have potential
visibility of both the transmission line and wind farm. However, it is very unlikely that a
viewer from these in-water locations would see both the major transmission line and the
WTG simultaneously.
Very little area on the mainland will have views of both the transmission line and wind
farm. According to the cumulative vegetative viewshed (Figure 2.18-1) there is the
possibility from some locations of a simultaneous view of the transmission line and wind
farm. These areas of cumulative visibility are generally along Henderson Harbor. Two of
these locations are along the Seaway Trail at the intersection of Route 3 and Route 178
and along Route 3 north of this intersection. However, at these locations the wind farm
would be nearly 10 miles away and partially screened by Stony Island. Neither of these
locations are the Seaway Trail Scenic Byway Overlook.
Regarding potential cumulative impacts from other operating wind farm projects, the
only potential cumulative impact is along the Seaway Trail Scenic Byway Overlook and
involves views to the currently operating Wolfe Island Wind Project in Canada. The
relevant portion of the Seaway Trail comprises New York Routes 3 and 12 and generally
runs from Sacket's Harbor to Watertown in a north and south direction. The towers on
Wolfe Island are visible at night to vehicle traffic on the Seaway Trail due to the aviation
warning lights located on the top of the towers. Similar warning lights will be located on
twenty-three towers on Galloo Island.
Given the relative physical location of Wolfe and Galloo Island from the Seaway Trail,
there are few vantages that will allow for visibility of both projects at the same time. It is
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therefore unlikely that a viewer will be able to see both projects at the same time. Only
in a rare instance will both projects be seen together, which would be at best background
elements in the viewshed. For most circumstances, the operation of both projects is
unlikely to have a cumulative effect. There may be some locations where both projects
are viewable within the same view. However, overall scenic views from the Seway Trail
are limited at night and even potential views at dusk and dawn it is anticipated that
potential visibility of both projects is significantly limited and therefore will not create a
cumulative impact.
The potential cumulative visual impact of the build-out of all existing and formally
proposed wind projects in the Lake Ontario/St. Lawrence River region (Hounsfield Wind
Farm, St. Lawrence Windpower, Cape Vincent Wind Farm, Horse Creek Wind Farm, and
Wolfe Island Wind Farm) would include approximately 350 utility-scale wind generating
turbines spread throughout the region, each likely exceeding 390 feet in height. While not
continuously visible, wind-generating turbines would be a dominant and widespread
visual feature from local roadways, homes and various places of interest. Turbines would
also be visible on the horizon from vantage points on Lake Ontario and the St. Lawrence
River along approximately 50 miles of waterway, from Clayton west and south to
Southwick Beach State Park in Jefferson County. At this point only the Wolfe Island
project has been completed, and DEC has received applications for permits for one other
wind project, the proposed 53-turbine St. Lawrence Windpower project in the Town of
Cape Vincent. It should also be noted that wind turbines on the mainland present a larger
foreground visual impact than those proposed on Galloo Island; nonetheless the Galloo
Island turbines, although distant, would represent a change to the visual setting on the
horizon at vantage points along the Lake Ontario shore.
2.19 Transmission Line
Due to the relocation of the substation (described in Section 1.12-3) the transmission line
on Galloo Island, has been relocated. The transmission line is now shorter, only 1,760
feet on Galloo Island, compared to 13,293 feet previously. This change also eliminates
several locations where turbines were located closer than 1.5 times tip height from the

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transmission line.

The current layout maintains a 1.5 tip height setback between

overhead transmission structures and turbines. It also maintains a 1.1 tip height setback
between the underground transmission line and WTG.

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3.0 Response to Comments


This section presents the comments that were submitted during the public comment
period for the DEIS. Comments are numbered based on the section of the DEIS the
comment reference. Where appropriate, like comments are presented together.

The

commenter is noted as the source at the end of the comment.

Comment
#
1.0-1

1.0-2

Topic: Project Description


Comments
The document describes project
components in this section, but
we noted that there were no
distances listed for overhead and
below ground 34.5 kilovolt
collection
lines
provided
(although it is mentioned later in
the text). We recommend this
information be provided in the
Executive Summary.
Source: USFWS
Two Related Comments:
Comment 1: Upstate NY Power
Corporation is proposing to
install up to 84 wind turbines
with a capacity of approximately
252 megawatts (MW). It should
be noted that the actual output
from the project will be
approximately 83 MW because
of the intermittent nature of
wind.
Source: USFWS

1.0-3

Responses

Comment Noted. The 34.5 kV electrical


collection system (ECS) is described in
detail in Section 1.2 Project Description
beginning on page 1-22. In that section it is
stated that approximately 16.6 miles of 34.5
kV buried cable and 5.5 miles of overhead
cable will be required to connect the WTGs
and tie into the substation. This information
was left out of the Executive Summary for
the sake of brevity.
It is standard practice for an electric
generating facility to measure output based
upon nameplate capacity. For example, the
New York Public Service law and the
jurisdiction of the Public Service
Commission is based upon the nameplate
capacity of a generating facility. The DEIS
does note on pages ES-2 and 1-3 that it is
assumed that the Project will generate
electricity at 33-34% of the nameplate
capacity and that this percentage or capacity
factor represents a total yearly average
output for the project when considering
outages, maintenance and fluctuations in the
wind resource. The DEIS further states that
preliminary estimates indicate an average
project output of approximately 83.2 MWs
which would generate approximately
728,482 MW hours per year.

Comment 2: If you are going to


get 252 megawatts out of this
island, that's really the maximum
that it can produce under ideal
conditions of high winds and
steady winds.
Source: Herb Bowers (H)
In regard to fossil fuel According to the New York State Draft
reductions, the DEIS indicates Energy Plan, August 2009, the emission of
that the project will reduce NOX, SO2, and other pollutants are
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Final Environmental Impact Statement

emissions of carbon dioxide


(CO2), sulfur dioxide (SO2), and
nitrogen oxide (NOX) by large
amounts.
However, these
emissions have been declining
steadily in New York State since
1999. The SO2 has declined 77
percent, NOX by 61 percent, and
CO2 by 28 percent (USEPA
2009).
Source: USFWS

1.0-4

associated with a number of adverse health


effects, including cardiovascular disease,
respiratory effects, infections, asthma
exacerbation, cancer, central nervous
system effects, liver effects, kidney effects
and mortality. Emissions of acid deposition
precursors (NOX and SO2_ from sources in
New York and upwind continue to degrade
the States forests and water bodies and
impair visibility. In general, the decrease in
emissions of these contaminants will reduce
the likelihood of both health and
environmental impacts. The Draft Energy
Plan concludes that this can be
accomplished through a shift to non-carbon
based energy sources, such as wind.

The calculations in Section 1.1 - Project


Need - Emissions Reductions from Fossil
Fuel Offset, are based on a formula in the
NYSERDA Wind Energy Tool Kit and
are intended to illustrate the potential
reduction in greenhouse gasses and
resulting environmental benefit that could
result by shifting from the use of fossil fuels
for electricity generation to renewable wind
energy for the production of new electricity.
This is consistent with a number of State
and Federal goals and incentives
encouraging the development of renewable
energy sources as well as the Draft State
Energy Plan which states that Renewable
energy
technologies,
including
hydroelectric, wind, biomass and solar
power generation, have fewer negative
environmental impacts than fossil fuelbased generation. (See Draft State Energy
Plan, August 2009, Issue Brief regarding
Environmental Management of Energy
Systems, page 8).
The DEIS reports that the actual The point of this comment is not clear and
(nameplate) capacity of the in any event, the comment is incorrect.
proposed
electric
grid Generating capacity is stated in the DEIS in
interconnect is only 83 MW.
megawatts and transmission power is stated
Source: USFWS
in kilovolts (kV). The nameplate capacity
of the Project is 252 megawatts (MW).
Based on the capacity factor of 33-34%, the
3-2

Hounsfield Wind Farm


Final Environmental Impact Statement

1.0-5

We note that many of the data


contained in this section (1.0
Project Description) is from the
fall of 2008 and outdated. The
number of projects, turbines and
interconnection requests should
be updated.
Source: USFWS

1.0-6

The document indicates on Page


1-29 that 2.4 miles of overhead
transmission line will be needed
on the island, but page 1-23
indicates that 2.6 miles of
overhead line will be needed.
This discrepancy should be
reviewed.
Source: USFWS
We note that the DEIS does not
provide information about the
exact size of the water intake nor
the size opening of any screen
mesh.
Source: USFWS

1.0-7

actual output will be approximately 83


MW.
In terms of transmission, the
proposed transmission line will transmit
electricity at 230 kV. At the Mexico
interconnect substation, voltage will be
stepped up from 230kV to 345kV for
connection to the regional power grid.
The articles cited in preparing Section 1.1 Project Need - Impacts of the Project on
Market were current when the DEIS was
written and are still relevant. In the time the
DEIS has been in review the relative
position of the Project in the NYS ISO
queue has not substantially changed.
According to the NYSISOs 2009 Load &
Capacity Data Gold Book - Table IV-1
there now are 24 Proposed Generator
Additions utilizing wind turbines; as
opposed to 33 in the 2008 Gold Book. The
Project remains listed in the category of
Class 2009 Candidates.
Comment noted. In response to additional
comments on the DEIS and in the Article
VII proceeding from the NYSDPS, the
layout of components on the island has been
revised to substantially shorten the onisland portion of the major transmission line
to 1,800 feet.

The water intake system is designed to


provide an adequate supply of fresh lake
water to both the potable water system and
fire protection system for use at the housing
and operations & maintenance complex. A
detailed description is provided in the
Offloading Facility, Water Intake &
Wastewater Discharge Design Report, June
2009 (Design Report) prepared by URS
Corporation as Appendix A to the Joint
Application for Permit.
The intake pipe will extend approximately
575 feet underwater from shore. At the
inlet location the pipe will be buried and
terminated with a six foot diameter precast
concrete pipe section set vertically with the
top approximately 1 foot above the existing
3-3

Hounsfield Wind Farm


Final Environmental Impact Statement

Comment
#
1.1-1

1.1-2

lake bed at a water depth of approximately


30 feet. An intake screen cap will be
attached to the top of precast section to
prevent debris, fish, and other organisms
from entering the intake. The cap will
consist of a non-metal bar rack frame which
will support a finer alloy screen with 2
millimeter maximum openings.
Topic: Purpose Need and Benefits
Comments
Responses
The discussion of policies and
statements by public officials at
pages 1-6 through 1-10 should
be reviewed and revised to
distinguish the citations of
official testimony from the DEIS
narrative.
Some
of
the
conclusory points appear to be
arguments provided by DEIS
authors rather than attributable to
statements by public officials,
which may be misleading to
readers of the DEIS.
Source: DPS
Two Related Comments:
Comment 1: Wind turbines will
generate electricity intermittently
and other sources of generation
will be needed as a backup
during low wind periods.
Source: USFWS

Comment noted. Statements from the


quoted public officials are presented herein
because they are consistent with the benefits
and need of the Project. Quotes from the
reports and public statements are presented
within quotation marks in order to
distinguish them from the DEIS authors
narrative. It was not the DEIS authors
intent to confuse statements attributed to
public officials with the arguments put forth
by the DEIS authors. Additional New York
policy adopted since the DEIS is updated
and discussed in Section 1.2 of the FEIS.
The production of electricity from this
project will be variable based on wind
speed. The electricity that is generated will
be sold to the power grid in the New York
State energy market.
Other energy
producers sell electricity on this market
including other wind projects, hydro and
fossil fuel powered plants.
Therefore,
because other power plants will be operating
during periods of high and low wind, there
is always a sufficient capacity and no one
generation facility is a specific backup to
another. Electric power generated by the
wind farm will be sold to the power grid
based on price and availability; offsetting
the demand for power from other generating
sources. As more wind power projects are
brought on-line, there will be less demand
for new fossil fuel plant expansion.

Comment 2: But you need to


have another 252 megawatts of
backup capacity, which could be
nuclear power, could be coal
power, could be gas powered,
hydro -- any of the sources that
we use here in New York State.
And the winds might produce 25
to 30 percent of the 252
megawatts over a year's time. So
the rest of the other 75 percent or
70 to 75 percent would have to In addition, in a report issued in June 2009,
be produced by some other the NYISO looked at the impact of Plug-in
3-4

Hounsfield Wind Farm


Final Environmental Impact Statement

source. And that source would


likely be something like coal or
nuclear or gas turbines.
Source: Herb Bowers (H)

Hybrid Electric Vehicle technology on grid


operations and electricity system planning
and concluded that, in general, the
production profile of wind resources in New
York correlates very well with off-peak
charging of PHEVs, creating the potential
for a synergy between wind generation and
transportation energy needs. (See NYISO,
Alternate
Route:
Electrifying
the
Transportation Sector, June 2009)
The DEIS does not state that the Project will
be clean and free of pollution. The
intent of DEIS section discussing emissions
reductions from fossil fuel offset was to
present the potential offset in emissions (as
published by the NYSERDA) that can be
realized by bringing additional supply from
renewable sources to market and lessening
the need for additional fossil fuel based
generation capacity.
However, it is true
that wind turbines require no fossil fuel to
generate energy. Also see comment 1.1-2
regarding back up power sources.

1.1-3

It's really a false statement to say


that all this power is going to be
clean and free of pollution
because these backup power
sources have to operate not just
70 percent of the time. They
have to operate a hundred
percent of the time, and there is - as an engineer I realize there is
a limited ability for the operators
of these major power plants to
follow the variability of wind,
Source: Herb Bowers (H)

1.1-4

The power of wind is a function Comment noted.


As described in the
of the cube of the wind speed. response to comment 1.0-3 nameplate
So the turbine almost magnifies capacity is adjusted utilizing a conservative
the variability of wind. What capacity factor to adjust for the reduction in
that means is if the wind speed is output based on the variability of wind
halved, say you have a wind of speeds.
32 miles an hour and you go
down to 16, the power you can
get out of that wind is now one
eighth of the power. So there is a
strong variance in the output of
the wind.
Source: Herb Bowers (H)
And there is genuine debate Both the New York State Draft Energy Plan
among people who study this as and the recent Mid-Course Report on the
to whether there is, in fact, any RPS by the Public Service Commission
savings of fuel or emissions at recognize that it is in the public interest to
all from wind power. Experience expand the States clean energy investments
in Denmark and Germany in New York and that clean energy sources
suggests there is none.
provide significant environmental benefits.
Source: Herb Bowers (H)
How do local residents benefit In addition to the State-wide benefits
from this project? In particular associated with the Projects consistency
3-5

1.1-5

1.1-6

Hounsfield Wind Farm


Final Environmental Impact Statement

access to the following should be


provided:
A copy of the
agreement between the local
governments, the developer, and
relevant power companies. The
plans for energy dissemination.
Information on the tax and
energy price implications for
nearby residents. Estimates of
positive
and
negative
externalities.
Source: Jane Bardon

with the many State policies seeking to


promote renewable energy sources due to
their low environmental impacts and many
environmental benefits, specifically, there
are many direct local benefits from the
Project as well. The most direct benefits to
Town of Hounsfield residents will result
from:
a) payments in lieu of taxes (PILOT) or a
host community agreement, and
b) from jobs and benefits to the regional
economy from construction.
An application to the Jefferson County
Industrial Development Agency (IDA) was
submitted Fall 2009 and at the time of
writing has not yet been approved. It is
anticipated that PILOT payments will be
$8,500 per MW. At 252 MW, total annual
PILOT payments are anticipated to be
approximately $2.14 million and are
expected to be split between the Town of
Hounsfield, Jefferson County, and the
Sackets Harbor Central School District.
After the term of the PILOT agreement
expires, the Project will be taxed at its full
assessed value. It is estimated in the
Jefferson County IDA application that
approximately 200 jobs will be created
during
construction
resulting
in
approximately $18 million in local labor
wages over a two-year construction period.
Agreements Local Governments:
At this time no agreements have been
adopted or approved by the Town of
Hounsfield or Jefferson County. Under
SEQRA, approvals can not be granted until
the completion of the EIS process and
adoption of Findings.
Agreements with Power Companies:
At this time, New York Upstate Power does
not have a power purchase agreement with
any utility company. However, a power
purchase agreement is not necessary for the

3-6

Hounsfield Wind Farm


Final Environmental Impact Statement

Project to operate because power may be


sold wholesale through the day-ahead
market.
Energy Dissemination:
The purpose of the Hounsfield Wind Farm
Project is to develop a wind powered system
to generate electricity from a clean
renewable source and to sell that power to
the power grid in the New York State
energy market. Given existing capacity
constraints, connection to the regional
power grid will be made in the Town of
Mexico, Oswego County. The wholesale
power will not be transmitted in a manner to
be assigned or directed to a specific
community.
The power generated on
Galloo Island will not directly serve
residents in the Town of Hounsfield but will
instead add to the availability of electricity
for the power grid in New York State.
Tax and Energy Price Implications:
Specific effects of the PILOT agreement on
local taxes will be a function of several
factors, including how the PILOT payments
are divided between the County, Town and
School District; and how each municipal
government in turn budgets the use and
expenditure of that revenue. It should be
noted that since the completion of the DEIS
in February 2009, the proposed PILOT
payment has increased from $8,000 to
$8,500 per MW.

1.1-7

Positive and Negative Externalities:


The comment is noted. It is outside the
scope of the DEIS to account for and
address all possible externalities. The DEIS
is primarily an environmental based
balancing evaluation and has addressed all
the issues and alternatives required by
SEQRA and identified through the Public
Scoping process.
It is stated that the project will The calculations on fossil fuel offset were
reduce the discharge of several prepared by utilizing data presented in the
pollutants by displacing fossil NYSERDA Wind Energy Tool Kit for a
3-7

Hounsfield Wind Farm


Final Environmental Impact Statement

fuel-based electric generation.


Data to support this statement
should be provided in the DEIS.
Source: USFWS

per kilowatt reduction in emissions


calculated for the use of new wind power
instead of fossil fuel-fired power generation
(NYSERDA
website:
http://www.powernaturally.org/Programs/W
ind/largewindfaqs.pdf). The NYSERDA per
KW estimates based on 35% capacity
factor) were then applied to the anticipated a
20-year project life and the nameplate
capacity.
Moreover, the environmental
benefits have been widely established in
New York State policy statements like the
State Draft Energy plan, the PSCs RPS
program, the Governors recent Executive
Order No. 24, and the DECs Climate
Change Office and GHG Emissions Guide.
There is a typographical error on page 1-5
of the DEIS. A preliminary estimate yields
an average project output of approximately
83.2 MWs (not 88 MW as stated) and would
generate approximately 728,482 MW hours
per year. Given the NYISO reported peak
summer demand in 2008 of 33,809 MW
((NYISO website: www.nyiso.com) the
Project could have met approximately
0.24% of the States peak demand in 2008.
In addition, as reported by the PSC, the
State presently anticipates only 62% of the
required Main Tier goal set by the RPS
being obtained. This Project will further
assist the State in meeting the goals of the
RPS.

1.1-8

Based on current electricity


usage, the project will provide
approximately one half of one
percent of the States current
electricity need.
Source: USFWS

1.1-9

The text indicates that summer


peak demand has increased by
1,640 MW over the previous
year and that wind generated
energy could help provide the
needed power. However, during
the summer months, winds
typically decrease in New York
State, as such, wind turbines will
not be providing the electricity
when it is most needed.
Source: USFWS

1.1-10

We note that there is little Comment Noted.


3-8

Although winds typically decrease in


summer, the Hounsfield Wind Farm will
still produce electricity during this time.
Based on the capacity factors discussed in
Section 1.3 of the DEIS. The location of the
project in Lake Ontario will allow for more
consistent energy production than most
inland projects.

Among other efforts,

Hounsfield Wind Farm


Final Environmental Impact Statement

mention here of conservation


measures as a means of
providing the necessary relief on
the States energy needs during
the peak summer period.
Source: USFWS

1.1-11

A recent report by the National


Research Council (NRC) found
that wind energy projects do not
deliver
the
environmental
benefits typically described by
project sponsors. For example,
turbines generally produce at 30
percent of the rated capacity due
to lack of wind.
The NRC also found that almost
no sulfur dioxide or nitrogen
oxide would be eliminated from
the operation of wind energy
projects. A portion of carbon
dioxide emissions is expected to
be reduced. In their report, the
NRC noted that the maximum
wind energy could contribute to
the reduction of this greenhouse
gas is 4 percent.

New York State has established a number of


policy initiatives with the goal of obtaining
increased
efficiency
and
reduced
consumption, for example the Governors
15 by 15 program as well as the PSCs
continuing Efficiency Standard proceeding.
Obtaining increased conservation measures
are a goal that cuts nation-wide across the
power generation and utility distribution
industries and is supported by Upstate
Power.
Conservation and efficiency
generally play an important role in our
energy policy as well as diversifying energy
resources and developing renewable energy
projects. The Project is intended to address
the second of these policy objectives by
contributing a nameplate capacity of 252
MW of clean renewable power to the New
York State electric grid. The need for
additional energy conservation measures are
outside of this SEQRA process and beyond
the stated purposes and goals of Upstate
Powers Project and therefore, not within
the scope of the DEIS.
It is acknowledged that most electric
generating facilities do not produce at the
nameplate capacity. Therefore, a capacity
factor of 33-34% was utilized in calculating
the average project output of 83.2 MW.
The National Research Council carried out a
scientific study of the environmental
impacts of wind-energy projects, focusing
on the Mid-Atlantic Highlands1 (MAH) as a
case example.
A more complete quote from page 5 of the
Environmental Impacts of Wind-Energy
Projects published by the National
Academies Press in 2007 states :
Because the wind blows intermittently,
wind turbines often produce less electricity
than their rated maximum output. On
average in the mid-Atlantic region, the
capacity factor of turbinesthe fraction of
their rated maximum output that they

3-9

Hounsfield Wind Farm


Final Environmental Impact Statement

Source: USFWS

produce on averageis about 30% for


current technology, and is forecast to
improve to nearly 37% by the year 2020.
Those are the fractions the committee used
in estimating how much wind energy would
displace other sources. Other factors, such
as how wind energy is integrated into the
electrical grid and how quickly other energy
sources can be turned on and off, also affect
the degree to which wind displaces other
energy sources and their emissions. Those
other factors probably further reduce the
30% (or projected 37%) figure, but the
reduction probably is small, at least for the
projected amount of onshore wind
development in the United States.
According to the above quote, the capacity
factor used in the DEIS is supported by the
report. It is noted that all generation types
do not operate at their full nameplate
capacity rating.
In addition the NRC study also concluded
that:
Using the future projections of installed
U.S. energy capacity by the DOE described
above, the committee estimates that windenergy
development
probably
will
contribute to offsets of approximately 4.5%
in U.S. emissions of CO2 from electricity
generation by other electricity-generation
sources by the year 2020. In 2005,
electricity generation produced 39% of all
CO2 emissions in the United States.
And it is acknowledged that the report
states:
In addition to CO2, coal-fired power plants
also are important sources of SO2 and NOx
emissions. Those two pollutants cause acid
deposition and contribute to concentrations
of airborne particulate matter. NOx is an
important precursor to ozone pollution in
the lower atmosphere. However, because
current and upcoming regulatory controls on
emissions of NOx and SO2 from electricity
3-10

Hounsfield Wind Farm


Final Environmental Impact Statement

generation in the eastern United States


involve total caps on emissions, the
committee concludes that development of
wind-powered electricity generation using
current technology probably will not result
in a significant reduction in total emission
of these pollutants from the electricity sector
in the mid-Atlantic region.

1.1-12

1.1-13

However, the addition of wind generated


electricity from this Project is far less CO2,
SOX and NOX than a comparable electric
generating project from fossil fuels.
Interestingly, electric generating Comment Noted. As recognized by the
facilities only produce about 39 NYSDEC, carbon dioxide emissions are a
percent of all carbon dioxide significant contributor to global warming.
emissions in the United States.
Source: USFWS
A reported project benefit is the Comment noted. Reduction in reliance on
reduction in reliance on foreign foreign oil is just one benefit of the Project.
oil to meet our energy needs. Additional benefits are described throughout
Eight percent of the electricity this Responsiveness Summary and in
generated in New York State Section 1.2 of the FEIS. Moreover, the
comes from petroleum-based New York State Energy Planning Board
products.
The addition of (Planning Board) has recognized the
electricity into the States grid inextricable link between the availability
from the Hounsfield Wind and price of energy and economic activity
Project
will
impact
that and well being. According to the State
percentage by a small amount.
Energy Planning Board, the U.S.s position
Source: USFWS
in the world economy and the standard of
living of its residents is dependent, to some
extent, on having ready access to reasonably
priced sources of energy. The primary
sources of energy are, to a large degree,
imported from abroad, have significant and
long-term effects on the environment, and
ultimately face depletion. Until new and
sustainable sources of energy are developed,
the U.S. and New York will continue to
experience the economic and social
challenges of fossil fuel dependency. (See
2002 State Energy Plan).
The New York State Public Service
Commission has also found that We are
increasingly concerned with the effects on
our climate of fossil-fired generation and the
3-11

Hounsfield Wind Farm


Final Environmental Impact Statement

security implications of importing [from


out-of-state] much of the fuel needed to
supply our electricity needs. Further in as
much as there is a finite supply of natural
gas and other fossil fuels, over-dependence
on such will leave the State vulnerable to
price
spikes
and
possible
supply
disruptions. (See Case No. 03-E-0188
Renewable Portfolio Standard, Order
Instituting Proceeding (issued February 19,
2003) p.1.).
Finally, the second stated objective of the
States Renewable Energy Portfolio is to
diversify the generation resource mix of
energy retained in New York State to
improve energy security and independence,
while ensuring protection of system
reliability.

Comment
#
1.2-1

The Project helps the State meet this goal


and is consistent with the policies stated
above promoting fuel diversity in order to
protect New York energy customers from
supply disruptions, price spikes as well as
alleviating the dependency on out-of-state
fuel sources.
Topic: General Description
Comments
Responses
Discussion of project area and The
Upstate
New
York
Power
layout in the DEIS section 1.2 Corporations proposed major transmission
should reference a map clearly line is subject to the review jurisdiction of
showing the relation of the the New York State Public Service
proposed project to the proposed Commission (PSC) under Public Service
on-island transmission facilities, Law Article VII. As such, it is a Type II
at a scale comparable to the action under SEQRA (6 NYCRR 617.5(c)
detailed project maps in the (35)) and therefore not subject to SEQRA
DEIS. The only figure provided review and is not included within the
depicting the transmission line Project subject to this DEIS. However, a
facilities
is
presented
at description of the mainland transmission
1:250,000 scale, which does not line is presented in Section 6.0
permit review of inter-relation of Cumulative Impacts of the DEIS.
the overall facilities on land use,
natural resources, or cultural Figure 1.1-1 has been added to show the
features.
project features on Galloo Island.
Source: DPS
3-12

Hounsfield Wind Farm


Final Environmental Impact Statement

1.2-2

Comment
#
1.3-1

1.3-2

Project area discussion does not On Galloo Island approximately, 1,760


include
area
devoted
to linear feet will be utilized for the
transmission facilities other than underground major transmission line ROW.
the substation. The proposed This acreage was not included in the DEIS
transmission facility would because the transmission line is not part of
require maintenance of a right- the wind farm facility subject to SEQR.
of-way up to 150 feet wide to be
cleared of tallgrowing trees to
meet clearance requirements and
minimize tree-induced outages.
An estimate of the acreage
should be provided in the FEIS.
Source: DPS
Topic: Project Design
Comments
Responses
The fire protection scheme
including water storage and
pumping capable of providing
volumes
and
pressures
appropriate to extinguish fires at
the
worker
housing
and
administrative buildings should
be identified in project layout
and design criteria.
Facility
design should meet or exceed
state building and fire safety
code requirements, due to the
remote location of the project
facilities
from
public
infrastructure and fire and
emergency responders.
Source: DPS
The project layout should be
carefully considered in terms of
inter-relation
of
project
components.
The
proposed
layout maximizes the number of
turbines while leaving only
minimal
setbacks
between
turbines and other infrastructure,
which can result in adverse
effects on facility operations.
Source: DPS

Fire Protection and issues relating to


Emergency
Response
generally
are
discussed in the Conceptual Emergency
Response Plan in Appendix S of the DEIS.
Among other things, the project will have
external fire hydrants and two pickup trucks
with fire fighting equipment. In addition,
the fire protection scheme is currently under
review by the Town of Hounsfield as part of
its site plan and building permit review for
the Project. The project sponsor will adhere
to all applicable New York State Building
and Fire codes.

Comment noted. With regard to setbacks


relating to project infrastructure and the
major electric transmission line, in response
to comments from DPS, the Project Sponsor
has revised the layout of the Project to
maintain a 1.5 times setback from all
turbines from the substation and 230 kV
line.
In addition, the project sponsor
modified the project layout to obtain a 1.1
times setback distance from underground
ECS.

However, according to the Project Sponsor,


the decision to maximize the number of
3-13

Hounsfield Wind Farm


Final Environmental Impact Statement

1.3-3

1.3-4

turbines included in the Project is a function


of the resource available at this unique
location and the costs associated with
development of a project on an island
location. A robust wind resource at this
location allows for the ability to accept
greater potential for wake loss than at other
projects. The reliability of the Project will
be demonstrated as part of the Project
Sponsors application for a certificate
pursuant to Section 68 of the PSL.
The helipad was located on the northern end
of Galloo Island based on the wind direction
and speed that would allow for the safest
take offs and landings for the helicopter.
This location is approximately 3.1 miles
along the services roads or 2.6 miles directly
across the island. This distance should not
significantly
slowdown
emergency
evacuation regardless of where an incident
occurs on the island and balancing the desire
for a safe landing and take-off location, it
was determined by the Project Sponsor that
this was the best location for the helipad..

The helicopter landing pad


location is at the furthest point
on the island from the proposed
occupied buildings, including
housing and the Operation and
Maintenance control center
building. Emergency evacuation
planning as part of project
design should consider alterative
arrangements,
such
as
identifying potential sites for the
emergency helicopter landing
pad nearer to centralized
Operations and Residential
buildings, to enable rapid
evacuation from the residential
and control center vicinity.
Source: DPS
The
proposed
Project To mitigate against this concern, the Project
arrangement results in several Sponsor has agreed to permanently maintain
potential risks to the Project a crane on Galloo Island. If there is a
facilities. Potential for turbine catastrophic failure of any tower or
failure, fall down or blade throw component it will be removed and any
incidents
should
be necessary repairs will be made with little to
accommodated in facility design. no interruption of operation of the Wind
The proposed boat slip and Farm. The operational safety of the Project
docking facility is within direct will be demonstrated as part of the Project
fall down distance of wind Sponsors application for a certificate
turbine generator (WTG) 10. pursuant to Section 68 of the PSL.
Catastrophic failure of WTG-10
could temporarily render ship
access problematic or infeasible.
Since the Project does not
propose to maintain a large lift
crane on the site permanently,
there will be limited availability
3-14

Hounsfield Wind Farm


Final Environmental Impact Statement

1.3-5

1.3-6

1.3-7

of equipment on the island to


remove major debris from the
dock landing area. This would
hinder recovery efforts by not
leaving clear access to the dock.
Source: DPS
The proposed backup power Turbine 53 was moved to mitigate against
system generation and diesel fuel this concern. It is now approximately 700
storage for the power system, feet from the substation and storage tanks.
comprised of three 6,000 gallon This is more than a 1.5 tip height setback for
storage tanks, are within direct this tower. No other turbines are within 650
fall down distance of WTG-53. feet of these systems.
Catastrophic failure of that
turbine could render backup
power supply unusable, and
possibly result in a fuel spill near
the potable water treatment and
fire protection system building.
Ignition of spilled fuel due to a
turbine fire and loss of backup
generation would render the fire
protection system inoperable.
Alternative arrangement
of
facilities should be seriously
considered, with isolation of
essential services and emergency
facilities from turbine fall down
zones.
Source: DPS
The proposed 230 kV substation The substation has been moved to the
site is within direct fall down northern end of the island, in the agricultural
zone of WTG-40. Catastrophic field near turbine 82. To accommodate this
failure of this turbine puts at risk location four turbines were slightly shifted
the entire generation output of to ensure at least a 1.5 tip height set back
the Project for an extended time from the substation and above ground
period, since clearing debris and transmission facilities, while maintaining
replacement of transformer or spacing between WTG. Additionally, a 1.1
other station equipment would setback from an underground transmission
be necessary prior to re- line has been incorporated into the project
energizing the system.
design and layout. See Figure 1.1-1.
Source: DPS
Electric transmission system The Article VII application filed on January
communication
facilities, 13, 2009 included a system of
including a redundant backup communication between the proposed
system, will be required between Galloo Island substation and the proposed
the proposed Galloo Island interconnection substation at the NYPA
substation, and the proposed transmission facilities. This communication
3-15

Hounsfield Wind Farm


Final Environmental Impact Statement

interconnection substation at the


New York Power Authority
(NYPA) transmission facilities.
The backup system may involve
facilities such as microwave
towers configured in a line-ofsight arrangement between the
two endpoints, with relay
facilities
at
intermediate
locations as appropriate to
maintain
continuity.
An
indication of the necessary
components at Galloo Island
related to transmission system
communications support should
be provided for consideration of
cumulative facilities impacts,
and in consideration of any
effect this may have on project
layout and arrangement.
Source: DPS

system consisted of a fiber optic cable


threaded through the overhead towers on
Galloo Island and on the mainland, bundled
within the 230 kV subaquatic and located in
a conduit within the underground cable.
In Tab 5 of its second supplement to the
1/13/09
application,
Upstate
Power
provided information on a redundant backup
for the communication system. The
redundant backup system will consist of a
second fiber optic cable threaded between
the overhead towers on Galloo Island and on
the mainland. While the preliminary design
of the Hounsfield Wind Farm contemplated
the installation of the first fiber optic cable
threaded through one of two static wire
positions on the tower, the second,
redundant fiber optic cable would replace
the second position being occupied by the
static wire.
To provide communication for the
subaquatic portion of the route, three
alternatives exist. One of these alternatives
consists of placing microwave towers at the
transition stations on Galloo Island and in
the Town of Henderson. These microwave
towers would be located within the fence
line of the transition station; however,
because of their height, they may yield
potential minor visual impacts. The second
alternative consists of bundling a second
fiber optic cable within the 230 kV
subaquatic transmission line. While the
design of this option has not been finalized,
it is likely that the impacts associated with
the addition of a second small diameter fiber
optic cable would be within the envelope of
impacts discussed in the Article VII
Application. The third alternative would
provide for the installation of four single
phase cables with at least two integral fiber
optic cables. This cable would be installed
within the same 400 foot proposed lakebed
corridor evaluated in the Article VII.

3-16

Hounsfield Wind Farm


Final Environmental Impact Statement

1.3-8

1.3-9

The proposed 230 kV electric


transmission facilities, including
the substation and transmission
line, are within direct fall down
distance of 13 wind turbine
generators, and two additional
turbines are proposed to be
located within 1.5 times the
WTG fall down distance. The
PSC has identified this distance
as a significant policy concern
regarding transmission system
reliability (see, Case O7-E-0213,
Sheldon Energy. Order Granting
Certificate
of
Public
Convenience and Necessity and
Providing
for
Lightened
Regulation, issued January 17,
2008). Catastrophic failure of
one turbine could remove the
entire project from operation for
extended
periods
while
substation or transmission line
components are repaired or
replaced. Serious consideration
should be given to alternative
arrangements,
including
reconfiguring substation site and
layout and co-location of the
proposed transmission facilities
along proposed access road in an
underground configuration.
Source: DPS
Alternative
arrangement
to
increase setback of turbines from
parcel 95-1-5, lands of New
York
State,
should
be
considered.
This
property
includes buildings and structures
potentially eligible for listing on
the State or National Register of
Historic Places.
Source: DPS

These alternatives will be evaluated further


in the Article VII process.
The substation has been moved to the
northern end of the island, in the agricultural
field near turbine 82. To accommodate this
location four turbines were shifted slightly
to ensure at least a 1.5 tip height set back
from the substation and above ground
transmission facilities, while maintaining
spacing between WTG. Additionally, a 1.1
setback from an underground transmission
line has been incorporated into the project
design and layout. See Figure 1.1-1.

The letter from SHPO dated June 23, 2009


determined that the Coast Guard Station on
Galloo Island is National Register Eligible.
However, the same letter states Given the
unique circumstances associated with this
portion of the project (turbine field
development) we see no reasonable way in
which the affects associated with the
construction of these units on Galloo Island
can be avoided or minimized through layout
alteration or unit number reduction.
Consistent with this finding, no alternative
3-17

Hounsfield Wind Farm


Final Environmental Impact Statement

1.3-10

1.3-11

1.3-12

1.3-13

Discussion at page 1-22 and 123 regarding electrical collection


system being located on wood
poles approximately 20 feet in
height under estimates the
necessary pole heights to achieve
clearances for access road
crossings and to generally
provide adequate elevations
above
ground
level
and
vegetation heights. Structures
supporting multiple 34.5 kV
collection lines are likely to be in
the range of 35 to 40 feet tall.
Source: DPS
DPS staff advises that poles
should
be
numbered
for
maintenance and operational
needs, as required by 16
NYCRR Part 217.
Source: DPS
The
EIS
should
contain
additional information regarding
the proposed wind turbines,
including
the
following
information:
Performance history of other
installed units;
Maintenance schedule;
Quality Assurance
procedures;
Certification of turbine and
blade configuration, with
details;
Results of accelerated
lifetime testing;
Lightning protection and
grounding requirements.
Source: DPS
Around the proposed substation,
the applicant will also need to
provide a clear zone free of
danger trees that could fall onto

arrangement of turbines has been analyzed


because it is unlikely to reduce visual
impacts.
The commenter is correct. Poles that carry
more than one 34.5 kV circuit may be more
than 20 feet tall. However, this does not
change the area that will be cleared for the
installation of the ECS.

Comment noted. Poles will be numbered as


part of the construction of the project.

This comment requests information not part


of the SEQRA Final Scoping Document for
the Project and is beyond the scope of the
EIS. Details regarding the WTGs proposed
for the Project will be provided as part of
the Project Sponsors application for a
certificate pursuant to Section 68 of the
PSL.

A clear zone of 45 feet will be required


around the substation. However, since the
substation will now be located in the
agricultural field, no additional clearing of

3-18

Hounsfield Wind Farm


Final Environmental Impact Statement

1.3-14

the station fence or electrical


equipment, to assure safety and
reliability of the station. The
substation site is estimated to be
1.3 acres within the fence. A
clearance zone approximately 45
feet wide around the fence
perimeter would increase the
effective footprint of the onisland substation to 2.2 acres,
rather than the 1.38 acres
reported in Table 1.2-1 at page
1-18 of the DEIS. Additional
equipment, including diesel-fired
back-up generator unit, fuel
supply, and communications
facilities,
are
likely
to
incrementally
increase
the
footprint of the substation site.
Site plan and layout information
should be updated as appropriate
to reflect the necessary station
equipment at the Galloo Island
site.
Source: DPS
Two Related Comments:

trees is required and therefore the footprint


of impact is unchanged.
Current plans do not include backup
generator within the substation fence. If
during the PSC review of the project during
the Article VII process this is required, it
would not significantly increase the
footprint of the substation. Additionally, the
revised location of the substation in an
agricultural field results in less of an impact
to forested areas on the island and a
potentially less sensitive habitat.
As stated in response to comment 1.3-7 the
design of the redundant communication
system has not been finalized and will be
resolved during the EMCP process. Any
increase to the footprint of the substation
from any of the options discussed above
would be minor and would not change the
ultimate findings and conclusions of the
EIS.

Comment 1 response: The applicant


undertook a further review of the design of
the electrical collection system. Based on
that review the applicant revised the ECS
layout and co-located significant portions of
the ECS. Where these changes would not
significantly lengthen the ECS route, the
lines were co-located with or placed
adjacent to the roads. The ECS was not
routed along the roads between WTG 69
and 76 because this would have
significantly increased the length and
potential impacts. Also in other locations
where the line was not co-located, such as
between WTGs 7 and 13, the line was
moved out of forested habitat and placed in
an open field habitat. These changes, along
with the relocation of the substation, have
decreased the impacts to forested areas by
12.78 acres.

Comment 1: Location of
electrical collection system
involves many sites where these
facilities are not co-located with
proposed turbine site access
roads. Review of detail figures
in Appendix J indicate that
several miles of electrical
collection lines will be located in
sites that will require forest
clearing, in many instances at
locations that will interrupt
habitat connectivity between
larger forest tracts and wetlands.
Maintenance of cleared zones
around overhead electrical lines
must be assured to avoid tree
induced contacts with electrical
conductors, thus there will be
continued
and
repeated Comment 2 response: The substation was
3-19

Hounsfield Wind Farm


Final Environmental Impact Statement

vegetation maintenance clearing


on the electrical system grid
throughout
the
island.
Consideration of an alternative
arrangement that maximizes the
use of cleared corridors through
facilities
co-location
is
appropriate
for
minimizing
forest fragmentation and wetland
impacts, and for enhancing
facility reliability by locating
components along roadways
where line clearances can be
readily observed.
Source: DPS

1.3-15

Comment 2: We recommend
that the transmission line be
routed around larger tracts of
forests, grasslands, and wetlands
to protect existing habitat value,
reduce
fragmentation,
and
maintain interior core areas.
Source: USFWS
The permanent meteorological
tower is proposed to be located
within the one large upland
meadow area on the island,
which appears to be relatively
free of invasive plant species.
Identification of an alternative
location for the met tower is
recommended,
to
preclude
repeated and ongoing access to
this site by project vehicles, as a
strategy to potentially slow the
spread of aggressive invasive
species to the last corner of
Galloo Island. Potential adverse
impacts to grassland nesting
birds would also be reduced by
avoiding this location. This
meadow is indicated at attached
Photograph 1.
Source: DPS

moved to the northern portion of the island.


This has reduced the length of the
transmission line by 11,534 linear feet and
has removed the line from forested areas
and wetlands.

The goal of the comment is consideration of


controls that will ensure that Project
construction or operational activities will
not contribute to the spread of invasive
species (pale swallow-wort) on the island.
However, this invasive species is already
prevalent throughout the island. While there
do appear to be a few remaining unaffected
areas, given that seeds from this species are
easily transported via air currents and
readily propagate, there can be no certainty
whether areas that presently appear
unaffected are indeed so or will not soon be
affected given the high mobility of this
invasive species Consequently, selective
siting of Project components is unlikely to
halt the spread of this highly invasive plant,
which, absent direct intervention, over time
is likely to cover the island whether the
Project is constructed or not.
Consequently the approach that the Project

3-20

Hounsfield Wind Farm


Final Environmental Impact Statement

Sponsor has proposed is to adopt best


management practices such as, washing
trucks and gear to ensure that construction
and operation activities do not transport pale
swallow-wort seeds from contaminated
areas to locations on the island that do not
appear to be contaminated. In addition in an
effort to stem and reverse the ongoing
spread of this invasive species throughout
the island, the Project Sponsor is committed
to maintain (through mechanical and/or
chemical methods) those areas that presently
appear to be unaffected so that they remain
free of pale swallow-wort, as well as reduce
the spread of the species in other areas (see,
Pale Swallow-wort Control Plan, Appendix
F).

1.3-16

It is conceivable that the project


could consist of fewer turbines.
Fewer turbines would mean less
impact to natural resources,
including less potential for bird
and bat mortality. We believe
that the project sponsor should
attempt to reduce potential
impacts to wildlife to the
greatest degree practicable.
Source: USFWS

Additionally, the meteorological tower must


be located in an area of the island that would
get a clear wind reading to accurately assess
wind speeds. Therefore, the met tower is
best sited at this location.
The DEIS evaluated six alternatives in a
resource-based analysis. These included the
no-build and preferred alternatives and four
other alternatives that were either smaller
projects or used less efficient technology.
As detailed in the DEIS even when the
number of turbines on Galloo Island were
reduced from 84 to 51, this significant
reductions in size did not result in
appreciable reductions to impacts on
wetlands, visual or noise impacts or impacts
on flora or fauna. However such reductions
would have significant and disproportionate
adverse impacts on the Projects goals and
benefits including: lowered production of
clean, renewable, carbon free energy from a
unique wind resource in New York; reduced
contribution to achieving New Yorks
energy and environmental policy goals and;
reduced contributions and benefits to the
health of the local economy. Therefore
these alternatives did not warrant further
consideration.
Also, in response to comments from the

3-21

Hounsfield Wind Farm


Final Environmental Impact Statement

1.3-17

1.3-18

1.3-19

Project staging and laydown


areas are described on page 1-18.
We note that over 9 acres of
forest habitat will be impacted
by these areas. No staging areas
are proposed in the disturbed
agricultural fields on the
northeast portion of the island.
Consideration should be given to
reducing impacts to higher
quality habitat, instead using
disturbed areas.
Source: USFWS

DPS and others addressing specific resource


concerns, an additional alternative layout
has been proposed which further minimize
the identified potential impacts while
preserving the Project Benefits outlined
above, through modifications in the siting of
turbines, ECS and the substation.
The laydown areas were located to be
central to the island. They were sited to
reduce the necessary travel on the island
during construction, which can potentially
impact animals on the island, the
centralization of these laydown areas will
also limit fuel use on the island.
The laydown areas were also sited as part of
the balancing of various concerns. This
balancing includes limiting the spread of the
invasive pale swallow-wort and wetland
impacts. The forested areas in which the
laydown areas are sited are not secondary
growth forest but rather scrub shrub forests,
which further minimizes their impact. The
laydown areas are temporary and will be
restored following construction. Based on
the type of vegetation present, it is
anticipated the functionality of the disturbed
habitat will return within 5 to 7 years.

However, layout changes to the ECS


described above have reduced the impact to
forested lands by 12.78 acres.
Further, we note that 35 turbines As stated in Section 1.12-3 of the FEIS and
are proposed in forest habitat in response to comment 1.1-14 the impacts
while only 8 are proposed in to forested areas have been reduced by
agricultural areas. A reduction 12.78 acres. It should be noted that that
in the number of turbines, along although approximately 66 acres of forested
with associated access roads and habitat will be impacted while only 15 acres
electric collection lines, placed of agricultural areas will be impacted there
in forest habitat is preferable.
are approximately 600 acres of forested
Source: USFWS
habitat and 168 acres of agricultural habitat
Therefore, about 11% of forested areas will
be impacted and 9% of the agricultural land
will be permanently impacted
Page 1-49 indicates that security Comment noted. This will be required and
lighting will be installed with included as part of the detailed design
lighting shielded in a downward drawings.
3-22

Hounsfield Wind Farm


Final Environmental Impact Statement

1.3-20

1.3-21

direction.
We support that
measure but also suggest that
motion sensors be placed on
outside
lighting
to
save
electricity and limit the amount
of time lights are on at night.
This will further reduce avian
attraction. Sodium vapor lights
should be avoided.
Source: USFWS
We
recommend
that
the
transmission line be routed
around larger tracts of forests,
grasslands, and wetlands to
protect existing habitat value,
reduce
fragmentation,
and
maintain interior core areas.
Source: USFWS

The transmission line has been significantly


reduced due to the relocation of the
substation. Additionally, the ECS has been
collocated in many locations with the roads
to reduce impacts to habitats. Because the
island consists of a mosaic of interspersed
habitat types with the majority of these
being wetland, grassland and forested areas,
it is not possible to avoid all these habitats.
In most cases routing around one habitat
type such as a forest, places the line in
another habitat including grassland or
wetland or increases the length of the ECS
route resulting in even more impact. Upstate
Power also tried to avoid placing the ECS
directly parallel to or within the ecotones or
edge habitats. As indicated in the Draft EIS
the habitats on the island are not unique or
pristine and are similar to habitats on the
mainland. The island has historically been
disturbed by agricultural activities, deer
management practices, clear cutting of cedar
forests and pervasive invasion by pale
swallow-wort.
Habitat
losses
and
fragmentation associated with the project are
not expected to adversely affect wildlife
populations.
Reference is made to a landfill As stated on page 1-44 of the DEIS there
on Page 2-33, but we saw no will not be any landfilling or permanent
other information for this type disposal of solid waste on the island. The
of facility.
If a landfill is landfill area stated on 2-33 refers to
proposed
on
the
island, temporary staging of debris prior to its
additional details on potential removal from the island. Due to the remote
wildlife impacts should be location of the island, debris removal from
provided.
the island will be scheduled for regular
Source: USFWS
removal and disposal at a regulated off-site
facility.
3-23

Hounsfield Wind Farm


Final Environmental Impact Statement

1.3-22

We do not believe that the


project design avoids wetlands
to
the
greatest
extent
practicable. Several roads and
electric lines can be moved to
avoid
wetlands
(between
Turbines 64 and 65/54 for
example). Also, the overhead
line between Turbines 71 and 77
could be moved to follow the
access road and avoid Wetland
F.
Source: USFWS

1.3-23

On Page 2-73, it is mentioned The substation has been moved to the


that the substation will be built northern end of the island, in the agricultural
within deciduous forest and field near WTG 82. To accommodate this
because there is no unique location, four turbines were shifted slightly
habitat or wildlife, an alternative to ensure at least a 1.5 tip height set back
location is not necessary. We from the substation and above ground
disagree with that statement. transmission facilities, while maintaining
An open field is located adjacent spacing between WTG. Where this setback
to the forested site where human could not be met, ECS will be located
disturbance, such as deer underground and a 1.1 setback from the
feeding stations and trails are underground transmission line is proposed.
found. We believe this would See Figure 1.1-1.
be a more appropriate location
and reduce the need for forest
clearing.
Source: USFWS
Wetlands and open water often The commenter does not indicate which
attract
concentrations
of specific areas on the island are important
waterfowl, but we did not find for wildlife. As identified in the DEIS and
information in the report which FEIS, each habitat located on the island
recommends removing turbines provides some value to various wildlife
near these areas (only placement species. With regard to wetland habitats and
outside of these habitats). avian species, the project design has
Movement or elimination of minimized impacts to wetlands to the extent
these turbines from bird practicable per the balancing required by
concentration areas or species of SEQRA. The avian studies did not identify
concern habitat could reduce the any greater risk to avian species associated
collision risk. We recommend with impacts to wetland habitat.
that the project sponsor reduce
the project size by removing
turbines, particularly those
located near areas identified as
3-24

1.3-24

The overhead line between WTGs 71 and 77


has been relocated to follow the road which
avoided impacts to Wetland F. The road
between turbines 64 and 65/54 has not been
relocated. Removing this road would limit
access to the access road between WTGs 38
and 37. This would significantly increase
the distance that would need to be traveled to
reach these towers. Travel along roads could
potentially impact some mammals and
reptiles. Additionally, the wetland is crossed
at the narrowest point and the hydrology of
the wetland complex would not be
negatively impacted.

Hounsfield Wind Farm


Final Environmental Impact Statement

1.3-25

1.3-26

important for wildlife.


Source: USFWS
Based on habitat information
and
the
wildlife
studies
completed to date, it seems to us
that placing turbines in certain
areas may pose more a risk. For
example, during our site visit,
we noted that concentrations of
birds
(cormorants,
gulls,
waterfowl) were found basking
on the eastern tip of Galloo
Island where Turbine 80 is
proposed.
Surveys noted
numerous species of shorebirds
attracted to the beach area
adjacent to Turbine 1.
Source: USFWS

The DEIS, including appendices, did


indicate that most waterfowl flight activity
was over the water along the east end of the
island (Winter Bird Survey, Appendix P) but
that very few were in transit over the island.
Shorebirds were also observed at the east
end of the island in September 2008. The
avian risk analysis for the Project concludes
that while risk of shorebird collision with
wind turbines would be greater on Galloo
Island than inland sites like Maple Ridge, it
would be lower than alternative coastal sites
along the primary shoreline of Lake Ontario
and the only shorebird species found in
baseline studies to be flying in the rotor
swept zone (RSZ) was the Greater
Yellowlegs. In addition relatively little
waterfowl activity was noted in the RSZ and
the risk analysis does not demonstrate
potential for high losses. Overall, losses of
waterfowl and shorebirds are expected to be
low.
Comment noted. The applicant has agreed
to two of these recommendations, safe
harbor and control of pale swallow-wort.
See sections 2.2 and 2.5.1 of the FEIS for
additional information.

DEIS Appendix G, Operations


and
Management
Plan,
identifies
a
number
of
environmental factors to be
considered
during
the
operational life of the facility,
including
restoration,
maintenance,
repairs,
decommissioning,
spill
management, wetland mitigation
management, invasive species
management,
and
ice
management. DEC typically
recommends that all wind
projects consider creation of
additional
environmental
enhancements during the life of
the project beyond those
required for restoration and
mitigation, through cooperative
partnerships with landowners,
local governments, educational
and conservation organizations.
3-25

Hounsfield Wind Farm


Final Environmental Impact Statement

Comment
#
1.4-1

1.4-2

The Galloo Island project is


unique in that the entire project
development area will be under
the control of the project
sponsor and, being a resource
identified as worthy of attention
in the Open Space Conservation
Plan, provides an unparalleled
opportunity for a cooperative
arrangement between the project
sponsor and DEC in the
development of management
plans for the island that
accomplish the objectives of the
project
sponsor,
promote
activities consistent with the
Open Space Plan, and further
the
resource
management
objectives of the Department.
These may include invasive
species
management
and
control,
grassland/forest
management
for
wildlife
conservation, and limited public
access
for
safe
harbor,
educational or recreational
purposes. DEC will continue
discussions with the project
sponsor to identify specific
opportunities for cooperative
management, and will include a
commitment to engage in this
process as a condition to permits
issued for project construction.
Source: DEC
Topic: Construction
Comments

Responses

Specific procedures should be The temporary dock and groin will be


identified that provide for the removed upon completion and operation of
removal of the proposed the permanent inlet slip and off-loading
temporary dock and groin and facility. Procedures for their removal will be
established time frames should included in the final design of docking
be proposed.
facilities.
Source: DOS
The applicant's analysis of Comment Noted. The reference to the slip
coastal policy states that being located to a depth of 14 feet below
3-26

Hounsfield Wind Farm


Final Environmental Impact Statement

1.4-3

1.4-4

excavation of the entrance water datum is incorrect. The correct depth


channel would be to a depth of of the entrance channel will be 14 feet below
14 feet below ordinary high ordinary low water mark. This does not
water, However, the document change any of the impact analysis in the
also makes reference to ordinary document.
low water as the applicable
datum. These discrepancies
should be addressed.
Source: DOS
Approximately 600 cubic yards The 17.01 miles of service roads will be
of rock will be removed for each approximately 38 feet wide with 12 to 6
foundation and it is unclear to us inches of rock or gravel on top. The
where this quantity of rock (over construction of these roads will utilize the
50,000 cubic yards in total) will material that will be removed for the
be disposed of if it is not used to foundations.
make concrete.
Source: USFWS
Instead of using culverts to cross The wetlands on Galloo Island are
wetlands, the project sponsor characterized by thin soil layers and shallow
proposes to use rock placed bedrock (See Appendix E -Mitigation).
within the wetland. We do not Also, none of the Island wetlands that will be
support this plan for a number crossed by roadways exhibit high flow rates,
of reasons. First, the rock may high rates of sedimentation or erosion. The
limit water movement when Project incorporates use of large permeable
compacted. Second, the rock granular fill that will be placed nearly flush
tends to trap sediment which can with grade to allow for circulation and water
also limit water movement. If flow. Based on the geological conditions in
heavy loads of sediment are the area and the design criteria, impacts on
present, it can become labor groundwater and surface flow in the
intensive and expensive to wetlands are not anticipated. The stone fill
maintain the crossing. During will be a minimum of 6-inches and more
high flow events, the rock can permeable than the wetland soils that already
become dislodged and move. exist in the wetland crossing areas. Where
Hard surfaces can cause erosion needed, areas adjacent to the roadway will be
in areas adjacent to where the vegetated at the downslope side of the road.
rock is placed. Further, the rock During final design and location of road
will limit nutrient uptake and crossings, Upstate Power will consider the
vegetation growth (although this placement of bottomless culverts in areas
could also be true for culverts). observed to show any substantial surface
Rock
crossings
are
not flow characteristics or ponding.
recommended in wetlands by
the
Natural
Resources
Conservation
Service.
Therefore, we recommend the
project sponsor review the
current design and, where
necessary,
replace
rock
3-27

Hounsfield Wind Farm


Final Environmental Impact Statement

1.4-5

1.4-6

1.4-7

crossings
with
bottomless
culverts.
Source: USFWS
We are concerned with language
on Page 1-46 in that it is vague
and
does
not
make
commitments to protect the
environment. For example, the
text states that mitigation for
temporary wetland impacts will
likely consist of restoring
disturbed areas as close as
possible to preconstruction
conditions.
A commitment
should be state that disturbed
areas will be restored to original
conditions.
Source: USFWS
Text on Page 1-46 also indicates
that several roads will be
constructed flush with the
surrounding grade to minimize
interruption of surface flow.
However, several portions of the
document discuss dumping
stone to create gravel access
roads. A flush surface will not
be created by dumping stone on
the ground; however, it would
cause a blockage to surface
water flow.
Source: USFWS

Requirements to return the area to


preconstruction conditions, as well as other
conditions of approval of the project will be
contained in both the findings statement for
the project and permits. The DEIS proposed
mitigations that the project sponsor felt
would offset or eliminate any negative
impacts form the project. During the review
of the EIS and the permit applications,
mitigations will be enforced by the various
agencies that have permit authority.

Roads will cross both wetland and upland


areas.
Within the wetland areas clean
crushed stone will be placed on non-woven
geotextile materials and the ends will be
wrapped. Then 6-inch minimum sized rock
will be placed on top forming a very
permeable layer. Elevations will be kept as
close to the wetland surface as possible. In
other areas the roads will be constructed to
be flush with grade to have a minimal impact
on post-construction flow paths. In cases
where shallow soils do not allow the full
thickness of the road to be flush with grade,
the road will be built above grade. Where the
road is bearing directly upon bedrock, the
road thickness will be reduced to a minimum
of 6-inches. Roads are designed to not
impede flow in both wetland areas and in
regard to overland flow at upland sites. For
instance, for those roads above grade,
surface water runoff will flow with the slope
of the land along the upslope side of the
road. It will be conveyed to the point at
which the road is again flush with grade,
where it will flow over the road to the
downslope side. Please also see response to
comment 1.4-5 regarding the permeability of
stone fill material.
On page 1-47 of this section, it Comment noted.
3-28

Hounsfield Wind Farm


Final Environmental Impact Statement

Comment
#
1.6-1

1.6-2

is stated, Upon completion of


the Statement of Findings and
environmental permitting, the
relevant conditions and best
management
practices
pertaining to construction and
restoration will be incorporated
into the final EMP. DEC will
include, as a condition of
permits issued by the agency,
submission
of
a
Final
Environmental Monitoring Plan
that includes all relevant
conditions and best management
practices
pertaining
to
construction and restoration
contained within the SEQR
Findings Statement and permits
and approvals from all involved
agencies. This condition will
require submission of the final
EMP within 30 days of project
commencement.
Source: DEC
Topic: Permits and Approvals
Comments
The consultation record on Table
1.-2 is out of date and should be
updated after May 2008.
Source: USFWS

Other statutes under our


jurisdiction, in additional to
those listed on Page 1-59,
include the MBTA and BGEPA.
The text should be revised to
reflect these laws.
Source: USFWS

Responses

Table 1.6-2: Agency Consultation reflected


the formal consultation conducted as part
of preparing the Draft EIS. Key agency
correspondence since the DEIS was
completed in February 2009 is included in
Appendix Q of this FEIS.
As discussed under the heading of
Coordination with the NEPA Process, the
project is subject to Migratory Bird treaty
Act (MBTA) and Bald and Golden Eagle
Act (BGEPA). The text on page 1-59
related to U.S. Fish and Wildlife Service
jurisdiction should read as follows:

and review by the U.S. Fish and Wildlife


Service under the Fish and Wildlife
Coordination Act, the Endangered Species
Act, the Migratory Bird Treaty Act and the
Bald and Golden Eagle Protection Act.
Topic: Ownership
3-29

Hounsfield Wind Farm


Final Environmental Impact Statement

Comment
#
1.7-1

1.7-2

Comments

Responses

Figure 1.2-1, Project Layout, Comment Noted.


Project components
shows Turbine # 1 and the previously proposed for this location have
associated
access
road/ been relocated off of the State land.
interconnect located on a parcel
of land owned by DEC. There is
a reversionary clause regarding
this parcel in the State's deed
from the United States of
America to DEC (1234/283).
This deed states that the property
is to be continuously used by
NYS only for the conservation of
wildlife, other than migratory
birds, and is conveyed upon the
condition that in the event it is
no longer used for such
purposes, or in the event it is
used for any purpose that is not
compatible with the use and
maintenance of the property and
for conservation of wildlife, the
title shall automatically and
immediately revert to the United
States, etc. Any uses of the DEC
lands on Galloo Island for the
wind project would not be for
wildlife conservation purposes
and therefore would not be
consistent with the terms of the
deed.
Source: DEC
The statement on DEIS page 2- The
Commenters
point
regarding
63, Galloo Island is privately ownership is noted; the text on page 2-63
owned and not currently should read:
accessible by the public, should The majority of Galloo Island (~1,938
be corrected. While most of the acres) is privately owned. Public lands are
island is under single ownership, not currently accessible without permission
there is one private parcel and access over private lands.
(containing the lighthouse), one Text starting on DEIS page 2-9 provides a
small parcel owned by the U.S. complete description of all the parcels on
Coast Guard, and two parcels Galloo Island. The U.S. Coast Guard
owned by DEC (one including Property is depicted on DEIS Figure 1.2-3,
the former Coast Guard station). however due to the scale of the map and
DEIS Figure 1.2-3 shows the parcels small size (<1 acre), this parcel
existing land use, including is not clearly visible. Figure 3.0-1 shows
3-30

Hounsfield Wind Farm


Final Environmental Impact Statement

Comment
#
2.1-1

current ownership. Not identified the ownership information as available


on this map is the small U.S. from the Jefferson County tax records:
Coast Guard property (located Owner: United States of America
just north of proposed Turbine # Parcel ID: 95.00-1-7.
71). Also shown on this map is a
small parcel and island adjacent It is also important to note that New York
to North Pond owned by the Upstate Power has an option with the
Galloo Island Corporation, with landowner to purchase the lighthouse
no proposed improvements. Will parcel which is currently in private
this parcel remain under current ownership.
ownership or will it be purchased
as part of the project? This figure At this time there are no additional plans
should be revised to more for parcel adjacent to North Pond, however
completely describe the current this parcel will remain part of the Upstate
ownership of properties on the NY Power Corporations purchase of the
island.
island property.
Source: DEC
Topic: Topography, Geology and Soils
Comments
Responses
This section states, Limestone
is subject to dissolution by acidic
groundwater along bedding
planes, fractures, joints and
faults. While no limestone
(karst) hazards are mapped on
Galloo Island, the Trenton Group
is comprised of carbonate rocks
that are susceptible to dissolution
and
sinkhole
formation,
especially with joint and
fractures common in limestone
(DEIS page 2-2). Geotechnical
investigations performed prior to
construction start should include
identification of karst features,
and the Draft Erosion and
Sediment Control Plan (DEIS
Appendix D) and the Conceptual
Spill, Prevention, Control and
Countermeasures Plan (DEIS
Appendix E), should be revised
to include measures to prevent
discharge
of
stormwater,
sediment
and
construction/operation chemicals

As stated in the DEIS there are no known


karst hazards on Galloo Island. During
the
preconstruction
geotechnical
investigations any karst hazards proximate
to any areas of land disturbance will be
mapped
prior
to
construction.
Additionally, the Spill, Prevention,
Control and Countermeasures Plan have
been updated to include measures to
prevent runoff including to potential karst
features. These measures will be included
in the Stormwater Pollution Prevention
Plan prepared in accordance with the
SPDES General Permit for Stormwater
Discharges from Construction Activity GP-0-08-001, which will be submitted to
DEC for review and authorization prior to
construction start.

3-31

Hounsfield Wind Farm


Final Environmental Impact Statement

Comment
#
2.2-1

into karst inlets, in addition to


surface waters and wetlands.
Source: NYSDEC
Topic: Land Use
Comments
The
proposed
project
components do not conform to
Town of Hounsfield zoning
regulations. Permanent housing
facilities as proposed do not
conform
to
local
zoning
restrictions. Absent a local wind
energy zoning resolution, it
appears that the code allows for
a planned development use,
which allows for waivers of code
restrictions as appropriate.
Source: DPS

Responses

The determination of whether the Project


is consistent with the Town of Hounsfield
Zoning Law, as amended last by Local
Law 1 of 2008, is solely within the
jurisdiction of the Town of Hounsfield.
The Town of Hounsfield Planning Board
views this proposed Project in its entirety
as an Essential Service as that term is
defined in its Zoning Law.
The
fundamental land use of the Project s a
publicly regulated utility generating
electricity for public sale and use. The
following is a list of uses or structures
which under the Towns Zoning
definitions are either accessory uses or
structures to the generation, collection and
transmission of electricity:
1. Helipad
2. Temporary and permanent docking
facilities
3. Seasonal and permanent housing
buildings
4. Water supply, storage, treatment
and distribution
5. Sanitary septic collection and
treatment
6. Community
Building
with
infirmary
7. Various storage and maintenance
buildings
8. Stone quarry
9. Temporary concrete batch plant
10. Initial and emergency backup
generators
11. Fuel Storage and dispensing
facilities
12. Private roads.
All the foregoing will be reviewed as

3-32

Hounsfield Wind Farm


Final Environmental Impact Statement

2.2-2

The development layout would


render the existing small aircraft
takeoff and landing strip
unusable. The Environmental
Impact Statement (EIS) should
give consideration of an
alternative facility layout to
enable continued use of the
airstrip
as
a
private
transportation facility, with
potential for use in emergency
situations.
Source: DPS

2.2-3

The parcel of New York State


land at the southwestern end of
Galloo Island is indicated in a
database maintained by NYS
Department of Environmental
Conservation (DEC) as "Wildlife
Management" category. The
former U.S. Coast Guard
(USCG) property owned by
NYS DEC is categorized as
"Land Access - Safe Harbor for
Boats." The EIS should consider
in greater detail the compatibility
of the proposed development and
intensity of land use with the
designated uses of lands owned
by the State of New York.
Source: DPS

accessory uses or structures by the Town


Planning Board as past of the Sire Plan
Review Process required for the Essential
Service of an electrical generation facility
by a regulated utility in the Marine
Residential District. Under the Town
Zoning Law a Planned Development
District is not needed under the Towns
current Zoning Law for this project.
The inclusion of an airstrip on Galloo
Island is not proposed by the project
sponsor.
Instead the project sponsor
proposes the use of helicopter, this will
allow for emergency evacuations. The
removal of the airstrip is not an
environmental concern but a project
design and liability consideration.
It
should be further noted that the airstrip
configuration is not best suited for the
prevailing wind direction on the island,
and often causes the small planes to land
or take off in a cross-wind direction,
which limits its current use. The Project
Sponsor has determined that the use of a
helicopter is safer and more reliable in this
particular situation.
The development of the Hounsfield Wind
Farm will not have any impact on the
intensity of land use based on the current
designation of the former USCG station as
Land Access Safe Harbor for Boats.
Nothing about the wind farm will change
the designation. There is currently little to
no use of this facility. The docking
facilities at this parcel are not stable and
the upland portion of the property is
fenced off. The intensity of use of this
parcel can be considered very low. To
help relive the safe harbor concern for
boaters the Project Sponsor has agreed to
allow safe harbor use of Gill Harbor and
the North Pond area during construction
and operation.

The parcel at the southwestern end of


Galloo Island is categorized as wildlife
management. Due to the remote location
3-33

Hounsfield Wind Farm


Final Environmental Impact Statement

2.2-4

of the parcel, there is little active


management of this land and the intensity
of use is very low. The Project Sponsor
has indicated a desire to locate a wind
turbine on this land and evaluated it as
part of the DEIS, to analyze the maximum
potential layout. Based on comments
received from DEC, the turbine and
associated infrastructure proposed for this
parcel have been removed from the
project. The avian and bat resource
investigations have indicated that there are
potential impacts to birds and bats from
the operation of the wind farm. These
impacts are not anticipated to be
significant, however they will be verified
by post-construction avian/bat mortality
monitoring required as a condition of DEC
permits.
The Project Sponsor has agreed to allow
Three Related Comments:
safe harbor use of the island at both Gill
Comment 1: Continued access Harbor and the North Pond. No public
to Gill Harbor for safe harbor access is planned for the privately owned
shelter should be accommodated portions of Galloo Island.
in facility design and operation,
and as a requirement in
permitting as a public interest
issue.
Source: DPS
Comment 2: Potential publicaccess
and
water-related
recreational opportunities that
are compatible with the proposed
activity should be identified and
considered. These may include
providing areas of safe harbor as
identified at the May 18, 2009
public hearing, public docking
facilities to encourage (sic)
Source: DOS
Comment 3: I would like to see
mitigation on the Coast Guard
station to upgrade for public use
with this if this project was to
go forward, as a safe harbor.
3-34

Hounsfield Wind Farm


Final Environmental Impact Statement

2.2-5

And for public use to utilize the


property that the Department
owns on the head of the island
around the lighthouse.
Source: Mitch Franz (H)
In both the 2006 and 2009 versions of the
Two Related Comments:
Open Space Plan Galloo Island is
Comment 1: The DEIS states (at mentioned in the Region 6, 7, 8 & 9
page 2.62) that Galloo Island has Priority Projects, Great Lakes Shoreline
been identified by the New York and Niagara River. The 2009 Plan states
State Open Space Conservation Galloo Island, the largest undeveloped
Plan as part of the Great Lakes island in Lake Ontario measuring
Shoreline and Niagara River approximately 3 miles by 1 mile or
priority conservation project 1,934 acres is just one of the undeveloped
area. The EIS should evaluate islands worthy of attention. The goals of
how development of the the 2009 New York's Open Space
proposed project is consistent Conservation plan are:
with the goals, objectives and
To protect habitat for the diversity of
details of the Plan.
plant and animal species in order to
Source: DPS
ensure the protection of healthy,
viable and sustainable ecosystems.
Comment 2: On page 2-62 of
To protect our State's water quality,
the DEIS, it states, Galloo
including surface and underground
Island has been identified in the
drinking water supplies, lakes,
New York State Open Space
streams and coastal and estuarine
Plan as a part of the Great Lakes
waters needed to sustain human life
Shorelines and Niagara River
and aquatic ecosystems.
priority conservation project
To combat global climate change by
area. (NYSDEC et. al., 2006).
encouraging more compact
The 2009 New York State Open
community design patterns.
Space
Conservation
Plan,
To combat global climate change by
released June 2009, continues to
sustainable stewardship of our
list Galloo Island as an important
State's forests for carbon
natural resource. On page 102 of
sequestration and air quality
the Plan, it states, Galloo
enhancement.
Island, the largest undeveloped
To combat climate change by
island
in
Lake
Ontario
protecting our State's coastlines, and
measuring approximately 3
broad riparian corridors and
miles by 1 mile or 1,934 acres
wetlands.
is just one of the undeveloped
To combat global climate change by
islands worthy of attention.
adding to the tree canopy in our
DEC has in the past expressed
urban centers and urban
interest in acquisition of Galloo
communities in order to moderate
Island but was not able to
temperature fluctuations, thereby
negotiate terms sufficient to
lowering our energy consumption.
carry out this plan. Nonetheless,
To maintain an interconnected
DEC continues to hold interest in
3-35

Hounsfield Wind Farm


Final Environmental Impact Statement

exploring
opportunities
for
wildlife conservation, public use
and access of existing state lands
on Galloo Island consistent with
the management objectives of
those properties, and other
opportunities that may be
available
for
overall
management of the island
consistent with the Open Space
Conservation Plan.
Source: DEC

network of protected lands and


waters allowing wildlife to be able
to shift range with climate change to
follow natural migration patterns.
To improve quality of life and overall
health in our States communities,
especially those with limited current
access to open space.
To maintain critical natural resource
industries such as farming, forest
products, commercial fishing and
tourism.
To protect habitat to sustain the
traditional pastimes of hunting,
fishing, trapping and wildlife
viewing.
To provide accessible, quality outdoor
recreation and open space to all New
Yorkers.
To provide places for education and
research relating to ecological,
environmental and cultural
resources.
To protect and enhance scenic, historic
and cultural resources considered to
be valued parts of the common
heritage of our State's citizens.
The project will not have a significant
negative impact on any of the resources
associated with the goals of the Open
Space Plan and in fact is consistent with
many of the Plans goals. For example,
one of the primary strategies of the Plan is
to combat global climate change which is
one of the many benefits of developing an
electric generating facility using wind
power. In addition, the use of the property
as a wind farm allows for the continued
use of the property for sustaining habitat
that could otherwise be destroyed by other
forms of development.
The project
sponsor has additionally committed to an
invasive species control program with the
goal of reducing the areal coverage of pale
swallow-wort in open areas and forest

3-36

Hounsfield Wind Farm


Final Environmental Impact Statement

2.2-6

2.2-7

2.2-8

2.2-9

understory areas on the island by 20% per


year over five years.
This larger
management plan has the potential to
improve habitat on the island for alvar and
grassland species, including grassland bird
species, however use of this improved
habitat by grassland bird species will need
to be monitored by the post-construction
study to determine if grassland bird
species exhibit avoidance behavior due to
the presence of turbines.
The Project Sponsor has indicated there
are no plans for the Nature Conservancy to
have a role in the operation of Galloo
Island.

I have heard that the Nature


Conservancy will have a role in
the stewardship of the island's
environmental resources. This
would be a positive action. This
arrangement could provide for
public access to the island.
Source: Jan Maas
Upon decommissioning of the The Project Sponsor will own Galloo
wind farm project in the distant Island during the operation of the Wind
future, it would be a benefit to Farm and after decommissioning. Future
have the island become a use of the island has not been determined.
regional park run by the
Conservancy or a State Agency,
such as the Office of Parks
Recreation
and
Historic
Preservation or the Department
of Environmental Conservation.
Source: Jan Maas
Galloo Island has long been Comment noted: The 2009, as well as the
listed as a priority protection 2006, New York Open Space Plan states
project in the "New York State that Galloo Island, the largest
Open Space Plan", including the undeveloped island in Lake Ontario
latest 2006 Plan version and the measuring approximately 3 miles by 1
new draft plan currently being mile or 1,934 acres is just one of the
developed.
undeveloped islands worthy of attention.
Source: Thomas Brown
See response to 2.2-5 above.
Galloo Island has long been Comment Noted and see response to 2.2-5
recognized by the NYSDEC as a above.
scarce Lake Ontario island in
need of protection and open
space preservation.
Lake
Ontario islands are considered
critical natural resources largely
due to their lake wide scarcity.
Source: Thomas Brown
3-37

Hounsfield Wind Farm


Final Environmental Impact Statement

2.2-10

2.2-11

2.2-12

2.2-13

A number of years ago the State Public access has not been available at
gained limited public access to Galloo Island. Although, the State owns
the island when it acquired the and controls property on the island the
former Galloo Island Coast only available functioning dock facility is
Guard station. The State in on private land. This limits the ability of
recent years has attempted to the state and public to access Galloo
purchase the entire island.
Island.
Source: Thomas Brown
The DEIS should recognize that Comment noted.
The designation of
the State-owned portions of portions of Galloo Island as part of the
Galloo Island, not just Little Lake Ontario Bird Conservation Area does
Galloo, are included within the not change the results or findings of any of
Lake Ontario Islands Bird the natural resource investigations.
Conservation Area.
Source: OPRHP
Boaters Destination Park - The The Project Sponsor has indicated that
harbor utilized for the temporary public access would not be allowed on
construction
village
could Galloo Island. The Project Sponsor has
become a park for access of agreed to allow for safe harbor use of Gill
boaters from throughout the Harbor and North Pond. The arrangement
region
(Sackets
Harbor, allowing for fish bakes may also continue,
Henderson Harbor, Dexter, however this is at the sole discretion of the
Chaumont, and Cape Vincent). Project Sponsor.
Unlike the Thousand Island
region with its abundance of
State and provincial island parks,
there is no off-shore destination
in the Eastern Bays of Lake
accessible to the public.
If
dockage were provided as well
as amenities, such as picnic
areas, walking trails and rental
cottages, this development could
provide recreational, tourism and
economic benefits to the town of
Hounsfield.
Source: Jan Maas
Reuse of temporary workers The Project Sponsor has indicated that the
cottages - At the end of the workers cottages would be removed from
construction phase of the project the island and the end of construction and
most
of
the
housing not donated to the State.
infrastructure is slated to be
removed for the island. The
potential for reusing some of
these small cottages at regional
parks in the area, such as Robert
Wehle State Park and Westcotts
3-38

Hounsfield Wind Farm


Final Environmental Impact Statement

2.2-14

Comment
#
2.3-1

Comment
#
2.4.1-1

Beach State Park could be


beneficial if donated by the
project sponsor.
Source: Jan Maas
Reuse of temporary Community The Project Sponsor has indicated that
Center - At the end of the public access would not be allowed on
construction phase of the project Galloo Island.
the community center could be
reused as an interpretive center
for the visiting public. The
project sponsor could interpret
the story of wind power, as well
as the island story.
Source: Jan Maas
Topic: Agricultural Resources
Comments
Responses
The DEIS indicated that up to Comment Noted. There are no plans to
168 acres of the island has been continue any agricultural use of Galloo
used for agriculture.
It is Island during the operation of the
important to note that large Hounsfield Wind Farm.
numbers of gulls have been
observed feeding in these areas.
However, the report also
indicates
that
agricultural
practices will be halted upon
project construction but available
for future use.
Given that
productive agriculture can attract
some birds in large numbers, we
recommend against planting
crops which attract birds to the
island. This will avoid attracting
wildlife to an area with turbines.
Source: USFWS
Topic: Surface Water
Comments
Responses
Appropriate best management
practices and procedures should
be identified that will control
stormwater runoff and associated
non-point source pollutants
reaching Lake Ontario during the
construction and operation of the
proposed facility. Additionally,

The owner/permittee is required to obtain


coverage under the SPDES General Permit
for
Stormwater
Discharges
From
Construction Activity prior to commencing
construction. As part of this permit, the
permittee is required to develop and
implement a Stormwater Pollution
Prevention Plan (SWPPP) that describes

3-39

Hounsfield Wind Farm


Final Environmental Impact Statement

all point source discharges


should be treated in a manner
consistent with current state
regulations. These discharges
should not effect any current or
proposed potable water supplies.
Source: DOS

2.4.1-2

Permanent
road
crossings
through streams and wetlands
are described in Page 1-43. It is
anticipated that four wetland
crossings and no stream crossing
will be required. However, we
noted the presence of multiple
channels
which
may
be
intermittent or ephemeral.
Source: USFWS

the erosion and sediment control practices


and
post-construction
stormwater
management practices that will be used
and/or constructed to reduce the pollutants
in stormwater discharges and to assure
compliance with the terms and conditions
of this permit. It is a violation of the
general permit and the Environmental
Conservation Law for any discharge to
either cause or contribute to a violation of
the water quality standards as contained in
Parts 700 through 705 of Title 6 of the
Official Compilation of Codes, Rules and
Regulations of the State of the State of
New York.
The sanitary system outflow will conform
to State established standards, as detailed in
the SPDES permit for a point source
discharge.
The permit will establish
criteria for both effluent limits and testing
standards following the construction of the
wastewater treatment system. The point
source discharge will be located a
sufficient distance from the proposed
potable water intake and will be located
downstream of the long-shore current along
the island.
The DEIS listed streams either shown on
USGS maps or those listed and identified
on the NYSDEC stream mapping system.
The DEIS did indicate on page 1-42 that
the mapped tributary on the south side of
the island would be crossed using a culvert.
This stream has some intermittent and/or
ephemeral channels within a forested
wetland located inland of the crossing site.
However, there are no road crossings above
the main stem of the mapped stream (Ont.
Galloo Island 1). During field work
conducted for the wetland and waterway
delineations, two drainage ditches were
identified. However, these ditches did not
have bed and banks and are therefore not
considered jurisdictional streams under
Corps of Engineers definitions. The JD
received from the Corps of Engineers

3-40

Hounsfield Wind Farm


Final Environmental Impact Statement

agrees with this determination that only


one actual stream exists on the island.
The bathymetry report prepared for the
Project (DEIS, Appendix K), demonstrates
that the sites of the vessel slip (offloading
facility) and water intake/discharge
structures consist predominantly of
bedrock with almost no overlying
sediment.
Additionally, the blasting
technique calls for placing the charges in
holes drilled into the bedrock and covering
with sufficient angular stemming materials.
This confines the blast impact. Therefore
only thin veneers of sediment in small
depressions in the bottom could potentially
be resuspended. Even though the expected
amount of turbidity is low, Upstate Power
will employ use of a silt screen system as
shown in the joint permit application to the
NYSDEC and USACE. The system will
consist of a floating turbidity barrier in
Lake Ontario that will surround the
excavation area. It will consist of a floating
curtain that is set with piles or anchors to
the bottom.
The slip will be constructed within rockfaced shoreline which is resistant to erosion
from boat wakes.
The slip will be
surrounded by 100 foot concrete aprons.
The dock at Gill Harbor will receive
similar boat traffic volume and type to
current operations and therefore there will
be no impact. The Stormwater Pollution
Prevention Plan for project proposes
measures to protect ensure runoff does not
impact Lake Ontario.

2.4.1-3

Work within Lake Ontario


includes blasting and dredging to
create a vessel slip.
We
recommend that silt curtains be
required to contain turbidity and
protect water quality in the work
areas.
Source: USFWS

2.4.1-4

Approximately 650 large boat


trips, 216 large boat trips, 51
small boat trips, and the arrival
of mechanized landing craft on
another
41
trips
during
construction, will result in
impacts to shoreline areas and
water quality. Slip and dock
areas should be monitored
regularly for erosion during the
construction
period
and
corrective measures taken if
necessary.
Source: USFWS
The report indicates a de The Conceptual Spill Prevention Control
minimus amount of fluids could and Countermeasures Plan (Appendix E of
leak
from
vehicles
and the DEIS) identified leak or failure of oil
equipment, but does not consider containment within the nacelle as a
hazardous fluids in turbine potential source of contamination. The
nacelles or transformers. This maximum discharge was identified as 66
should be addressed in this gallons. A land-based spill response kit
section.
would be used to contain any leak. As
3-41

2.4.1-5

Hounsfield Wind Farm


Final Environmental Impact Statement

Source: USFWS

Comment
#
2.4.2-1

2.4.2-2

stated in the SPCCC In the unlikely event


that a turbine had a release of the entire 66
gallons of oil stored in the equipment, the
oil would flow overland for a relatively
short distance and would be absorbed into
the soils on site or immediately
downgradient of the site. Therefore, there
is little to no risk of impacts to surface
water from a leak in the nacelle.
Topic: Marine Sediment
Comments
Responses

Lake sediments are described on


Page 2-36 and testing indicates that
of 17 samples, 10 had no
appreciable contamination, but the
other samples had moderate
contamination. The DEIS should
provide a better summary of the
sampling results and do a more
thorough evaluation of the potential
contaminants that may occur in
proposed disturbed areas. This
should include a more in-depth
analysis of the potential impacts to
fish and wildlife.
Source: USFWS

As stated in the DEIS on page 2-34 and


as discussed in the Bathymetry Report
attached as Appendix A to the DEIS,
there is very little to no sediment in the
proposed disturbed areas for the portion
of the Project being reviewed pursuant
to the EIS. The areas where some
sediment
exists
and
sediment
contaminants were identified are along
the proposed transmission line route.
The evaluation of the potential
contaminants that may occur areas along
the transmission line are described in
Appendix G of the Article VII
Application which is under review by
the New York Department of Public
Service in the Article VII process.
On page 2-42 of this subsection it Comment noted.
This will be a
cites: As discussed in Section condition of the Article 15 permit that
2.5.5, Blasting, in water blasting will be issued for the project.
work will be limited to avoid
sensitive fish spawning dates. No
project construction will occur in
sensitive fish habitat. The Article
15 permit required for Excavation
and Fill in Navigable Waters will
include a condition that blasting in
protected waters is prohibited,
except during the period from July
15 October 15, to avoid adverse
impacts to important fish species
during the spawning and incubation
periods.
Source: NYSDEC
3-42

Hounsfield Wind Farm


Final Environmental Impact Statement

Topic: Wetlands
Comment
#
2.4.3-1

2.4.3-2

2.4.3-3

2.4.3-4

2.4.3-5

Comments

Responses

State regulated freshwater wetlands


should be preserved and protected
and as such, destruction should be
avoided. However, the DEIS states
that some wetlands impacts are
unavoidable and proposes wetland
mitigation.
If
determined
acceptable it should be stipulated
that where practical, all wetland
mitigation should be located within
the sub-watershed that the original
disturbed wetland is located within
and that area to be mitigated should
be maximized.
Source: DOS
Specific parameters should be
established that define what would
constitute a successfully established
wetland and at what point
guaranteed remedial action would
occur, should success parameters
not be met.
Source: DOS
It may be advantageous to
guarantee
proper
wetland
establishment through bonding or
other
financial
security
mechanisms.
Source: DOS
Additionally, public comments
have been received that identify
public recreational uses associated
with various wetland areas on the
island through existing agreements
with the private landowner; these
uses should be preserved to the
extent practical.
Source: DOS
The overall wetland mapping and
boundary delineation has met
Department standards and will not
require additional field verification

Wetland Impacts that are unavoidable


will be mitigated on Galloo Island. The
proposed mitigation site for the DEC
wetland is on Galloo Island adjacent to
an existing wetland and shown on Figure
1.1-1 of this FEIS.

3-43

Requirements and standards regarding


the establishment of a wetland are part
of the wetland permitting process.

Wetland Permits issued by the NYSDEC


and USACE will have conditions which
will likely require 5 years of monitoring
to ensure the establishment wetlands.
This issue will be part of the permits
issued by NYSDEC and USACE.
The only current active recreational use
of the island is hunting by private
parties.
The Project Sponsor has
indicated it is unlikely that public
hunting will be allowed at a working
wind farm. The proposed project will
not affect public access to the two
parcels of land on Galloo Island owned
by the State of New York.
Comment Noted.

Hounsfield Wind Farm


Final Environmental Impact Statement

2.4.3-6

2.4.3-7

2.4.3-8

by Department staff.
Source: DEC
It does appear that you are mixing
DEC regulated wetlands and
wetlands regulated by the ACOE
and showing them as one and the
same. For permitting purposes it
will be necessary for you to
separate these two jurisdiction from
each other.
Source: DEC
The developer claims loss of less
than an acre of wetlands due to the
project. The facilities including
over 15 miles of roads are adjacent
to almost 80% of the island's
wetlands. The construction and
maintenance of this project will
impact the efficacy of the wetlands
as breeding sites.
Source:
Onondaga
Audubon
Society

Comment Noted.

The loss of less than an acre of wetland


describes the direct impact of the project
on habitat by filling and clearing.
Indirect impacts to wildlife (including
breeding avian species) such as those
from noise and activity during
construction and operations were
discussed on pages 2-68 through 2-72 of
the DEIS. The adjacency of roads to
wetland areas will result in these indirect
impacts from noise and human activity
but the majority of these impacts will
occur on a temporary basis during actual
construction. Very little activity will
occur on the roadways during the
conduct of operational and maintenance
activities. Displacement of breeding
avian species were addressed in the
DEIS on page 2-93 and 2-94. This
section acknowledges that disturbances
will impact the efficacy of some areas as
breeding sites during the periods of time
that the disturbances occur. Many
grassland birds have been found to
inhibit or reduce the frequency of the
activities (nesting, foraging) from about
250-300 to 650 feet from wind turbines.
It is currently unknown if wildlife and
grassland birds could become habituated
to the presence of large commercial
wind energy facility. These impacts will
be verified through an avian/bat postconstruction monitoring study required
by DEC as a condition for permits.
On Page 2-30, the text states that Comment noted. Slurry disposal and
concrete slurry disposal and washout procedures are also intended to
3-44

Hounsfield Wind Farm


Final Environmental Impact Statement

washout procedures will protect


steam, pond, and lake water
quality, but does not specifically
mention wetlands.
Source: USFWS

2.4.3-9

2.4.3-10

Wetlands are described in Section


2.4.3
which
indicates
that
approximately 361 acres of this
habitat type are found on the island.
One area, Wetland J, may not be
jurisdictional due to its isolation
from a navigable waterway. The
report should be updated and
provide information on whether or
not this area has been deemed
jurisdictional.
Source: USFWS
Placement of fill into wetlands will
mostly result from the construction
of access roads and clearing for
electric lines. A total of 0.79 acres
will be permanently impacted. As
mentioned above, the placement of
rock into wetlands for crossings is
not recommended. Instead culverts
should be considered as a means of
crossing these areas.
Source: USFWS

3-45

protect wetlands.
Although not
mentioned on Page 2-30, page 2-52 in
the Wetlands Section of the DEIS states
No accidental releases of oils, fuels,
and concrete leachates to wetlands are
expected. The proposed Project includes
an SWPPP, a SPCC, and plans for
containment of non-oil materials to
ensure that proper precautions and
containment procedures are taken to
prevent such material releases and to
ensure proper cleanup and containment
in the unlikely event of an accident.
The SPCC is enclosed as Appendix B.
A conceptual erosion control plan as
included in the DEIS. The SWPPP will
be included in the SPDES permit
application to DEC (GP-0-08-001).
The project sponsor has agreed to
assume
that
all
wetlands
are
jurisdictional through the USACEs
Preliminary Jurisdictional Determination
process. Wetland permits and mitigation
will proceed as if all wetlands are
jurisdictional.

The wetlands on Galloo Island are


characterized by thin soil layers and
shallow bedrock (See Appendix EMitigation). Also, none of the Island
wetlands that will be crossed by
roadways exhibit high flow rates, high
rates of sedimentation or erosion. The
Project incorporates use of large
permeable granular fill that will be
placed nearly flush with grade to allow
for circulation and water flow. Based on
the geological conditions in the area and
the design criteria, impacts on
groundwater and surface flow in the
wetlands are not anticipated. The stone
fill will be a minimum of 6-inches and
more permeable than the wetland soils

Hounsfield Wind Farm


Final Environmental Impact Statement

2.4.3-11

While the project design does avoid


most of the site wetlands, many of
these areas will be completely
surrounded by roads and turbines,
thereby decreasing the habitat
value.
Source: USFWS

2.4.3-12

As mitigation for 0.79 acre wetland


impact, the project sponsor
proposes to create 0.27 acre of
wetland from an upland area. We
found no explanation as to why the
wetlands would not be replaced in
their entirety. Typically, wetlands
are replaced at a ratio higher than
what is being impacted. Forested
wetlands are usually replaced at a
ratio or 2 acres created for every 1
acre impacted, due to the time it
takes to replace wetland functions.
It is stated that few locations are
available to create more wetlands.
We have not seen information
which supports the notion that
3-46

that already exist in the wetland crossing


areas. Where needed areas adjacent to
the roadway will be vegetated at the
downslope side of the road. During final
design and location of road crossings,
Upstate Power will consider the
placement of bottomless culverts in
areas observed to show any substantial
surface flow characteristics or ponding.
Final designs for all wetland crossings
will conform with DEC and USACE
permitting requirements.
As indicated in the DEIS the habitats on
the island are not unique or pristine and
are similar to habitats on the mainland.
The island has historically been
disturbed by agricultural activities, deer
management practices, clear cutting of
cedar forests and pervasive invasion by
pale swallow-wort. Habitat losses and
fragmentation associated with the
project are not expected to adversely
affect wildlife populations, and may be
offset somewhat through the proposed
aggressive pale swallow-wort control
program, however these efforts will be
verified
through
avian/bat
post
construction monitoring that will include
measurement of avoidance behavior of
nesting and grassland bird species.
As mitigation for wetland and buffer
area impacts resulting from this project
the applicant proposes to create
0.558acres of wetland (a 1:2.5 ratio of
loss to creation), and 3.65 acres of
protected forested adjacent area (a 1:2
ratio of loss to creation). The mitigation
as proposed will allow the project to
meet requirements of the Freshwater
Wetlands Act (Article 24 of the ECL)
and 6NYCRR Part 663 (regulations
regarding permit issuance standards).

Hounsfield Wind Farm


Final Environmental Impact Statement

2.4.3-13

2.4.3-14

additional wetlands cannot be


created on the island. In fact, we
observed several suitable areas,
such as adjacent to Wetlands D or
F. We recommend the wetland
mitigation plan be reevaluated and
at least 1.5 acres of created wetland
be built or restored, since most of
the impacted wetland is forested in
nature.
Source: USFWS
Measures to protect wetlands are
listed on Pages 2-53 and 2-54.
However, measures are suggested
rather than committed to in the text.
We suggest changes to the text, for
example, rather than stating that
clay ditch plugs can be used to
prevent draining of wetlands, the
text should say they will be used.
Also seeding with appropriate
grasses should be changed to
seeding with native species if
appropriate.
Source: USFWS
The statement on DEIS page 2-44,
On August 12, 2008 the USACE
and NYSDEC accompanied C&S
and TES to the Island to verify the
delineated wetland boundaries,
should be corrected. The site visit
conducted that day was a general
tour of the project development
area by agency staff; not a specific
delineation-verification site visit.
Subsequent to that date, however,
DEC has agreed to the delineations
prepared for the project, as stated
by Ken Kogut, Region 6 Natural
Resources Supervisor, in an email
to the project sponsors consultant
dated March 30, 2009, which reads,
The overall wetland mapping and
boundary delineation has met
Department standards and will not
require additional field verification
by Department staff. DEC
3-47

The phrasing used in the DEIS was


appropriate. In the Findings Statement
and any permit approvals mitigation
measures will be mandated rather than
suggested. No changes to the DEIS is
required.

Comment Noted.

Hounsfield Wind Farm


Final Environmental Impact Statement

Comment
#
2.5-1

continues to advise that state and


federal wetland jurisdictions be
clearly defined for purposes of the
Joint Application for Permit.
Source: DEC
Topic: Wildlife and Habitat
Comments
Section 2.5 describes wildlife and
habitat and lists the attributes of the
eastern Lake Ontario region and its
importance to wildlife, particularly
birds. In discussing the various
habitat types found on the island
and associated wildlife dependent
upon them, the DEIS concludes
that there will be minor wildlife
impacts.
Given the long time
frames for construction (3 years)
and the constant human activity, we
expect impacts to be substantial, if
not significant, to sensitive species.
Source: USFWS

3-48

Responses

This comment does not indicate which


particular sensitive species are of
concern to the US Fish and Wildlife
Service or the specific type of impact
that would be of a substantial nature. In
terms of mammals and avian species, the
predominant populations on the island
are species that are common to the
region and widespread throughout the
State of New York, with the exception
of short-eared owls and other wintering
raptors that may represent a significant
portion of the avian biomass on the
island in winter, and are not found in
such concentrations at many other places
in New York State. Winter residents are
unlikely to be directly affected by
construction activities, as those activities
will occur mostly at times of the year
when wintering birds are not present in
large numbers, however may be subject
to collision risks while wintering on the
island. These impacts will be verified
through post-construction monitoring
required as a condition of DEC permits.
In regard to the time span of the
construction and construction logistics,
work activities will never be pervasive
throughout the island nor will all types
of construction be going on at the same
time. For instance the first phase
includes only the construction of the
temporary dock. Later when materials
and equipment can be brought to the
island access roadways and laydown
areas would be constructed. WTG would
be constructed a few at a time. Therefore
there will always be some undisturbed

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5-2

areas available as habitat for fauna that


are temporarily displaced by noise and
human activity. Since the habitat
available to displaced animals is limited
based on the island location, compared
to a mainland location, the effect of
displacement may be greater.
Also,
given
the
web
of The DEIS on page 2-71 acknowledges
infrastructure and turbines to be the fact that the web of infrastructure
constructed throughout the island, and turbines will alter and fragment
remaining habitat will be degraded. some habitat areas on the island but not
Source: USFWS
all remaining habitats will be adversely
affected. Significant amounts of various
habitat types will remain untouched and
will be relatively free from human
intrusions during the operational and
maintenance phases of the Project.
Fragmentation of habitat has been
minimized as much as practicable
through the design and layout of the
Project features.
Fragmentation has
been further minimized by the
redesigned layout of the Project. This
layout reduces habitat fragmentation by
collocating ECS and roads in a number
of locations. The substation was also
moved to the eastern edge of the island,
to the agricultural area. These changes
have reduced impacts to forested areas
by 12.78 acres.
Roadways will be at or near existing
ground level and will not affect
movement
of
wildlife
typically
inhabiting forest and open field habitats.
Maintenance of low level vegetation in
areas that are cleared through forests for
overhead transmission lines will also not
impede movement or migration of
animals. Cleared zones may provide
some additional edge (ecotones) for
wildlife use. These created ecotones will
favor some wildlife species over others.
Creating edge may favor some predatory
species of wildlife. Most of the mammal
species on the island and a large
percentage of the bird species are ones
3-49

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5-3

Further, we believe that the


permanent presence of project staff
on the island who will be
constantly inspecting, operating,
repairing and moving equipment
throughout
the
island,
will
permanently
affect
wildlife,
especially those species not
accustomed to or tolerant of human
presence.
Source: USFWS

2.5-4

The first paragraph on Page ES-22


has contradictory statements with
the first sentence indicating a
minimal impact on birds and bats,
and the second sentence signifying
there will be impacts of medium
significance.
This should be
clarified.
Source: USFWS

2.5-5

Although the report states there will


be habitat fragmentation from roads
and electric lines, it does not
qualify the effects on habitat
quality. This should be added to
the document.
3-50

that do tolerate some degree of human


presence. In addition, many of the
potential impacts will be temporary in
nature and occur only during the
construction phase of the Project.
Human activity for operations and
maintenance will not be pervasive
throughout the island but rather will be
intermittent and generally centered on
only a few areas of the island at any
given time. Full-time operations staff
will consist of only about 24 people
(refer to pages 1-52 and 1-53 of DEIS).
Most human activity will be at the
various buildings near Gill Harbor and at
the offloading facility. Use of small
vehicles for inspection and maintenance
is not expected to cause substantial
disturbances to wildlife. Over the nearly
2,000 acre island, there will only be 12
project staff on island at one time. This
staff will not work 24 hours a day. This
low intensity of use will provide plenty
of opportunity for refuge for species that
are not accustomed or tolerant of
humans.
The text on page E-22 states A
summary of the results of the cumulative
assessment of avian and bat impacts,
suggest that overall, significance of
cumulative environmental change is
generally considered minimal. However,
impacts of medium significance are
expected on avian and bat resources.
The first statement should more clearly
state A summary of the results of the
cumulative assessment suggest that
overall, significance of cumulative
environmental change is generally
considered minimal. This statement
has been clarified in the FEIS.
Following the publication of the DEIS, a
revised layout has been proposed and is
reviewed in Section 1.12.3. This layout
reduces forested habitat fragmentation
by collocating ECS and roads in a
number of locations. The substation was

Hounsfield Wind Farm


Final Environmental Impact Statement

Source: USFWS

also moved to the eastern edge of the


island, to the agricultural area. These
As previously mentioned, despite changes have reduced impacts to
lower number of habitat impacts for forested areas by 12.78 acres, mostly
the project when compared to through this collocation.
similar wind energy projects, the
patchwork of roads, electric lines, However, fragmentation cannot be
and turbines across the island may entirely avoided. The effects of
result in greater habitat impacts to fragmentation on wildlife are both
species sensitive to these structures habitat specific and species specific.
than reported.
Some of the fragmentation of open field
Source: USFWS
and upland deciduous forests is due to
the avoidance of impacts to freshwater
wetlands.
Fragmentation affects the quality of
various habitats by loss of habitat,
dissecting the habitats into smaller
parcels or tracts, and causing a change in
occupancy of the remaining divided
habitat. The fragmented habitats change
in area, configuration, or spatial
relationship. While it is possible to
quantify the amount of habitat lost and
size of remaining parcels, meaningful
modeling of effects on quality from a
conceptual basis is difficult for
numerous reasons. Some of these
reasons include: ambiguity in various
definitions of fragmentation; habitat
heterogeneity and dynamics compound
effects from fragmentation; inherent
complexity of ecological systems has led
to compound effects and multicausal
responses by wildlife; species-specific
responses to fragmentation has let to
varied responses by wildlife; and several
other factors.
Fragmentation effects generally result
from: patch-size reduction; edge effect;
and isolation effects. Fragmentation can
affect wildlife in negative, positive and
neutral ways. The species most affected
from the Project by fragmentation are
the avian, mammal, reptile and
amphibian species that utilize the upland
3-51

Hounsfield Wind Farm


Final Environmental Impact Statement

deciduous forests and open field habitats


for some of their life cycle requirements
(reproduction,
feeding,
rearing,
migration, etc). Some large mammals
may demonstrate road avoidance
behaviors and changes in edge caused by
roads may favor wildlife species that use
edge environments to the detriment of
other species. Some changes in habitat
carrying capacity may also occur as a
result of fragmentation.
Some avian responses to fragmentation
include potential life cycle alterations,
increased parasitism, and habitat affinity
associations.
Although the project will dissect open
fields and deciduous upland forests, the
tracts or parcels that remain are still of
relatively large size and will provide
habitat to serve life cycles of wildlife on
the island.

2.5-6

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.
Source: USFWS

3-52

Recommendations to reduce isolation


typically include minimizing inter-patch
distances and keeping equivalent
habitats adjacent to one another. While
the project will dissect habitats, it will
keep the adjacent habitats the same in
terms of equivalent quality and distance
between patches will be relatively small.
Road elevation will be kept as close as
possible to existing ground level to
minimize effects on wildlife travel
patterns.
A preliminary environmental monitoring
plan was included in the DEIS. A more
detailed Proposed Scope of Work for
Post-Construction is included as
Appendix I of the FEIS. A final plan
will be required by DEC as a permit
condition for construction of the project.
The final plan will be developed in
consultation with DEC and USFWS. A
training component for workers to
identify and handle injured or dead

Hounsfield Wind Farm


Final Environmental Impact Statement

Comment
#
2.5.1-1

2.5.1-2

2.5.1-3

wildlife will be included. The plan will


include requirements for all personnel
that handle avian, bat and other wildlife
carcasses to obtain necessary handling
permits.
Topic: Flora and Fauna
Comments
Responses
The draft EIS gives no detailed
indication of how whitetails have
shaped the Galloo ecosystem since
their introduction.
Source: Gordon Whittington

Detailed studies of Galloo Island are not


available for the time prior to the
introduction of deer. Impacts to flora
and fauna are detailed in Section 2.5 of
the DEIS. It is unclear whether the
information sought by this commenter
would provide any further information
for evaluating the impacts of the
proposed wind farm on the current
island environment.

Even with the presumed ongoing


presence of a natural predator (the
coyote) after any deer culling has
been done, history suggests that in
absence of continued hunter harvest
and/or extreme winter conditions,
the deer population will rapidly
rebound to high levels. Indeed, I
believe it is likely to soon exceed
any reasonable carrying capacity,
whether or not there is a total loss
of the agricultural crops historically
cultivated to provide whitetail
forage. This almost assuredly risks
a loss of floral (and possibly
faunal) biodiversity, potentially
including at least some of the
threatened/endangered
species
mentioned in the draft EIS.
Source: Gordon Whittington
While I would hardly suggest the
whitetail is "native" to Galloo
Island, it presumably is now the
single most impactful species on
that ecosystem. As such, I believe it
prudent to develop a plan for
ongoing hunter harvest of deer,

To control the deer population on-going


hunter harvest by project staff will be
conducted as necessary to maintain the
deer population at a level that does not
exceed the carrying capacity of this
island once active agricultural practices
for the support of a large deer population
ceases. A deer management program
will be developed in consultation with
the regional NYSDEC deer biologist to
address potential impacts to both the
deer population and the effects of this
population
of
the
surrounding
environment.

3-53

The project sponsor has indicated that


any necessary control of the deer
population on the island will be
undertaken by project staff.

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.1-4

2.5.1-5

particularly
if
agricultural
subsidization and supplemental
feeding of the herd are soon to
cease. Yes, I understand the issues
involved in allowing the public
some level of access to a major
power installation, even under
highly restrictive rules. However, I
have seen bow hunting in particular
be tremendously effective in
controlling deer numbers in similar
situations.
Source: Gordon Whittington
We are concerned about the
wildfire spread of Swallow wort.
Current efforts have had little
result.
Source: Town of Hounsfield
Planning Board

It is mentioned that impacts to


reptile and amphibian habitat will
be minimal due to the low amount
of wetland loss. However, upland
areas represent significant habitat
during some portion of herpafauna
life cycles. The DEIS needs to
consider the impact to upland areas
as well as the network of roads and
utility corridors upon habitat
conditions.
Source: USFWS

3-54

Control of the Pale Swallow-wort is


addressed in the invasive species control
plan, attached as Appendix F to this
FEIS. The goal of the invasive species
control plan is to reduce the spread of
this invasive species on the island and to
control further spreading to the mainland
from the island, in particular those areas
of the mainland that have been identified
as staging areas for project construction
personnel and supplies.
The DEIS identifies the fact that upland
areas do serve as habitat for some
portion of the life cycles of certain
amphibians and reptiles. As indicated on
page 2-67 of the DEIS six species of
amphibians and five species of reptiles
were observed on the island although
others may also inhabit the island.
American toad, red-backed salamander,
northern leopard frogs, pickerel frogs
and others use habitats other than
wetlands for portions of their life cycles.
They were found in various habitats
including upland deciduous forests,
upland scrub-shrub, rocky shore habitat,
agricultural and open fields and various
wetland cover types. The amount of
upland habitat to be lost from the Project
will not likely affect amphibian and
reptile populations. Some amphibians or
reptiles may be displaced and/or killed
during construction. The habitats in
which the observed reptiles and

Hounsfield Wind Farm


Final Environmental Impact Statement

amphibians on Galloo Island were found


are listed in table 3 of the Ecological
Resources Report prepared by TES as
contained in Appendix N of the DEIS.
Additionally, as a result of a survey
effort for the state-listed endangered
Blandings Turtle, conducted during the
summer of 2009 according to DEC
recommendations, it was determined
that it is unlikely that Blandings Turtles
currently occupy Galloo Island.
In summary, although some individual
amphibians and reptiles may be
impacted there is nothing to indicate
significant numbers or rare threatened or
endangered species will be affected.

Comment
#
2.5.3-1

Topic: Avian Species


Comments
Five Related Comments:
Comment
1:
It
may
be
advantageous to explore the
potential benefits derived from
curtailing generation during periods
of increased avian activity. A
recent study at the Casselman Wind
Power Project in Pennsylvania
indicated that avian and bat impacts
may be reduced by 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
viability
of
proximate
Significant Coastal Fish and
Wildlife Habitats (SCFWH).
Source: DOS
3-55

Responses

Proposing specific adaptive management


measures at this time would be
premature. The Avian Risk Assessment
determined that impacts are not
anticipated to be significant. If studies
subsequent to project commissioning
identify
unanticipated
significant
impacts, adaptive management measures
would be identified and implemented.
Although the need for adaptive
management and specific adaptive
management techniques cannot be
identified at this point, such measures, if
necessary
would
likely
involve
operational interventions, like those
referenced by the commenter, or habitat
conservation/improvement that results in
a net conservation benefit for an
impacted species.

Hounsfield Wind Farm


Final Environmental Impact Statement

Comment 2: Galloo Island is an


important route for migrating birds
and bats, and we encourage Upstate
New York Power Corporation to
consider operational closures to
protect birds and bats during
critical migratory periods.
Source: Nature Conservancy
Comment 3: We note that the
DEIS calls for post-construction
mortality studies and we seek
assurance that there is an adaptive
management
requirement
to
address any significant adverse
impacts to birds and bats.
Source: OPRHP
Comment 4: One measure not
listed is the performance of postconstruction monitoring to improve
the understanding of avian impacts.
While
a
noteworthy
task,
monitoring alone is not a form of
mitigation to alleviate avian loss.
As stated above, this section does
not provide effective mitigation
measures,
such
as
turbine
operational adjustments during
migration, to reduce wildlife
mortality.
Source: USFWS

2.5.3-2

Comment 5: Also, project


approval should be conditioned
upon an adaptive management plan
to address wildlife mortality as a
result of turbine operations.
Source: USFWS
It is located on and adjacent to bird
habitat that is unique and shrinking
in New York.
Source:
Onondaga
Audubon
Society
3-56

The habitats found on Galloo Island


were documented in the Ecological
Resources Report (DEIS, Appendix N)
and as indicated on page 2-60 of the
EIS, the habitats on the island are neither
unique nor pristine since the island has

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.3-3

First, it is located in a major bird


migration corridor.
Source:
Onondaga
Audubon
Society

2.5.3-4

Galloo Island has a documented


history of being an important
wintering area.
Source:
Onondaga
Audubon
Society

3-57

historically
been
disturbed
by
agricultural activities, deer management
practices, clear cutting of cedar forests
and pervasive invasions by pale
swallow-wort. The habitats found on
the island are similar to those found on
the mainland. Although the project
results in the loss of some habitat
(primarily open field, upland deciduous
forest and agricultural land) and
contributes to some degree to the
cumulative loss of these habitats in New
York State; the cumulative impact from
the Project is minimal (refer to pages 659 through 6-64 of the DEIS).
The Draft EIS on pages 2-80 to 2-82
recognizes the importance of the
regional area as a major bird migration
corridor. In order to ascertain use of the
Galloo Island habitats for nesting,
breeding, feeding and migration stop
over, an ecological resources survey and
several onsite avian studies, including an
avian risk analysis, were conducted for
the project (refer to Appendices N and P
of the DEIS). These reports document
the habitats being used by various
species and included observations of
flyovers and use of the island by
migratory bird species. The avian risk
analysis included migratory landbirds,
shorebirds, waterfowl, raptors and
endangered, threatened and special
concern species and did not show
substantial risk to migratory species.
The Galloo Island Winter Bird Surveys
and Avian Risk Analysis address the use
of the island by wintering birds. No prior
bird surveys in winter had been
conducted until the 2007-2008 survey
that was done for the Project. The winter
survey focus was on documenting the
number of raptors, the region of the
island where they occurred, as well as
specific information on whether birds
were perched or in flight, their flight
height, and direction of flight.

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.3-5

Additional landbird species were noted


during the course of the raptor surveys.
With the exception of Bald Eagle diurnal
winter raptor densities on Galloo Island
appear tied to the vole cycle on the
island. The fact that Galloo Island is
wind-swept and surrounded by relatively
warm lake waters in late fall means that
its grounds will tend to be open (snowfree) later in the winter than coastal and
inland sites. At times when voles are
plentiful, Galloo Island likely attracts
and holds good numbers of winter
raptors as compared to other areas that
are in a phase of the cycle when voles
are not plentiful. The survey confirmed
that winter raptors aggregate on the
island when food is available. (Refer to
DEIS Appendix P). Very few raptors
were observed in active migratory flight
during the diurnal movement study. Data
from the winter bird study suggest that
the spring migration of raptors (notably
Rough-legged Hawks) occurs across the
eastern Lake Ontario coastal plains and
largely avoids Galloo Island. While
some fall raptor migration activity was
documented over Galloo Island, it is
believed to occur in lower numbers than
along the primary eastern coastal zone of
Lake Ontario. The risk assessment
concludes that Rough-legged Hawk,
Red-tailed Hawk and Bald Eagle
collision risk during some winters may
be greater than at other proposed or
existing wind projects in New York
because these species may be relatively
more numerous on Galloo Island in
some winters when food is plentiful. In
general raptor collisions (per MW)
during migration and during breeding
season are expected to be lower at the
Project than at Cape Vincent, and Wolfe
Island facilities (especially in spring)
because of greater numbers of migratory
and breeding raptors at these sites.
The site has impact on a significant The avian studies conducted for the
3-58

Hounsfield Wind Farm


Final Environmental Impact Statement

number of threatened and of special


concern species.
Source:
Onondaga
Audubon
Society

Project did identify a number of


threatened and endangered species that
use or migrate over Galloo Island
including Upland Sandpiper, Bald Eagle,
Northern Harrier, Short-eared Owl,
Pied-billed Grebe, Least Bittern, Sedge
Wren, Henslows Sparrow, Peregrine
Falcon and Golden Eagle. Potential risks
from collision, displacement, habitat loss
and fragmentation were discussed in the
DEIS and the Avian Risk Assessment.
In addition nine species of special
concern were documented as possible
migrants, possible breeders, and/or
occasional visitors to Galloo Island
including Common Loon, American
Bittern, Coopers Hawk, Sharp-shinned
Hawk, Common Nighthawk, Whippoor-will, Red-headed Woodpecker,
Horned Lark, and Cerulean Warbler.
None of these nine species were
confirmed breeding on Galloo Island
and only one or two individuals of each
were observed except for Horned Lark
(flock of 10 seen during the winter bird
survey) and Common Nighthawks (6
migrants in late May). These species
could be subject to minor collision risk.
It should be noted that to date, there is
only one unconfirmed case of a Bald
Eagle experiencing collision mortality at
a wind project in the northeast and there
are no studies or data available for this
species regarding avoidance or evasive
behavior.

2.5.3-6

The ARA for the Hounsfield wind


project discusses potential risks to NY
listed species and assesses risk relative
to the Maple Ridge wind project. The
ARA concludes that the Hounsfield
wind project would not have greater
overall impact to NY listed species than
Maple Ridge. There are no assessments
that suggest otherwise.
We believe there is sufficient Pre-construction
avian
studies
3-59

Hounsfield Wind Farm


Final Environmental Impact Statement

uncertainty about impact of this


project on the current and future
resident
and
migrant
bird
populations to warrant extreme
caution about the advisability of
establishing a wind project on this
site.
Source:
Onondaga
Audubon
Society

2.5.3-7

The project is directly in the flight


path
of
important
breeding
concentrations of birds including
Little Galloo Island, a recognized
Important Bird Area.
Source:
Onondaga
Audubon
Society

3-60

performed for wind energy projects are


generally used to provide a baseline to
determine use of habitats for breeding,
feeding and migration and to determine
flight patterns and altitudes among other
things. The avian impact is generally
defined as the realm of changes that
occur to the pre-construction avian
resource during and after wind project
construction. Current understanding of
potential impacts on birds is based on
fatality studies at existing operations and
studies on the geographic distribution
and behavior of certain species before
and after such facilities are built. To
assess the potential avian impact of the
Project, this latter information (primarily
regional studies) is considered along
with recent extensive documentation of
the existing bird resource on Galloo
Island. Due to the fact that there are
currently only a few credible avian
fatality studies at wind energy projects
in eastern North America, it is difficult
to definitively assess potential collision
impact from the project. The avian risk
assessment becomes primarily a series
of relative comparisons of avian
distribution and activity between
proposed or existing sites. The avian
studies as contained in the DEIS and
Appendix P are standard studies that are
recommended by NYSDEC at all large
wind projects and are supplemented by
other studies specifically designed for
the Project. The predicted theoretical
losses do represent the current state of
knowledge of wind farm impacts.
Studies performed by Old Bird, Inc for
the Project were specifically designed to
assess the use of Galloo Island by birds
using Little Galloo Island for breeding
and to account for impacts on migratory
species. Little Galloo is the closest of
the islands in relationship to Galloo
island and impacts to avians using other
islands for breeding would presumably

Hounsfield Wind Farm


Final Environmental Impact Statement

be less than those associated with Little


Galloo Island avians due to greater
distances. Also, there is no evidence
that the Project will effect any changes
to bird populations on the mainland,
including areas such as Point Peninsula
Bird Conservation Areas.
As noted on page 9 of the breeding bird
survey of Galloo Island, the regular
diurnal transit between Galloo Island
and the mainland or nearby islands
appeared to be limited to a few species
(and with very low frequency) such as
Great Blue Heron, Northern Harrier,
American Crow, Common Raven. The
diurnal bird movement study for the
Project actually focused particular
attention on Little Galloo Island due to
its importance to avian species,
especially colonial waterbirds-gulls,
Caspian Tern, and Double-crested
Cormorant. The general objective of the
diurnal bird movement study was to
characterize flight patterns of birds
during the day for assessing potential
avian collision risk with the Projects
wind turbines and for gathering baseline
data that could be compared to similar
data after project construction. The
results of all these studies at Galloo
Island indicate that the Project would not
have a significant impact on the viability
of the Little Galloo Island waterbird
colony either in collisions, in feeding
ground displacement, or in energetics.
Large numbers of diurnal landbirds
move around Lake Ontario and not over
the water. Nocturnal and diurnal
migrating passerines would likely have
lower collision fatalities per MW at the
Project than the Wolfe Island Wind
Farm and other wind projects in the
eastern coastal zone of Lake Ontario.
In addition the 2009 Diurnal Bird
Movement Study showed passage rates
over Galloo Island for Caspian Terns,
3-61

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.3-8

We are very concerned that the


cumulative impact of the project
will impact breeding, migrating and
wintering bird patterns and
behavior on the island and
surrounding area.
Source:
Onondaga
Audubon
Society

Ring-billed Gulls and Double-crested


Cormorants as peaking in early June
through early July. Depending on results
of
post-construction
monitoring,
adaptive management actions to prevent
turbine strikes during certain time
periods of operation may be considered.
This comment relates to behavioral and
community
impacts
such
as
displacement, avoidance and habituation
of avian species that breed, migrate or
winter on Galloo Island and surrounding
areas and presumably losses due to
collision, habitat loss and habitat
fragmentation. All of these potential
effects are addressed in the DEIS (pages
2-93 to 2-98) and Appendix P. The
DEIS and Avian reports in Appendix H
acknowledge that some changes such as
displacement of ground nesting birds,
rendering of some habitats less suitable
for certain species, losses due to
collisions and other avian impacts will
occur. Most of these disturbances will be
localized in nature and are not expected
to have adverse effects on regional
population levels, species diversity or
composition, or available regional
habitat.
The cumulative effect of the Project on
avian and bat populations taken in
conjunction with other proposed and/or
operating wind farm facilities was
addressed in the DEIS (pages 6-1 to 629). With the exception of habitat
related impacts (common to many
different types of projects) the height of
the turbines and the unique nature of
their movement make it more likely that
cumulative impacts would result more
from other wind farm projects than from
more common facilities such as cell
towers, communications towers and
transmission facilities. The results of the
cumulative impact analyses indicate that
while the project will contribute some to

3-62

Hounsfield Wind Farm


Final Environmental Impact Statement

cumulative losses of individuals and


avian habitat, the overall environmental
impact may be considered minimal.
While impacts of medium magnitude
may occur on waterbirds, these species
are populous in nature, so any impact
that may occur should not affect species
viability. There is potential for impacts
on raptors but four intensive fatality
studies in eastern North America have
documented few raptor fatalities.
2.5.3-9

Considering the variety of weather


and other natural cycles one winter
is not long enough for the raptor
study to meaningful and one season
is not enough study for the avian
and bat studies to be conclusive.
We would request that at least two
additional years of avian studies be
conducted.
Source:
Onondaga
Audubon
Society

2.5.3-10

The project is so important to the


future of wildlife in the region that
all and any comments in the study
should be data based. Referencing
other studies and proposed wind
projects that do not have a
historical basis for their data should
3-63

As requested by the NYSDEC,


additional winter bird surveys (20082009) and diurnal bird studies have been
conducted by Old Bird, Inc for the
Project. These studies supplement the
2007-2008 winter bird survey and the
2008 diurnal bird movement study. The
2008-2009 winter bird survey supports
the conclusions reached in the 20072008 survey that Galloo Island is
involved with the winter raptor
concentration
phenomenon
that
periodically occurs in the grasslands
proximal to northeastern Lake Ontario.
As such it supports the idea that the
winter concentration of raptors on
Galloo Island has considerable variance
from year to year. Bald Eagles were
noted in lower numbers than the
previous survey as were Rough-legged
and Red-tailed hawks. Numbers of
waterfowl were significantly down from
the prior years survey. No short-eared
owls were observed in the 2008-2009
survey and only one individual Northern
Harrier was documented. Another winter
bird study will be conducted in 2009
2010.
Site-specific studies performed for the
Project are in accordance with the
current
NYSDEC
protocol
for
conducting bird and bat studies related
to commercial wind energy projects. The
studies have been supplemented as
needed based on comments and reviews

Hounsfield Wind Farm


Final Environmental Impact Statement

be discounted and removed from


the report.
Source:
Onondaga
Audubon
Society

2.5.3-11

Obviously any wind power project


that gets approved and built should
include post construction studies.
For this very special 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 and cannot be
undone.
Source:
Onondaga
Audubon
Society

2.5.3-12

This has been a fly way for


migratory birds
Source: Raymond Walty

2.5.3-13

State Parks recommends that the


DEIS consider additional scientific
studies related to avian impacts.
Source: OPRHP

2.5.3-14

The DEIS states that it is difficult


to assess potential avian impacts
because of limited research "at
wind energy facilities in the eastern
part of North America". Please
make every effort in the EIS to
incorporate findings from avian
impact studies conducted in other
areas, for example studies in
western North America and
Europe.
Source: OPRHP

2.5.3-15

The DEIS should discuss the flight


altitude of nocturnal migrants over
Galloo Island. The mean flight
altitude during both spring and fall
migration was 298 ft (considerably
3-64

by various regulatory agencies. The


protocols are also intended to provide
comparability of data collection among
sites and between years in order to
contribute
to
the
statewide
understanding of ecological effects.
Studies for the Project include both preconstruction
and
post-construction
biological surveys. Some impact on
birds and bats is unavoidable but avian
and bat risk assessments do not
anticipate significant effects. If studies
subsequent to project commissioning
identify
unanticipated
significant
impacts, mitigation strategies, which
could include adaptive management
techniques would be identified and
implemented.
The DEIS acknowledged the fact that
Galloo Island is within a flyway region
important
to
migratory
birds.
Additionally, on-site migratory bird
surveys were performed for the Project.
Refer to pages 2-80 to 2-82 of the DEIS.
Additional studies have been performed
including additional breeding bird,
diurnal, and wintering bird surveys and
these are included in Section 2.5.3 of the
FEIS.
The avian impact studies that were
referenced in the DEIS and Avian Risk
Reports
are
those
that
most
appropriately reflect the regional
conditions and species associated with
the Hounsfield site. These studies in
addition to the site specific studies
conducted at Galloo Island provide the
best
information
available
for
assessment of impacts. Many of the
studies consulted and referenced in the
avian risk assessment were from Europe
and various regions of the United States.
The mean flight altitude for Spring
migration was 319 meters, for Fall
migration was 298 meters, not feet as
stated in the comment. The mean
migration altitude is approximately 978

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.3-16

2.5.3-17

lower than at other mainland sites


nearby), which appears to be in the
middle of the motor sweep zone.
Source: OPRHP
We request that information from
the following reports be considered
regarding lighting impacts on birds:
1) U.S. Fish and Wildlife Service.
2003. Interim Guidelines to Avoid
and Minimize Wildlife Impacts for
Wind Turbines. Wind Turbine
Siting Working Group; and 2)
Longcore, Travis, Catherine Rich
and Sidney A. Gauthreaux, Jr.
2008.
Source: OPRHP

Construction of this project will


require
a
work
force
of
approximately 200 staff.
In
addition, 24 permanent staff will
handle routine turbine operation
and maintenance. This level of
human presence and activity will be
extremely distributive to wildlife,
especially those species on the
island which are secretive and are
negatively affected by human
presence (i.e. American bittern).
Because the project will be
constructed on an island, there is
limited area for refuge from these
3-65

feet (in the Fall) above the radar site and


1047 feet in Spring. This is similar to
other wind power locations in New York
State.
As indicated on page 2-98 of the DEIS,
Upstate Power will incorporate currently
available technologies (for the WTG and
permanent
meteorological
tower)
designed to minimize attraction to
migrating birds, to the extent allowed by
Federal Aviation Standards.
The
USFWS Interim Guidance lighting
recommendations and the document by
Longcore et. al. both advise that white
(preferable) or red strobe lights should
be used at night and that these should be
the minimum number, intensity and
number of flashes per minute allowable
by the FAA. In addition, adjacent
building structures at towers should not
have constant exterior lighting. Page 299 of the DEIS states that permanent
lighting on the island will be minimized
to only that necessary at housing
facilities, maintenance buildings, and the
substation. Unnecessary lights will be
turned off in the evening. The Project
will utilize strobe lighting but specifics
of the number, color and frequency of
flashes is still pending final design and
must be in accordance with FAA
requirements.
Refer to the responses to comments
numbered 2.5-1, 2.5-2, and 2.5-3
concerning the amount of human
intrusion and impacts expected during
construction and operations. The
American Bittern, a species listed by
NYSDEC as Special Concern, was
documented during the breeding bird
survey as a single individual in the
North Pond area of the island. The
American Bittern was not detected
during point count surveys. An
individual was calling from the south
end of North Pond (May 27 & 28, 2008)
and one individual was flushed from a

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.3-18

activities. The DEIS should review small wetland between survey points 75
this issue in greater detail.
and 78 (June 27, 2008). Other secretive
Source: USFWS
marsh birds that were observed during
the breeding bird survey were the
Virginia Rail (detected during habitattargeted surveys at north pond but not
found during point count surveys) and
Sora (one individual in the south marsh
at point 18). The low numbers of these
secretive species may be due to the
limited amount of emergent wetland
habitat on the island. These species,
especially American Bittern, require
relatively large expanses of emergent
wetland and/or scrub-shrub wetland
habitat. These species could be subject
to minor risk from WTG collision and
displacement and avoidance especially
during construction that occurs near
North Pond and south marsh.
Also, there may be potential Little Galloo Island is located about 1.0
impacts to birds on nearby Little mile from Galloo Island. Boat traffic to
Galloo Island, including State- and from the island is not expected to
listed species, from construction have any substantial impact on Little
activity and boat traffic.
Galloo Island. Construction materials
Source: USFWS
and equipment will be delivered from
Oswego Harbor to Galloo Island by
barge (towed and self propelled). Noise
from this mode of transportation is
minimal and will not affect avian
populations on Little Galloo. Noise from
small recreational craft and shipping is
also common in this area during late
spring to early fall. Also, the barges will
not create any wakes that would affect
shoreline habitat areas of Little Galloo
due to the great distances from shipping
routes and the fact that the barges do not
generally cause large wakes.
Noise from general construction
activities on Galloo Island will occur
from approximately April to November
of each construction year. The one mile
distance from Little Galloo to Galloo
Island will attenuate most of the
construction noises and would not
adversely affect birds inhabiting Little
3-66

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.3-19

2.5.3-20

On Page 2-61 it is indicated that the


project will not adversely affect
adjacent Little Galloo Island or the
species that transit between the two
islands. We found insufficient data
in the report to support this
statement. It is noted in the avian
report that Little Galloo colonial
waterbirds were documented to
making regular feeding flights
across Big Galloo Island. Visual
surveys were only conducted for 20
minutes once a week between April
and November. Additional visual
observations are needed to confirm
movements of Caspian terns, gulls
and cormorants.
Source: USFWS
It is also stated that bird collisions
will
be
minor
with
the
implementation
of
proper
mitigation measures. However, we
3-67

Galloo Island. Noise sources that would


generally be more perceptible at Little
Galloo Island are those associated with
blasting (upland and underwater).
Upstate Power will use the NYSDEC
Guidelines for Evaluating Mining
Applications that Propose to Use
Blasting Including Best Management
Practices (June 2009) to minimize
impacts and will comply with all
NYSDEC restrictions are placed on
various permits. In addition, the
limestone in the Galloo Island area is
heavily jointed and this would facilitate
minimal blasting since the fractures
already present can be expanded for rock
removal activities (refer to page 2-161 of
DEIS). Although the diurnal bird
movement study did show birds moving
back and forth between the islands,
impacts on Little Galloo Island avians
from construction activities at Galloo
Island will be minimal and no adverse
effects in feeding ground displacement
and energetics are expected.
Based on discussions with the
NYSDEC, additional studies that were
performed and are included in Section
2.5.3 of this FEIS are additional diurnal,
breeding bird and wintering bird
surveys. The avian risk assessment
included more than just visual
observations of avian movements. It
was based on additional factors such as
radar studies and studies at other
operational wind farms and the
professional
judgment
of
the
researchers. We continue to conclude
that the project will not adversely impact
adjacent Little Galloo Island or the
species that transit between the two
islands.
Comment noted. The Project design and
turbine placement criteria involved
numerous
factors
including
environmental considerations such as

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.3-21

2.5.3-22

2.5.3-23

know of few effective measures,


outside of lighting and operation
adjustments, which will be
effective in reducing avian impacts.
We advocate proper study and
careful turbine placement as the
most effective means of avoiding
avian impacts. This issue should be
further evaluated in a Final EIS. A
list
of
proposed
mitigation
measures is provided in this
section.
Source: USFWS
We do not support introducing red
fox to the island for rodent control
and suggest this be removed from
the summary. Red fox can be a
predator on ground nesting birds
and also do not compete well with
the already established coyote.
Source: USFWS
Bald eagles have been observed on
the project site, particularly on the
northern shore near North Pond. A
golden eagle was also observed
near the center of the island. On
August 8, 2007, the bald eagle was
removed
from
the
Federal
Endangered Species list and is no
longer protected under the ESA;
however, bald eagles remain on the
New York State list as a threatened
species. Bald and golden eagles are
also protected under the MBTA and
BGEPA. The Service is currently
finalizing regulations related to
eagle take, and we suggest the
project sponsors review that
information when available.
Source: USFWS
Diurnal movement studies of the
project area were conducted over
43 days for only 1 year (2008).
The Service typically recommends
that avian studies be conducted for
more than one season in separate
years to account for seasonal and
3-68

fragmentation
and
habitat
loss.
Additional consultation with DEC will
be conducted to identify further
avoidance and minimization measures
within the native grassland area in the
vicinity of proposed WTGs 2 and 3,
where Upland Sandpiper and Northern
Harrier activity was observed in the
2008 and 2009 Breeding Bird Surveys.

Introduction of red fox is no longer


being considered for the Project.

The status of these species was


discussed on page 2-73 of the DEIS and
Upstate Power will comply with all
applicable and pertinent regulations.

Additional diurnal bird and breeding


bird surveys were conducted and are
contained in Section 2.5.3 of the FEIS.

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.3-24

2.5.3-25

annual variation. Therefore, we


recommend additional monitoring
be conducted to determine eagle
and other raptor use of the project
area.
Source: USFWS
Data is lacking on wintering birds
on and near the island. Only 5
avian surveys were completed
during winter of 2007-2008 and
these were conducted at a quick
pace due to adverse weather
conditions. Severe weather caused
the cancellation of 8 other surveys.
We understand the difficulty in
accessing the project site in winter;
however, there is a lack of data for
wintering birds. This is especially
troubling since large concentrations
of waterfowl use the lake around
the island and bald eagles use the
area in winter as well. In fact, bald
eagles were observed on each of the
five winter survey dates. For these
reasons, we recommend additional
surveys be conducted in the winter
to determine avian use during that
time.
We recommend weekly
surveys be conducted from
November through March and
encompass all times of the day.
Several
stations
should
be
monitored
simultaneously
throughout the island.
Source: USFWS
Eighty
bird
species
were
documented on the project site
during breeding bird surveys,
including eight State-listed species.
Another 42 species were observed
during the surveys, but it was
determined they were not breeding
on the island. Although this is a
good indication of species richness,
many of the breeders are common
species (American robin, yellow
warbler, house wren, etc.). Still,
3-69

An additional wintering bird survey was


conducted and may be found in Section
2.5.3 of the FEIS.

As stated in the DEIS, there were some


state listed species documented on the
island in various habitats and some may
be potential nesters. The risk analysis
prepared for the Project acknowledged
that one breeding pair of Upland
Sandpiper could be subject to collision
risk and potentially could be displaced
from breeding on the island. This
species is also likely an occasional
transient on the island during migration
and such migrating individuals may be

Hounsfield Wind Farm


Final Environmental Impact Statement

the island currently provides habitat


for some rare species which have
experienced population declines
and construction of the project may
reduce or eliminate breeding
opportunities for species of concern
(upland sandpiper, northern harrier,
and bald eagle).
While these
species are not known to nest on
the island, they were observed
several times and are potential
nesters. We disagree with the
statement that the project may open
up some areas and make them
suitable for northern harrier
nesting. The network of roads,
electric lines, and turbines will
limit nesting opportunities for this
species.
Source: USFWS

2.5.3-26

2.5.3-27

exposed to collision risk. The Northern


Harrier could also be potentially
displaced from breeding and would be
subject to collision risk as well as
transients that frequent the island during
migration.
To respond to the concern regarding the
Upland Sandpiper breeding on Galloo
Island and habitat associated with that a
number of roads were relocated to
reduce this impact. The movement of
roads reduced the impact from 2.91 to
1.03 acres.

The project sponsor will continue to


consult with DEC regarding avoidance
and minimization efforts that can be
conducted to maintain the contiguous
area of native grassland where Upland
Sandpiper and Northern Harriers were
observed. Based upon this consultation,
DEC may require an Article 11 permit
for the taking of these state-listed
species, which would require additional
measures to be employed by the project
sponsor to provide a net conservation
benefit for the species. Such measures
include but are not limited to habitat
improvement on Galloo Island, and
habitat
protection/improvement/
restoration on the mainland.
Additional breeding bird surveys An additional breeding bird survey was
should be performed with an conducted on Galloo Island and may be
emphasis on species of special found in Section 2.5.3 of the FEIS.
concern and their preferred nesting
habitats. We recommend weekly
surveys between June and August
covering both early morning and
late afternoon time periods.
Source: USFWS
The text on Page 2-79 indicated Refer to responses to comments 2.5-1 to
that the habitat impacts from the 2.5-3 and comment 2.5-5 which address
project will be low, so the fragmentation and displacement impacts.
biological impact will be low as It is noted that some species may be
well. We disagree with that notion, negatively impacted by fragmentation of
primarily because the project habitat.
3-70

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.3-28

2.5.3-29

2.5.3-30

infrastructure (roads, electric and


overhead lines, turbines, substation,
and buildings) will turn any
remaining habitat into a patchwork
of fragmented habitat.
Many
species could be negatively
impacted by this scenario. There
will be some species that use
fragmented
habitat
and
are
accustomed to human disturbance
which may benefit them (such as
the
European
starling
and
American crow).
Source: USFWS
Mobile marine radar surveys were
conducted from April 15 to June 2,
2008, and while the survey was
designed to study spring migration,
we believe that the surveys were
started too late and missed many
early migrants (we recommend a
March 1st start). The study was
conducted on 43 nights of a
migration which lasts at least 90
days in the spring. However, it is
unknown if peak migration nights
were sampled.
Source: USFWS
It should be noted that the mean
passage rate of 624 targets per
kilometer per hour is one of the
highest recorded in New York.
While the report indicated that most
targets flew above the turbine
height, approximately 19 percent
flew within the rotor swept zone
and would be at risk of collision.
The report does not indicate the
importance of the island as a
migratory
stopover
habitat,
particularly
during
inclement
weather conditions, but should
address this issue.
Source: USFWS
As with the spring migration, we
believe the fall radar sampling
period missed a key portion of
3-71

The radar study was conducted in


accordance with criteria established in
the NYSDEC scope of work for the
project and in accordance with the
NYSDEC Draft Protocol for Conducting
Bird and Bat Studies at Commercial
Wind Energy Projects. The dates were
recommended in the Final Scope of
Work. The study was conducted for the
purposes of preparing an EIS under
SEQRA.

The radar study was not designed to


assess use of the island as a stopover for
migratory bird species. It was used to
provide information on the abundance,
flight altitude and direction of birds and
bats. The diurnal bird studies and to
some extent the winter and breeding bird
surveys account for the specific species
using the island as a stopover habitat.

The radar study was conducted in


accordance with criteria established in
the NYSDEC scope of work for the

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.3-31

2.5.3-32

migration. This sampling occurred


from August 8 to October 7, 2008;
however, fall migration generally
starts in July and extends into
December.
Birds such as
shorebirds, water birds, raptors, and
waterfowl were probably missed
during these surveys. Some late
passerine migrants would not have
been counted as well.
Our
recommendation is that additional
radar surveys be conducted from
July to December to cover the
entire period of fall migration.
Source: USFWS
We note that the NYSDEC
Guidelines for Conducting Bird and
Bat Studies at Commercial Wind
Energy Project (2009) specifies that
for certain areas of the State where
a higher risk to wildlife is possible,
expanded pre-construction surveys
should be completed.
The
Hounsfield Wind Project falls
within two of the criteria which
necessitate
additional
study,
including 2.b.ii, within 5 miles of
the Great Lakes, and 2.b.iii, within
2 miles of areas which concentrate
raptors, waterfowl, or species of
special concern. Therefore, the
project sponsor should adhere to
the guidelines and conduct at least
one additional year of radar
surveys. Doing so will provide a
more robust data set and account
for annual variations in the data.
Source: USFWS
The diurnal avian surveys were
conducted approximately weekly
from late March through July. Five
stations were established and
surveyed for 20 to 30 minutes each.
Data on individual species was
collected and indicated that gulls
(ring-billed and herring) were most
numerous over the island. These
3-72

project and in accordance with the


NYSDEC Draft Protocol for Conducting
Bird and Bat Studies at Commercial
Wind Energy Projects. The dates were
recommended in the Final Scope of
Work. The study was conducted for the
purposes of preparing an EIS under
SEQRA.

The avian and bat studies that were


performed for the Project were
developed in consultation with the
NYSDEC and are in accordance with the
Final Scope of Work for the SEQRA
process and the NYSDEC Protocol for
avian and bat studies. All relevant
factors were taken into consideration
during the design and approval of the
studies.

An additional diurnal avian survey was


conducted and is found in Section 2.5.3
of the FEIS.

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.3-33

2.5.3-34

species along with Caspian terns


could be at risk from collision
based on flight altitudes and
patterns. Passerines were observed
in pulses and some fall-out onto the
island was noted. Important data
on passage rates, flight behaviors,
habitat use, and timing were
obtained.
Noteworthy, is the
passerine behavior when birds
reached the end of the island and
some turned around and flew back
along the length of the island. If
flying through the turbines, this
would increase the risk for collision
since the birds would be flying
through or around them twice. We
believe this survey effort is worth
repeating to confirm study findings.
The study should be initiated in
early March to capture more of the
early spring migration.
Source: USFWS
Included in this study were radar
images from a local weather station
which showed a large mass of
waterfowl moving along the eastern
end of Lake Ontario on March 27,
2008.
We raise the question
whether similar weather data can be
reviewed for other portions of the
year, and/or other years, to gain
knowledge of migration over the
project area.
Source: USFWS
Impacts to birds are discussed on
Page 2-92, and while there is a
section on forest habitat and
fragmentation and displacement of
sensitive species, little is mentioned
about grassland species. While no
very large blocks of this habitat
type exist on the island, there are
blocks which currently exist but
may be fragmented and made
unsuitable for obligate species
(such as bobolinks). Grassland
3-73

The radar images were used to


supplement the actual observations that
were made on March 27, 2008 by the
researcher. The images provided
suggested flight origin and direction. In
regard to waterfowl, the studies have
shown very little activity over Galloo
Island and review of a massive amount
of weather data would not provide
additional meaningful data beyond the
actual observed results during the
studies.
An additional breeding bird survey was
conducted on Galloo Island and is found
in Section 2.5.3 of the FEIS. Upstate
Power will provide mitigation for open
field
habitats
by
controlling
swallowwort, and mowing to maintain
open field habitats. Impacts to breeding
bird populations, including grassland
species, are discussed in the Avian Risk
Assessment contained in Appendix P of
the DEIS.

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.3-35

2.5.3-36

breeding bird surveys should be


conducted in these areas to
determine the extent of breeding
activity and use. Surveys should be
conducted from early June through
August at least once per week.
This should be reviewed and
discussed in the report.
Source: USFWS
It is reported on Page 2-95 that the
project has been designed to lessen
the impact on avian habitat, such as
forest, wetland, and grassland
habitats, to the extent practicable.
We do not find this statement to be
substantiated. It appears the project
is designed to fit the greatest
amount of turbines on the island
and
only
avoid
wetlands.
Consequently, the other habitats are
bisected in a regular pattern.
Source: USFWS

No portion of the island has been


set aside to preserve wildlife
habitat. Our recommendation is to
reduce the number of turbines in
those areas that are of the most
importance to birds.
Source: USFWS

3-74

Grassland
species
impacts
were
discussed in the DEIS and included
habitat loss, displacement, and potential
habituation to wind structures, among
other effects.

The Proposal discussed in the DEIS is


not the maximum build-out alternative.
See Section 3.3 of the DEIS. Also the
ECS has been redesigned since
publication of the DEIS to more closely
follow the road alignment, thus reducing
forest fragmentation compared to the
previously proposed plan. The revised
plan does create some additional loss of
potential grassland in the northern end of
the island, currently in agricultural
production, and impact an area of native
grassland at the south end of the island
where Upland Sandpiper and Northern
Harrier were observed. The project
sponsor will continue to consult with
DEC to develop management plans for
the existing agricultural lands, control
pale swallow-wort, and propose further
avoidance/minimization in the native
grassland area. Also, refer to our
responses to the USFWS comments on
fragmentation
and
habitat
loss
(comments listed in 2.5-5).
Comment noted.
The project as
designed utilizes portions of the island
that are not regulated or unavailable due
to ownership. Several large areas of
wetlands of the island have been avoided
and will remain intact. The proposed
turbine on the DEC property at the
southern end of the island has been
eliminated. Furthermore, fragmentation
and loss of habitat has been reduced
from the original proposal by collocating
ECS and roads in a number of locations.
The substation was also moved to the
eastern edge of the island to the

Hounsfield Wind Farm


Final Environmental Impact Statement

agricultural area. These changes have


reduced impacts to forested areas by
6,780 linear feet (though as a result there
will be some additional impacts to
grassland area habitat). Although the
project will, in some cases, divide open
fields and deciduous upland forests, the
tracts or parcels that remain are still of
relatively large size and will provide
habitat to serve life cycles of wildlife on
the island.
2.5.3-37

2.5.3-38

2.5.3-39

Collision
risk
from
project
operations is discussed on Page 296 and concluded that there is no
information to suggest impacts will
be anything but low. However,
Galloo Island is a unique setting,
there are very few examples of
avian studies with which to
compare to (none in the northeast),
and the brief study period (1 year)
makes it extremely difficult to
predict risk. Considering that many
State-listed species and species of
conservation concern are found on
the island, including Caspian tern
(which is found adjacent to the
project, in one of only two colonies
in the State), more careful study is
warranted.
Source: USFWS
Further, several listed raptor
species may be at risk of collision,
including the bald eagle, and
warrant a cautious approach.
Source: USFWS
In summary, we find the DEIS does
not contain adequate information
regarding potential impacts of the
project on wildlife, and additional
environmental review is necessary.
Baseline information on biological
resources is incomplete or omitted.
Data are lacking for a complete
understanding
of
migrating,
breeding and wintering birds.
3-75

Additional diurnal bird, breeding bird,


and winter bird surveys were conducted
and may be found in Section 2.5.3 of the
FEIS. The actual observations on-site
account for any unique setting
characteristics of Galloo Island such as
species composition, breeding, and
migrating (including stopovers) and
flight patterns, altitudes, and directions.

Comment noted. Bald eagle is addressed


in the Avian Risk Assessment.

Additional studies as specified in


responses above have been completed
and studies will continue into the post
construction monitoring period.

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.3-40

2.5.3-41

Comment
#
2.5.4-1

Surveys during migration and


breeding seasons were conducted
for only 1 year.
Source: USFWS
Overall, we find that insufficient Additional studies as specified in
data were collected at the project responses above have been completed
site to determine the spatial and and studies will continue into the post
temporal use of the project airspace construction monitoring period. Upstate
by
flying
animals.
Our Power has performed the studies as
recommendation
for
wildlife specified by the NYSDEC in the Final
studies at wind projects generally Scope of Work and in accordance with
specifies that data be collected over the NYSDEC Protocol for conducting
multiple seasons and years to bird and bat studies at commercial wind
determine
average
annual energy projects.
conditions. Because of variability
in
migration
and
weather,
collecting data for 1 year likely
does not reflect typical wildlife use
in the project area. Therefore, we
find that insufficient data currently
exist to adequately conduct a risk
assessment and predict wildlife
mortality for this project.
Source: USFWS
Overhead
lines
can
cause The potential for avian and bat collision
substantial avian and bat mortality with overhead power lines and poles is
due to collisions with lines and acknowledged.
The
project
will
poles. Avian electrocutions can incorporate procedures found in
occur if these structures are not Suggested Practices for Avian Protection
properly designed. An important on Power Lines by the APLIC.
resource for planning power line
corridors was produced by the
Avian Power Line Interaction
Committee and should be followed.
Source: USFWS
Topic: Bats
Comments
Responses
It is stated on Page ES-13 that a
small population of migratory bats
may be at risk of collision with
turbines. However, it is not clear
how the migratory bat population
size was determined.
We
recommend the term small not be
used in this context.
3-76

The bat risk analysis was based on mist


net surveys and acoustic monitoring.
The analysis and procedures that were
used for the risk analysis are consistent
with the NYSDEC Guidelines for
Conducting Bird and Bat Studies at
Commercial Wind Energy Projects.
Based on these onsite studies,

Hounsfield Wind Farm


Final Environmental Impact Statement

Source: USFWS

2.5.4-2

2.5.4-3

2.5.4-4

Several mitigation measures are


listed in the text including post
construction monitoring.
The
Service will work with the project
sponsor on developing appropriate
monitoring protocols.
Source: USFWS
The use of adaptive management as
a means of mitigating impacts to
bats (and birds) is not listed. Prior
to project approval, the NYSDEC,
as Lead Agency, should require
measures which would offset
unavoidable impacts. This would
include, but not be limited to,
measures such as turbine shut down
during certain times or during
migration season, the feathering of
blades, and adjusting the cut-in
speed of turbines during periods
when wind speed is low and little
energy is being generated but when
bat activity is highest. This is the
period when most bats are killed as
documented by recent research.
Further, we recommend operational
modifications be mandatory during
low wind speed nights between
July 15 and September 15 to
mitigate predicted impacts to bats.
Source: USFWS
Two related comments:

knowledge of regional bat populations


and migrations, and losses found at
operational
facilities,
the
NEES
researchers used professional judgment
to indicate that small populations may be
at risk. (See Appendix O of the DEIS)
The term small was aimed at the risk
involved, not just the size of the
population since detailed population
studies are beyond the scope of this
DEIS. We acknowledge that the use of
the word small is subjective.
Comment noted. The post-construction
monitoring program will meet the
standards established in DEC Guidelines
for Conducting Bird and Bat Studies at
Commercial Wind Energy Projects.

Proposing adaptive management at this


time would be premature. The Bat Risk
Assessment determined that impacts
would not be significant. If studies
subsequent to project commissioning
identify
unanticipated
significant
impacts, that would be the time to
identify and implement mitigation
strategies, which could include adaptive
management techniques.

Proposing specific adaptive management


measures at this time would be
Comment 1: To mitigate potential premature. The bat Risk Assessment
impacts to bats, turbine operation determined that impacts are not
3-77

Hounsfield Wind Farm


Final Environmental Impact Statement

should be curtailed when bats are


most active and at a higher risk of
collision. This includes during fall
migration (between July 15 to
September 15), 5 hours after sunset,
and when wind speeds are less than
6 meters per second (turbines
should have a cut in speed of 6
meters per second).
Recent
research at the Meyersdale Wind
Project in Pennsylvania showed that
bat mortality is reduced when
turbines are not operational during
low wind periods.
Source: USFWS

anticipated to be significant. If studies


subsequent to project commissioning
identify
unanticipated
significant
impacts, adaptive management measures
would be identified and implemented.
Although the need for adaptive
management and specific adaptive
management techniques cannot be
identified at this point, such measures, if
necessary
would
likely
involve
operational interventions, like those
referenced by the commenter, or habitat
conservation/improvement that results in
a net conservation benefit for an
impacted species.

Comment 2: The project sponsor


has indicted in the DEIS that
mitigation measures, such as a postconstruction wildlife monitoring
plan, will be developed. However,
few details are provided at this
point in time. Further, monitoring,
in and of itself, is not an adequate
mitigation
measure.
We
recommend the document not be
approved until the project sponsor
develops an adequate monitoring
plan which includes adaptive
management measures which can
be implemented to reduce wildlife
mortality.
This would include
mitigation measures such as turbine
shut down during certain times or
during a migration season, the
feathering of blades, adjusting the
cut in speed is low and little energy
is being generated but when bat
activity is highest, and the removal
of turbines in locations may result
in higher mortality. Only after
these commitments have been
provided in writing should the
project be approved.
Source: USFWS
Topic: Post Construction Monitoring Plan
3-78

Hounsfield Wind Farm


Final Environmental Impact Statement

Comment
Comments
#
2.5.5-1
The report states that it is unknown if
waterfowl movements will be
affected by the proposed project. If
the project is built, we suggest that
post-construction
monitoring
evaluate this issue.
Source: USFWS

2.5.5-2

Two Related Comments:


Comment 1: The Service typically
recommends that these studies be
conducted over multiple years of
project operation and be conducted at
all times of the year and under varied
weather conditions. If turbines will
be located within blocks of grassland
habitat,
we
recommend
that
information
be
gathered
on
displacement of grassland nesting
birds.
Source: USFWS
Comment
2:
The
Service
recommends that all wind power
projects that proceed to construction
should be monitored for impacts to
wildlife following construction and
during turbine operation.
Postconstruction bat and bird mortality
monitoring should occur for a
minimum of 3 years. Proposals for
conducting monitoring should be
coordinated with both the Service and
the NYSDEC to ensure they are
comprehensive,
accurate,
and
correctly timed. Information gained
from post-construction monitoring
will continue to aid the Service and
project sponsors as we learn more
about potential impacts, or lack
thereof, to wildlife in the project area.
We recommend that project approval
3-79

Responses
The
Post-Construction
Monitoring
Protocol includes diurnal movement
studies.
The
Post-Construction
Monitoring Plan has been submitted to
DEC and reviewed.
One of the
purposes of the diurnal movement
surveys is to document waterfowl
activity. These will be done weekly
from April through July during the
monitoring program.
As stated on page 2-110 of the DEIS,
State and Federal regulators, including
NYSDEC, are requiring developers of
wind energy projects to conduct postconstruction studies at large scale
facilities. The Project sponsor will work
with the regulatory agencies and
USFWS in development of a final plan
for post construction monitoring.
Currently, the scope and framework of
the study is discussed in Section 2.5.5 of
the DEIS and includes a multiple-year
plan to monitor collisions that covers a
time-frame of approximately three years
of operations. The post-construction
monitoring plan will be developed and
approved by DEC prior to the issuance
of the wetland permits.

Hounsfield Wind Farm


Final Environmental Impact Statement

not be given until after the details of


the post-construction monitoring plan
have been reviewed and approved by
the Service and the NYSDEC.
Source: USFWS
Topic: Fish and Aquatic Species
Comment
Comments
Responses
#
2.5.6-1
The cumulative effect of the Project The proposed action that is subject to
with the related electric transmission review in the DEIS is located entirely on
facilities may adversely affect Galloo Island and the construction and
sensitive fish habitat. The proposed operation will not affect any sensitive
alternative transmission facility route fish habitat or Significant Coastal Fish
traverses the shallow shoals between and Wildlife Habitats (SCFEWH) as
the designated Stony Island and Calf designated by the NYSDOS under the
Island significant coastal fisheries NYS Coastal Management Program.
habitat areas. The Article VII The submerged electric cable from the
application
and
supplemental island to the mainland, and the potential
information filed by Upstate New impacts to SCFWH are being reviewed
York Power Corp. with the Public as part of the New York State Public
Service Commission (PSC) in Case Service Commissions Article VII
09-T-0049 indicates that mitigation application and for the USACE permit
measures, including the use of required under Section 10 of the Rivers
horizontal directional drilling will be and Harbors Act and Section 404 of the
employed, to avoid open trenching in Clean Water Act. Upstate Power
the shallow water area which selected the northern route for the
supports fisheries spawning. This submerged cable as the preferred
technology is useful in minimizing alternative specifically to avoid the
in-water disturbances in many sensitive fish habitats and SCFWH
situations, however how that areas. Any concerns related to the
technology would be applied at this technology involved in horizontal
setting has not been explained.
directional drilling beneath the sensitive
shoal areas at alternative routes will be
Source: DPS
addressed through the Article VII
review process and the ultimate
certification of the transmission line.
2.5.6-2
Several SCFWHs are located within The SCFWH closest to Galloo Island
close proximity to the proposed are Little Galloo Island, Calf Island, and
project site and because of the Stony Island with Little Galloo being
selected wind turbine's significant the closest. The Calf Island/Stony Island
vertical profiles, avian utilization of SCFWHs are significant habitats for
these SCFWHs may be affected. wildlife because they are one of the few
Specific
pre-construction locations regionally where Blackcharacterization of avian uses of the crowned Night Herons are found and are
SCFWHs should be required along reported nesting. Nesting Doublewith sufficient post construction crested Cormorants are also found on
3-80

Hounsfield Wind Farm


Final Environmental Impact Statement

monitoring to quantify any potential


effects. Appropriate provisions for
operating
procedure
adaptation
should be included in the DEIS
should
effects
on
proximate
SCFWHs become evident. These and
all other wildlife monitoring data
should be presented to all regulatory
agencies and made available for
public inspection.
Source: DOS

these SCFWHs. Little Galloo Island is


significant as a nesting area for a large
number of various colonial waterbird
species, nesting Ring-billed Gulls, and
Double-crested Cormorants. Calf Island,
based on the NYSDEC 2008 survey,
had
about
170
Double-crested
Cormorant nests and 16 Black-crowned
Night Heron nests. The diurnal bird
movement survey performed by Old
Bird, Inc for Galloo Island documented
the cormorant flight pattern over the
island. Although it is unknown whether
any cormorant individuals specifically
from Calf Island were passing over
Galloo Island, since NYSDEC is
controlling the number of breeding
cormorants (on Little Galloo Island) the
impact of the Project on Calf Island
cormorants would not be of concern.
Because Calf Island is further than Little
Galloo from Galloo Island it would be
less likely for Calf Island cormorants to
fly over Galloo than those nesting on
Little Galloo Island.
Black-crowned Night Heron activity on
Galloo Island was documented in
several of the studies conducted by Old
Bird, Inc. No nest sites were found but
up to six birds were frequently
documented to be present on Galloo
Island at dusk during the breeding
season. It is therefore likely that the
birds were not Calf Island nesters.
However, the birds from the Calf Island
colony may make regular visits to
Galloo Island. It is suspected that Calf
Island birds would be more likely to use
the closer Stony Island for foraging. No
Black-crowned Night Herons were
observed in any of the Galloo Island
bird studies making flights from Galoo
toward Calf or Little Galloo Islands.
Impact on the Calf Island Blackcrowned Night Heron colony is
unlikely.

3-81

Hounsfield Wind Farm


Final Environmental Impact Statement

Detailed results that are contained in the


DEIS Avian Risk Assessment indicate
that the wind farm will not have a
significant impact on the viability of
avian species associated with the
SCFWHs near Galloo Island. The risk
assessment shows that the turbine
locations will not have a significant
impact on the viability of the Little
Galloo Island waterbird colony.
Further, avian and bat radar studies
demonstrate that mean seasonal target
flight height, as well as mean seasonal
targets below turbine height, observed at
Galloo Island, are within range of other
similar regionally based studies and tend
to support indications of lowered risk of
collision at the site due to the fact that
much of the season migration occurs at
heights well above the turbine heights.
Given the lowered risk of collision at
the site, it is not anticipated that the
turbine locations on Galloo Island, or
any other project components, would
result in impacts to avian species
associated with nearby SCFWHs.
Impacts from the transmission line on
avian species associated with SCFWHs
is contained in Exhibit 4 of the Article
VII application. As indicated on page 2110 of the DEIS, state and Federal
regulators, specifically NYSDEC and
USACE, are requiring developers of
large-scale wind energy projects to
conduct post-construction studies of
avian and bat mortality.
While based on the existing studies we
do not anticipate significant impacts on
avian species, a multiple-year plan to
monitor collisions that covers a timeframe of approximately three years of
operations is envisioned. Specifics of
these post-construction studies are still
pending. It is premature to speculate on
possible operational adjustments to
3-82

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.6-3

If they were going to do any dredging


in Gill Harbor, that they would
mitigate any disturbance to the
spawning areas for the small mouth
bass and northern pike that populate
that area.
Source: Mitch Franz (H)

2.5.6-4

An intake line will be installed to


supply potable water. Details on the
water line are lacking and have been
changed several times, but the text
indicated that intake velocities will be
small and no impacts are expected to
aquatic life.
We request that
adequate
supporting
data
be
provided. Most of the intake line
would be 30 feet below the water
surface so as not to interfere with
boat navigation.
An unknown
quantity of water would be
withdrawn from the lake by use of a
pump. A separate chemical feed line
would be used to clean the intake
screen.
Source: USFWS

2.5.6-5

It is not clear if appropriate hydraulic


evaluations were completed to
determine if potential water velocities
at the intake. This analysis is needed
to determine if impingement or
3-83

address possible post construction


impacts because: (1) at this time such
impacts are not anticipated and (2) in
the event post construction studies
revealed that there were significant
impacts, the determination of an
appropriate response would have to be
made based on the particular facts and
circumstances revealed in such post
construction studies.
Although work was initially proposed in
Gill Harbor for a temporary unloading
facility, this structure will now be
located on the southwest end of the
island in the same area proposed for the
permanent unloading facility. The water
intake and treated sewage outfall
structures are located to the west side of
the peninsula forming Gill Harbor.
There will no dredging or other work
located in or adversely affecting Gill
Harbor.
The selection of the thirty foot depth
contour for the water intake structure is
not only for navigational purposes but
also is a recommended depth (in most
power plant and manufacturing facilities
in the Great Lakes) to reduce impacts to
the fisheries and to prevent buildup of
frazil ice. 15 gallons per minute are
required for potable water needs. The
intake velocity of the structure will be
kept below 0.5 feet per second. Since
the flow and volume of water to be used
are very low, adverse impacts on
fisheries are not expected. Although
screen materials to be used at the intake
head are those that minimize biofouling,
a separate chemical feed line is also be
installed for periodic removal of
biological growth should it present a
problem.
The entrainment and impingement of
adult and juvenile fish, larvae and
ichthyoplankton and zooplankton is
generally attributed to
very high
volume and high velocity intake

Hounsfield Wind Farm


Final Environmental Impact Statement

2.5.6-6

entrainment of aquatic life would structures that are associated with


occur during water withdrawal.
cooling and process waters for steam
Source: USFWS
electric generating stations and major
manufacturing plants. Detailed studies
and hydraulic analysis for major steam
electric
generating
stations
and
manufacturing facilities to assess
impingement and entrainment are
required under Section 316 (b) of the
Clean Water Act. However these types
of detailed analysis are required only for
facilities that withdraw over 2 million
gallons of water per day for cooling
purposes and also require NPDES
discharge permits. These requirements
do not apply to water intake facilities
such as those proposed on Galloo
Island. The intake structure at Galloo
Island will withdraw a maximum
(during construction) volume of only
15,000 gallons of water per day (gpd).
This will drop to about 2,500 gpd with
maximum flows of 5,000 gpd during
operations and maintenance.
No
substantial impacts are expected. Also
see response to comment 2.13-6 below.
Impingement, the trapping of aquatic This comment correctly states that one
life against the intake screen, can of the factors influencing impingement
result in injury, predation, or death to is the water intake approach velocity at
organisms unable to escape intake the intake head. However, some studies
flow velocity. The Service typically indicate that that physical location,
recommends that approach velocities withdrawal volume and characteristics
at the intake not exceed 2 feet per of an intake may be more important.
second so that aquatic life will be Many impingement studies in the Great
able to escape the intake flow. Lakes have indicated that placement of
Entrainment is the removal of aquatic structures at about the 30 foot depth
life into the intake pipe. A wedge contour or greater will generally reduce
wire screen or similar device is used impingement and entrainment. Small
to prevent entry into the pipe, but if water intake structures such as the one
the openings are too large, smaller proposed for Galloo Island are not
fish, larval fish, eggs, and typically
associated
with
high
invertebrates can be drawn into the impingement and entrainment losses and
pipe. We typically recommend a 2 therefore are not regulated under
millimeter clear spacing in the mesh Section 316 (b) of the Clean Water Act.
openings. The intake opening should The low volume of water withdrawal,
be set perpendicular to flow. We use of appropriate sized screening and
recommend that the DEIS provide location at the 30 foot contour indicate
3-84

Hounsfield Wind Farm


Final Environmental Impact Statement

more information regarding


design of the water intake.
Source: USFWS

the that impact will be low. The intake


velocity will be less than 0.5 fps. The
intake head will have a screen cap
consisting of a bar-rack frame which
will support a finer screen with 2 mm
maximum openings. This finer screen
will be either woven mesh or wedge
wire screening.
Topic: Visual Resources
Comments
Responses

Comment
#
2.6-1
The Sackets Harbor Battlefield State
Historic Site will have views to the
Project facilities (as depicted at DEIS
Visual Impact Assessment (VIA)
Figure A12b). The recently installed
Wolfe Island wind turbines, located
over 18 miles northwesterly from the
Historic Site, are visible from the
waterfront overlook area at the Site
during periods of clear visibility. The
EIS should document current
visibility and address cumulative
effects of the Hounsfield Project on
this highly significant cultural,
historic and visual resource.
Source: DPS
2.6-2
Darker blue-gray coloration should
be considered as potential mitigation
measure for turbine towers, to reduce
long-range visibility from historic
and scenic resources at shoreline and
upland locations, with open vistas
across open water.
Marine
camouflage concepts should be
evaluated for applicability in this
project based on the waterfront
setting of most significant resources
with views to the project.
Source: DPS

3-85

Field visits and photos did not show


visibility of the Wolfe Island Turbines
from the Sackets Harbor Battlefield.
The site was visited on at least two
occasions with clear visibility.

To address these comments a number of


additional photosimulations were done.
In
particular
the
following
photosimulations were completed from:
Simulations of blue-gray turbines
with required white lights during a
clear day from Sackets Harbor
Battlefield, Wehle State Park and
Eastern Ontario Waterway
Access.
Simulations of blue-gray turbines
with required white lights during a
cloudy day from Sackets Harbor
Battlefield, Wehle State Park and
Eastern Ontario Waterway
Access.
Simulation of white turbines during
a cloudy day from Sackets Harbor
Battlefield, Wehle State Park and

Hounsfield Wind Farm


Final Environmental Impact Statement

2.6-3

Project visibility from the NYS


property at the southeastern portion
of Galloo Island is not thoroughly
reported or represented in the DEIS.
This area is part of a State Wildlife
Management Unit, as noted in the
DEIS. The setting of this property
includes open old field and
waterfront sites, including a white
sand beach which is a significant
visual resource. Attached Photograph
19 depicts the view northeasterly
from the beach on New York State
lands. Proposed wind turbine
generators 2, 3, 9 and 10 would be
arrayed along the waterfront setting,
with additional turbines 19, 20 and 27
located further behind the nearest
turbines. This site has high intrinsic
scenic
quality,
due
to
the
undeveloped shoreline, contrast of
white sand (shell) beach and stony
shallows. The site also has
southeasterly views to the historic
Galloo Island Lighthouse.
3-86

Eastern Ontario Waterway


Access.
The simulations show that blue-gray
turbines would provide a minor amount
of camouflage of the turbines.
However, the required lighting would
increase the visibility of the turbines to
make it nearly equivalent to the
currently proposed white turbines. The
required intensity of daylighting would
be 20,000 candelas compared to the
2,000 candelas for night lighting.
Additionally, although the FAA circular
regarding lighting wind turbines does
not prohibit blue-gray turbines, it is
clear that white is the preferred color.
Therefore, since the impact is not
significantly reduced and painting the
turbines may not be approved by the
FAA due to concern regarding plane
safety, a blue gray color will not be
required for the Hounsfield Wind Farm.
A simulation was done of the towers for
the photograph 19 that was provided by
DPS. The simulation is an estimate of
visibility, exact photo location, focal
length and orientation were not
provided. However, this is a reasonable
estimate of visibility. Nearly a dozen
towers or portions of towers are visible
in the simulation. The visibility of the
project will be similar as to what was
presented in other near view simulations
of the island. Although, the commenter
feels the site has high intrinsic scenic
quality, the limited site access severely
restricts the use of the site. Therefore,
this simulation does not change the
impact analysis presented in the DEIS.

Hounsfield Wind Farm


Final Environmental Impact Statement

2.6-4

2.6-5

2.6-6

2.6-7

Source: DPS
Consideration of offset mitigation is
recommended to be explored only
after a detailed consideration of direct
mitigation
opportunities.
DPS
recommends that consideration of
specific mitigation strategies for
important State resources including
State Parks such as Robert Wehle and
Westcott Beach State Parks, the
Sackets Harbor Battlefield State
Historic Site, the Seaway Trail
Scenic Byway and two New York
State properties on Galloo Island
should be given serious consideration
in impact mitigation efforts.
Source: DPS
The discussion of meteorological
effects indicates that at distances of
5.6 miles the project may appear
indistinct. While this statement would
reflect periods of haze, observations
in the broader project area reveal that
there are conditions where large
facilities, such as wind turbines and
thermal facility cooling tower and
plume, are visible with some
distinction at significantly greater
distances in this area of low terrain
and open water.
Source: DPS
Discussion under the subheading
"Viewshed Analysis" includes an
incomplete sentence at the start of the
second paragraph, which should be
corrected ("en views of the Project
will be available from offshore
vantage points...").
Source: DPS
Project visibility from NYS lands on
Galloo Island warrants additional
evaluation and impact assessment. As
noted above under discussion of
Cultural Resources, project impacts
on the NYS owned historic Coast
Guard Station site will be significant
due to the close offset of project
3-87

As stated by SHPO Given the unique


circumstances associated with this
portion of the project (turbine field
development) we see no reasonable way
in which the affects associated with the
construction of these units on Galloo
Island can be avoided or minimized
through layout alteration or unit number
reduction. NYSDEC agrees with this
assessment, and therefore offset
mitigations would be appropriate for
this project.

There are certain distinctive elements of


the region that are visible at distances
greater than 5.6 miles, including wind
turbines and elements of the nuclear
power plant, in particular over the open
water. The DEIS evaluated impacts to
resources from as much as 15 miles
from Galloo Island.
The visual
simulations prepared for the DEIS show
that although visible at distances greater
than 5 miles the turbines often become
minor features at this distance.

Comment Noted. The sentence should


read Views of the Project will be
available from offshore vantage points
on Lake Ontario.

As stated by SHPO Given the unique


circumstances associated with this
portion of the project (turbine field
development) we see no reasonable way
in which the affects associated with the
construction of these units on Galloo
Island can be avoided or minimized
through layout alteration or unit number

Hounsfield Wind Farm


Final Environmental Impact Statement

2.6-8

2.6-9

2.6-10

components from that site. Most


notably, 410 feet tall turbines will be
located within 500 feet of the site.
The photo-simulations in Figure A19 depict in pan the appearance of the
proposed turbine array in relation to
the former Coast Guard Station
buildings. Notably missing are the
highest elements of the nearest
turbines, which (as indicated in
figures A19-f and A19-j), are too tall
to include in the photographs as
framed. From the vantage of the
USCG building settings, it is likely
that nearly all of the project turbines
will be visible from these buildings.
Mitigation
options,
including
increasing setbacks or removal of the
turbines nearest to the buildings,
should be addressed in an alternatives
analysis.
Source: DPS
The discussion of "Impact on Visual
Resources" does not address lands of
New York State with foreground
views of project components,
including the former USCG Station
and the Wildlife Management Area,
located on Galloo Island.
Source: DPS

Consideration of mitigation of
impacts on those facilities is likely to
be warranted. Direct mitigation
should be explored in detail prior to
adoption of an off- set mitigation
program.
Source: DPS
Characterization of impacts should
include discussion of specific
contrasts, including turbine color
contrasts with other landscape
elements; and rotational motion of
3-88

reduction.
It is unlikely that the
removal of turbines would mitigate the
visual impact on these properties, as
stated in the comment nearly all of the
project turbines will be visible from
these buildings.
NYSDEC does not have required
setbacks
from
state
property.
Additionally, although these properties
are owned by the State, there is no
developed public access on these
parcels.

A simulation was prepared from a


photograph provided by the commenter
from a location representative of the
Wildlife area. The simulation is an
estimate of visibility, exact photo
location, focal length and orientation
were not provided. However, this is a
reasonable estimate of visibility.
Turbines will be visible in the
foreground. However, this area is not
actively managed or used, so there will
be no significant impact to the
enjoyment of the property.
No mitigation is required for impacts to
NY State lands on Galloo Island,
because although the turbines will be
visible, they will not significantly
impact current use of the properties.

The VRA was conducted in accordance


with the scope for the DEIS and agreed
upon with the lead agency and others. It
is also consistent with the NYSDEC
Program
Policy:
Assessing
and

Hounsfield Wind Farm


Final Environmental Impact Statement

turbine blades at fixed positions,


which
contrasts
with
static
background and setting, as well as
with other ephemeral elements that
move with the wind, such as
sailboats, waves and wildlife.
Source: DPS

2.6-11

Additional consideration of the


Seaway
Trail
and
resources
associated with this scenic touring
route should be provided in the EIS
for both visual and cultural resource
significance. The Seaway Trail is a
designated Scenic Byway, as well as
a National Recreation Trail in the
National Trails System by the United
States Department of the Interior,
National Parks Service. The Seaway
Trail has guiding goals, management
policies and specific program
initiatives as documented in the 2005
Corridor Management Plan. That
plan includes a Development Plan,
Interpretation Plan, Management
Plan, Surveys and Inventories of
resources, and a Marketing Plan.
Some of the details of the Corridor
Management Plan which most
3-89

Mitigating Visual Impacts (NYSDEC,


2000).
The static, clear day views of the WTG
in the VRA are likely a worst case
analysis in that they focus the viewers
attention on a single depiction of the
array under the most favorable
atmospheric conditions for viewing.
They do not account for the distractions
and ameliorating effects of less
favorable
atmospheric
viewing
conditions, which are the predominant
case in this region. Also, as the question
may also imply, these views do not
account for the fact that in a real
world kinetic view there are numerous
other
distractions
that
will
reduce/ameliorate impacts, including
movement of other landscape features
including waves, trees, sailboats, cars
etc. the viewer him/herself, which will
compete for the viewers attention and
thereby further reduce any potential
impacts of the distant, background
views of the WTG.
Specific comments about the Seaway
trail are addressed below.
(See
Response to Comments 2.6-12 to 2.616).

Hounsfield Wind Farm


Final Environmental Impact Statement

2.6-12

closely relate to the Hounsfield Wind


Farm project study and related
transmission facilities study areas are
discussed
below.
Additional
consideration of project impacts on
the Scenic Byway and identified
resources,
plans
and
recommendations is warranted for
development of the EIS for the
project.
Source: DPS
Recommendations for Development
of the Scenic Byway in the Seaway
Trail Corridor Management Plan and
Development Plan include bywaywide recommendations, including a
key goal for any scenic resource:
"Preserve and Enhance Scenic
Quality."
Site-specific
recommendations
include resources in the vicinity of
the shoreline in the project study
area, including the Henderson Harbor
Overlook, and Sackets Harbor
Battlefield State Historic Site, as
detailed in the Seaway Trail
Interpretive Plan.
Henderson Harbor Overlook
The Henderson Harbor Overlook is a
NYS Department of Transportation
parking area and overlook with a
spectacular panoramic view of
Henderson Bay and Lake Ontario.
Currently, there is only limited
interpretation
and
travelers
information available. The Seaway
Trail Development Plan indicates that
specific
development
strategies
include:
Implement vegetation
management plan to maintain
and enhance scenic vista;
Develop visitor services including
byway interpretation.
3-90

Any vegetation management would not


significantly alter the view to Galloo
Island, it would increase the linear feet
of open view. As shown in the visual
simulation included in the VIA in the
DEIS, the view to the WTG is distant
with only the top of blades visible. This
is a very minimal view of the WTG. The
presence of turbines on Galloo Island
would not dominate the vista of
Henderson Harbor, nor be part of the
midrange view, from this location
Although clearing may expand the view
it would not change the impact.

Hounsfield Wind Farm


Final Environmental Impact Statement

2.6-13

DPS
notes
that
vegetation
management would enhance views to
the west, including views of
Henderson Harbor, the islands and
points-of-land near Stony Point, and
Lake Ontario. The wind turbine
facilities proposed for Galloo island
will be visible from the overlook, as
indicated in the DEIS VIA.
Enhancing the scenic vista through
clearing and trimming of vegetation,
and adding interpretive signage is
likely to increase usage of the scenic
overlook and increase the extent of
potential visibility of the proposed
wind turbines from this location.
Source: DPS
The Seaway Trail Interpretive Plan
identifies
other
subthemes
including eco-tourism and birdwatching as important tourism
development
opportunities.
Development of wind energy
projects, which can have adverse
effects on birds and migratory bats,
may create a perception of conflicting
interests for birding enthusiasts and
tourists traveling along the Jefferson
County section of the Seaway Trail
as birding theme is developed.
DPS notes that careful project siting
and operational control, to minimize
bird and bat mortality, and
educational
efforts
aimed
at
documenting and interpreting impacts
on natural populations, must both
occur to avoid significant conflicts
between potentially
competing policy goals of renewable
energy and eco-tourism development.
Source: DPS

3-91

The avian reports prepared for the DEIS


and those included in this FEIS did not
indicate there would be a significant
adverse
effect,
therefore
the
commentators reference to conflict is
not
anticipated.
Additionally,
perception is subjective and some of the
potential eco-tourists may perceive the
development of renewable energy
projects as being consistent with their
environmental principals.

Hounsfield Wind Farm


Final Environmental Impact Statement

2.6-14

2.6-15

Additional locations are noted in the


Seaway Trail Interpretive Plan,
including sites located within the
study area of the Hounsfield Wind
Farm Project and route of the
associated transmission facility. The
development
of
additional
interpretive information and links to
these sites from the Core Route 3
Scenic Byway are noted in the
Interpretive Plan.

As noted by SHPO minimization is not


feasible for this site due to the open
water views of the island.
Although the turbines will be visible
from several of these sites, based on
DECs Visual Assessment Policy, that
does not necessarily mean it is a
negative impact for all viewers.

The Henderson Harbor and Boat launch


will not have visibility of the project.
Robert Wehle State Park
Only limited views will be available
from the Harbor Overlook and Westcott
Henderson Harbor
Beach. Distant views of the project will
Henderson Harbor Overlook
be available at the locations at Wehle
Henderson Boat Launch
State Park that have cleared shoreline
Galloo Island Lighthouse
Westcott Beach State Park and looking onto Lake Ontario. There will
be significant views from the Galloo
Overlook
Island lighthouse.
DPS notes that the Hounsfield Wind
Farm
project
and
associated The views, excluding the lighthouse,
transmission facilities may have will not be foreground views and will
adverse visual effects on several of not eliminate all appreciation of these
these sites, and thus potentially affect scenic resources. Therefore, the project
the appreciation of resources will not have a undue adverse impact on
associated with the coordinated these sites or the tourism associated with
heritage tourism efforts promulgated the Seaway trail.
by the Seaway Trail and participating
municipalities and site owners and
managers.
Impact
minimization
should be fully explored in
consideration of developing final
project
layout,
design,
and
identification of appropriate permit
conditions and mitigation measures.
Source: DPS
The Sackets Harbor Battlefield and As stated by SHPO minimization of
State Historic Site encompasses 30 impacts to Sackets Harbor Battlefield
acres where parts of the first and State Historic Site is not feasible.
second battles of Sackets Harbor
were waged and where some of the Mitigations off-sets for this and other
massive fortifications that ringed the historic resources are discussed in
village once stood. The Seaway Trail Section 2.7 of the FEIS.
Off-set
Development Plan identifies specific projects will be memorialized in a
Memorandum of Agreement through the
strategies including:
Section 106 process with SHPO and
3-92

Hounsfield Wind Farm


Final Environmental Impact Statement

Support effort to receive National


Park status for expanded battlefield
site;
Support improvements to historic
site including enhanced entrance,
signage,
parking,
paths
and
interpretive facilities.

2.6-16

DPS observed in a recent site visit


that enhanced interpretive signage
has been installed, and audio
information is available via cell
phone to enhance understanding of
Battlefield features and history. DPS
notes that the Hounsfield Wind Farm
project development will result in
views to the proposed wind project
from
the
waterfront
area.
Enhancements
to
interpretive
facilities and potential for National
Park Status are likely to increase the
number of visitors to the site.
Impact minimization should be fully
explored
in
consideration
of
developing final project layout,
design,
and
identification
of
appropriate permit conditions and
mitigation measures.
Source: DPS
The Draft HAMP for the Village of
Sackets Harbor at Section 2.4.1
identifies goals of the Sackets Harbor
LWRP/HAMP, including a specific
goal of preservation, which is
profiled as "Restore, rehabilitate,
protect and enhance structures,
districts, sites and views that are of
significance
in
the
history,
architecture, archeology or culture of
the Village, state, and nation (2007;
pages un-numbered). The draft plan
also identities specific preservation
goals, including:

USACE. Off-set projects may include


additional interpretive signage that will
describe the current features visible
across the harbor in relation to its
historic nature.

There will be no limitation of public


access to the waterfront as a result of the
proposed project. The visibility from
the village-wide trail will be the same as
represented in the DEIS, as the trail
links existing sites and does not create
new destinations.

As previously stated by the SHPO, the


further minimization of visual impacts is
not feasible. WTG will not be in the
foreground and impacts will not be
significant. The consideration of onsiteaesthetic screening (vegetative or other)
would reduce the visibility of the WTG
Preserve and enhance the War of but also have an adverse effect of
1812 battlefield; and
reducing other scenic views that are
Preserve scenic views of the more prominent to the amenities of the
3-93

Hounsfield Wind Farm


Final Environmental Impact Statement

2.6-17

waterfront and open space (Section Village of Sackets Harbor.


2.4.2.3).
The HAMP also identifies Recreation It is also of note is that the Sackets
goals, including:
Harbor Battlefield is not surrounded by
a pristine environment but is situate in
Develop additional public access the midst of community with many
and active and passive recreational modern features. To the east of the
areas within the LWRP/HAMP area, Battlefield is a housing subdivision.
particularly the waterfront and areas There are other modern encroachments
consistent with projected participant as well including fences, roads, lighting
needs and demands.
and cars either in or adjacent to the
Increase number of scenic access Battlefield.
In this context the
points to waterfront areas and introduction of distant views of this
improve scenic quality of entire wind farm are not inconsistent.
LWRP/HAMP area.

Develop
a
Village-wide Additionally, potential offset mitigation
pedestrian/biking
pathway
in opportunities have been identified as
conjunction with the pathway system feasible within the battlefield setting,
developed to link major thematic including further development of the 40
areas.
waterfront acres of the original War of
1812 battlefield recently acquired by
DPS notes that the village-wide trail OPRHP, and improvements to the
was reported to have recently been Pickering-Beach
Museum
located
awarded funding by New York State directly adjacent to the battlefield site.
Department of Transportation, to
construct
a
"War
of
1812
Bicentennial Trail" (Sackets-Harbor
Gazette, April 29, 2009). The
detailed trail layout should be
reviewed for any additional scenic
vistas
that
would
warrant
consideration
in
the
visual
assessment of the Project.
Source: DPS
The Galloo Island wind power Comment Noted. Note that while towers
project will change the character of will be visible they will be distant
the Henderson area forever. You will background views and will not dominate
be able to see the wind towers from the landscape. The nighttime lighting
Henderson and from whole eastern will be the minimum allowed by the
end of Lake Ontario. This will ruin FAA.
sunsets and views of the lake which
is what makes this area so beautiful.
Most of the value of our property is
on the water not inland. We will
have to look at towers and blinking
lights at night and towers during the
day.
3-94

Hounsfield Wind Farm


Final Environmental Impact Statement

2.6-18

2.6-19

2.6-20

Source: Mike Contino


According to the Hounsfield Wind
Farm Visual Resource Assessment by
Saratoga Associates, this project will
be visible from six State Parks
facilities. From north to south, these
facilities include: - Chaumont State
Boat launch - Sackets Harbor
Battlefield State Historic Site Robert G. Wehle State Park Southwick Beach State Park Westcott Beach State Park - Stony
Creek State Boat Launch (jurisdiction
of State Parks not DEC). These six
State Parks facilities are major points
of public access to the shoreline in
this region.
The combined
attendance at these State Parks
facilities has averaged approximately
400,000 people each year during the
past five years. These facilities are
an important component of the public
recreational amenities in the region
and it is apparent that this project will
have an adverse impact on these
public facilities.
Source: OPRHP

Although there will be a change in the


visual setting at certain specific
locations within the state park facilities
identified by OPRHP, the potential
visual impacts are limited by the types
of uses of these facilities, (including
boating, hunting and hiking) and limited
available locations for scenic views of
Galloo Island.
The project will only be visible from 5
of these locations; no view will be
available from Stony Creek Boat
Launch. The impact to Sackets Harbor
Battlefield is discussed in response to
comment 2.6-16. The use of the other
parks is not closely associated with the
scenic quality of the area but rather a
specific intended use of the Park. For
example, the Chaumont State Boat
Launch primary use is for boat
launching activities and is not noted for
its scenic qualities.
The anticipated change in the visual
setting at these locations can be
mitigated by improvements to enhance
the visual settings at these parks. The
New York State Office of Parks,
Recreation and Historic Preservation has
provided recommendations for potential
offset mitigation projects at these
locations.
The GPS locations were submitted by
the Project applicant on June 10, 2009 to
Thomas Lyons.
Subsequently on
September 18, 2009 a meeting was held
between State Parks, DEC and the
Project
Sponsor.
No
additional
photosimulations were requested. Also
studies that were done were consistent
with the scope.

It is not possible to identify the


location(s) where the line-of-sight
confirmations were conducted. We
request information on the specific
locations from which the line-of-sight
field confirmations were taken,
preferably GPS coordinates, for
further review. Once we receive this
information, we may request
additional photo simulations to assist
in determining potential impacts.
Source: OPRHP
This project will be closest to Robert See response to 2.6-18. As shown in
3-95

Hounsfield Wind Farm


Final Environmental Impact Statement

G. Wehle State Park. This park was


acquired by State Parks in 2003. The
Robert Wehle State Park Interim
Management Guide, completed in
April 2004, classified this park as a
Scenic Park. State Parks has just
started to develop a master plan for
this facility. Initial analysis has
shown that the scenic vistas from the
16,840 feet of shoreline in the park
are considered one of its most
important resources and will play an
important role in determining future
park uses. The presence of the wind
farm on the horizon will affect the
current view, which presently does
not include any manmade structures.
Source: OPRHP
2.6-21

This project will also be substantially


visible from the Sackets Harbor
Battlefield State Historic Site. The
interpretation of the history of this
Site includes the view looking out
into Black River Bay and Lake
Ontario. As stated on the State Parks
web site and promotional literature:
"At the eastern end of Lake Ontario,
the Village of Sackets Harbor and the
Sackets Harbor Battlefield State
Historic Site form a seamless
community of historical richness.
Together they form the geographical
hub of Northern New York's serene
and picturesque waterfront heritage
center. The significant military and
maritime history of today's historic
site begin with the War of 1812, and
now this extraordinary place is
recognized by the National Park
Service as one of the top ten War of
1812 sites in the nation." During the
War of 1812, the British fleet often
appeared off these shores, twice
mounting attacks on the American
military fortifications and making
landfall in 1813 during the Battle of
3-96

Figure 3.0-2 there are only two defined


scenic overlooks in the Wehle
development plan that would have clear
views to Galloo Island. There are other
informal views to the Lake. However,
the entire shoreline does not have clear
visibility. Nothing in the development of
the wind farm is contrary to the Interim
Management Guide for Wehle Park.
While the WTG may be visible from
some vantage points within Wehle State
Park, the effect will not be adverse to a
portion of the visitors including those
that utilize the park for hunting, hiking
and picnicking.
There is no
information to support the idea that the
large majority of Park visitors are there
only for the scenic quality of the view of
the park.
The impact to historic structures and
properties is discussed in Comment 2.73. Impacts to historic properties have
been minimized to the extent practical
and will further be off-set by historic
off-set projects though the Section 106
process.
There are some locations from the
Battlefield Park where the Project will
be visible in the distance, however,
views of the water will remain
unchanged.
In addition, the DEC
disagrees with the statement that the
view has remained unchanged since
before the Battle since many modern
day elements have been added to the
viewshed, for example, motorboats can
be seen in the photos of current
conditions prepared for the Project
application in addition to roads and
roadside steel guard rails among others.
Nonetheless, the comment is noted and
the Project Sponsor has mitigated
potential visual impacts to this viewshed
to the extent practicable and is further
enhancing views and the appreciation
for this historic resource through the

Hounsfield Wind Farm


Final Environmental Impact Statement

2.6-22

2.6-23

2.6-24

Sackets Harbor.
On the onehundredth anniversary of the year of
the battle, Governor Franklin D.
Roosevelt dedicated a monument on
the Battlefield to the lives lost during
the War of 1812. The addition of the
Hounsfield Wind Farm will affect
this historic water view, which has
been unchanged since before the
Battle of Sackets Harbor.
Source: OPRHP
The Village of Sackets Harbor,
including the Sackets Harbor
Battlefield State Historic Site and
Horse Island is designated as the
Sackets Harbor Heritage Area
(formerly known as the Sackets
Harbor Urban Cultural Park). This
designation should be added to Table
3 of the Hounsfield Wind Farm
Visual Resources Analysis and to
Table 2.6-1 of the DEIS with a listing
of Statewide Significance.
Source: OPRHP
The Hounsfield Wind Farm Visual
Resource Analysis lists the Sackets
Harbor Visitor Center as having
Local Importance. Since the Visitor
Center is for the State-designated
Heritage Area, it should be listed as
having Statewide Significance.
Source: OPRHP
The Sackets Harbor Urban Cultural
Park Management Plan cites the
importance of the history of the
village, in particular the military
history, to the ongoing health and
development of the heritage tourism
industry in the Village and the region,
The Hounsfield Wind Farm will be
visible from the Sackets Harbor
Heritage Area.
Source: OPRHP

3-97

proposed off-set program.

Comment Noted. The table is not


republished in the FEIS. However, the
additional designation is noted.

Comment Noted.

The Urban Cultural Park Plan was


published in 1985 and is an archival
document.
It is unclear from the
comment whether there have been
follow up plans, whether the goals of the
plan were ever implemented, whether
the management objectives have been
adhered to over the last 20+ years and
what has been the application of this
20+ year old document to other
development in the area. Nonetheless,
the theme stated in this plan is
defense, referring to the historic
military importance of the Harbor area.
The Plan places significant importance

Hounsfield Wind Farm


Final Environmental Impact Statement

2.6-25

2.6-26

State Parks finds that the visual


impact of this proposal is not
consistent with the Sackets Harbor
Urban Cultural Park Management
Plan.
Source: OPRHP

Due to the importance of the views


from State Parks facilities, especially
the Sackets Harbor Battlefield and
Robert G. Wehle State Park, we are
requesting further documentation on
re-positioning,
lower,
and/or
decreasing the number of turbines to
reduce the visual impacts.
Source: OPRHP
3-98

on the military significance of the


Harbor area and the strategic value of
the deep-water port and its geographic
location. The natural environment is a
secondary theme for the UCP and is
focused on the abundance of timber,
limestone cliffs and the deep-water
resources which were used in the
development of the area as a major
shipbuilding and military installation.
Preservation of scenic views is not
mentioned in the UCP. In fact, the offset projects anticipated for the Project
are consistent with the goals of the plan
and will further enhance the historical
significance of the area. Thus, the
project is not inconsistent with the
goals or theme of the Urban Cultural
Park Plan.
It is unclear what is the basis for this
finding as there is nothing about the
theme or goals of the Urban Cultural
Park Management Plan that is
contradictory to the development of the
wind farm. The stated theme is
defense and the development of
Sackets Harbor as an important military
location. Commercial activities such as
shipbuilding and other activities in
support of this military history have
long been significant aspects of the local
economy.
Also, as noted in the previous responses,
mainland views of the Project are at
most
distant,
background
and
occasional,
given
the
prevalent
atmospheric conditions in the region.
As supported by the SHPO letter,
Given the unique circumstances
associated with this portion of the
project (turbine field development) we
see no reasonable way in which the
affects associated with the construction
of these units on Galloo Island can be
avoided or minimized through layout
alteration or unit number reduction.,

Hounsfield Wind Farm


Final Environmental Impact Statement

reduction of the project visibility if not


feasible.
Additionally, consistent with the
SEQRA Scope, the DEIS project
alternatives
adequately
reviewed
alternatives to the proposed project.

2.6-27

2.6-28

2.6-29

As was discussed in the alternatives


section of the DEIS on page 3-21 using
a turbine with a lower height would not
significantly change the visual impacts.
Therefore no additional simulations
were prepared.
Note that in the Hounsfield Wind Comment Noted.
Farm Visual Resource Analysis
"Stoney Creek Boat Launch" should
be spelled correctly as Stony Creek
State Boat Launch.
Source: OPRHP
The Seaway Trail is not only a State Comment Noted
Scenic
Byway
of
Statewide
Significance, but also a National
Scenic Byway and an All American
Road.
These
two
federal
designations should be noted.
Source: OPRHP
The discussion of lighting is limited Other on-sight lighting will be kept to a
to FAA mandated aviation warning minimum to the extent that safe work
lights. Other outdoor lighting, such environments are maintained. It is
as lighting at the various buildings of unlikely any of this light would be seen
the residential and operations and from the shore due to the distance and
maintenance areas, should conform to low intensity and low height of lights
good lighting practices. Use of full that will be installed. The lighting of
cut-off fixtures without drop-down these facilities will have far less
optics can be effective in providing significant of an impact than existing
lighting levels necessary to conform onshore development.
to all OSHA lighting requirements
for work area visibility, while
avoiding off-site lighting, reducing
glare that inhibits visual acuity, and
conserving energy, since unnecessary
lighting is avoided. Use of task
lighting at locations such as the
transmission substation can assure
that
lighting
necessary
for
maintenance activities is available as
3-99

Hounsfield Wind Farm


Final Environmental Impact Statement

needed, but that unnecessary light is


avoided.
Source: DPS
Topic: Archeological and Historic Resources
Comment
Comments
Responses
#
2.7-1
The potential for restoration and re- At this time, the USCG station is
use of the former USCG station as abandoned and there are no plans by the
some form of offices, visitor center, state or federal government for future
or similar use should be addressed as use therefore the potential adverse
a potential mitigation measure for effects on this resource from the Project
effects on this resource, which is are limited. Mitigation options for
potentially eligible for historic potential impacts to Cultural Resources
register listing. Source: DPS
are summarized in Section 2.7 of this
FEIS. Consistent with the range of
options identified in this section,
mitigation off-set projects will also be
selected through the Section 106 process
and in an agreement between the
USACE, NY SHPO and the Project
Sponsor.
2.7-2
Evaluation of additional information The Phase IB Report has been provided
is
appropriate.
Attached
are to the Lead Agency and is included in
photographs of resources and features the FEIS at Appendix K. The stone
on Galloo Island that were partially walls and foundations were identified as
catalogued in the Phase 1A inventory part of four locations requiring
(see Photos 1 through 17). Features additional investigation.
The cedar
including stone walls, foundations, stump fences were not identified by
and cedar stump fences related to SHPO
as
requiring
additional
historic agricultural uses of the island investigation. The Project Sponsor has
should be further documented and agreed to avoid three of these locations
evaluated in an impact assessment of and therefore, SHPO has concluded that
cultural resources. The Phase 1B no further assessment of those sites is
report, discussed in the DEIS, should necessary. For the fourth location, the
be provided for additional review and Project Sponsor has proposed a Phase II
comment prior to closing the investigation the methodology of which
comment period on the DEIS. is included in Appendix K.
Source: DPS
2.7-3
Consideration of visual and noise In a letter from SHPO dated June 23,
impacts to the setting of potentially 2009, SHPO concluded that Given the
eligible historic resources, such as the unique circumstances associated with
Coast Guard station buildings and this portion of the project (turbine field
structures is appropriate, and development) we see no reasonable way
potential methods of reducing in which the affects associated with the
adverse effects on resources should construction of these units on Galloo
be explored in additional alternatives Island can be avoided or minimized
3-100

Hounsfield Wind Farm


Final Environmental Impact Statement

evaluation. Increased setbacks of


turbine structures from property lines
of the Coast Guard station from the
approximately 500 feet distance
proposed, and 500 feet from the
lighthouse should be evaluated as a
mitigation measure to reduce impacts
on settings of historic resources.
Source: DPS

2.7-4

2.7-5

2.7-6

The only direct mitigation measure


identified in the DEIS for cultural
resource impacts is to paint wind
turbines in an off-white low
reflectivity finish. This alleged
mitigation
is
essentially
a
requirement for compliance with
FAA aviation hazard mitigation,
since the off-white colors are
required due to their highly visible
contrasts, rather than being lowvisibility as implied by the DEIS
identification as visual mitigation.
Source: DPS
DPS recommends that the State
Historic Preservation Officer staff be
consulted regarding the potential
eligibility of the Coast Guard Station
buildings and setting for listing on
the State or National Register of
Historic Places.
Source: DPS
Galloo Island Lighthouse - The
project sponsor should consider the
restoration and adaptive reuse of this
National Register of Historic Places
landmark. This landmark could serve
as a museum for interpreting the
history of the island.
Source: Jan Maas

3-101

through layout alteration or unit number


reduction.
Therefore, from the
standpoint of minimization of visual
impacts based on turbine layout, there is
no alternative arrangement of turbines,
including increasing setbacks that will
reduce visual impacts to identified
locations on the island. Regarding
potential noise impacts, the locations
identified in the comment will be
owned, and their access controlled, by
the Project Sponsor. There are no
current plans for future use of the
locations identified and therefore, noise
impacts are expected to be limited.
Comment noted. Please response to
comment 2.7-3. In addition, the project
sponsor investigated the feasibility and
visual impact of a gray color. The
results of this investigation are in
Appendix J.

A letter on June 23, 2009 from the State


Historic Preservation Office (SHPO) has
indicated that the Coast Guard Station
buildings are eligible for listing on the
National Register of Historic Places.

Mitigation options for potential impacts


to Cultural Resources are summarized in
Section 2.7 of the EIS. Consistent with
the range of options identified in this
section, mitigation off-set projects will
also be selected through the Section 106
process and in an agreement between
the USACE, NY SHPO and the Project
Sponsor. Restoration of the lighthouse
will be one potential mitigation off-set

Hounsfield Wind Farm


Final Environmental Impact Statement

project considered. However, use of the


lighthouse as a public museum is
complicated by the location of the
lighthouse on the remote island and
public accessibility concerns.
Mitigation options for potential impacts
to Cultural Resources are summarized in
Section 2.7 of the EIS. One potential
option for mitigation will be the creation
of a local mitigation fund with the Town
of Hounsfield in order to provide
funding for cultural projects of
significance to the local community.
Specific off-set projects will also be
identified through the Section 106
process and in an agreement between
the USACE, NY SHPO and the Project
Sponsor.
Due to the remote location and lack of
useable public docking facilities there is
no known active public use of the
former Coast Guard Station. Therefore,
it is not anticipated that the Hounsfield
Wind Farm will impact the use of
cultural resources on the island.

2.7-7

Local Impact Fund - There should be


a program developed to compensate
local communities, which are
negatively
impacted
by
the
development of the project and its
transmission lines. The New York
Power Authority project in Messena
and its funding of local infrastructure
development
in
communities
impacted by the power project serves
as an example of such a program.
Source: Jan Maas

2.7-8

Several public property parcels are


located on Galloo Island with various
historic, cultural recreational, visual
and other resources associated with
them. Additionally, public areas on
the mainland, notably the historic
areas of Sackets Harbor, may have
similar resources. The benefits
derived by the public from these The parcel on the southern tip of Galloo
Island similarly lacks any public or
properties should not be impacted.
Source: DOS
private docking facilities. The lack of
access and distance from the mainland
indicates that there is little to no use of
the island by the public. However, one
current use of a portion of the island is
for wildlife management. Based on the
bat and avian risk assessments, provided
in Appendix P of the DEIS, the use of
the island for the Project will allow for
the continued use of a portion of the
island as a wildlife management area.
Therefore, this public benefit of the
NYS owned portion of the island will
not be impaired.
The only potential impact to
properties on the mainland from the
wind farm is the potential visual impact.
Although the turbines will be visible
3-102

Hounsfield Wind Farm


Final Environmental Impact Statement

2.7-9

The Fort Ontario State Historic Site


("Fort Ontario") is located near the
Port of Oswego. We request further
information
regarding
potential
impacts that may occur to Fort
Ontario during the construction phase
of this project particularly from
noise, traffic and/or visual impacts.
Source: OPRHP

from various locations on the mainland


including from some locations at the
Sackets Harbor Battlefield State Historic
Site, the visual resource assessment
study determined that the Project will be
a background feature. The change in
setting at this site will be offset by
mitigation designed to enhance the
experience of this setting to the visiting
public, including but not limited to
refurbishment of the Pickering-Beach
Museum cottage and historic collection,
and further development of the Sackets
Harbor Battlefield State Historic Site.
The Port of Oswego, as the first U.S.
port of call on the Great Lakes, is one of
the leading, most productive and active
ports in North America and abroad.
Between the existence of deep draft
terminals and access to the New York
State Barge Canal, the Port of Oswego
offers multi-modal connectivity that
includes marine highway, on dock rail,
and immediate efficient connections to
the Interstate system.
According to information from the Port
of Oswego, incoming and outgoing
cargoes span the globe from Brazil and
the Netherlands to Russia and Indonesia.
Last year, more than a million tons of
cargo went through the Port. The Port
of Oswego has been used for the
delivery of wind farm components for
other wind farm projects in New York
State most recently in Steuben County
and also the Maple Ridge Wind Farm.
For this Project, the Project Sponsor is
not proposing the construction of any
new facilities at the Port of Oswego but
will be using existing facilities within
the Port. Therefore, it is not anticipated
that there will be any new impacts to
Fort Ontario. The Port of Oswego will
be used in accordance with its
regulations and standard procedures.

3-103

Hounsfield Wind Farm


Final Environmental Impact Statement

Topic: Socioeconomics
Comments

Comment
#
2.8-1
Few dollars for the wind project will
stay to benefit our local community.
These projects are highly subsidized
by our tax dollars while people from
outside the area are raking in the
profits.
Source: Mike Contino

2.8-2

Responses

As stated in Section 2.8 of the DEIS the


Payment in Lieu of Taxes (PILOT)
payment to the local taxing jurisdictions
is currently estimated to be $8,500 per
MW,
which
would
provide
approximately $2.14 million to the local
taxing jurisdictions annually. During
construction approximately 200 workers
will be employed by the project.
Additionally, the 24 new permanent
employees will earn up to $1,440,000.
I would also like to see some of this Pursuant to State law, the power
power given to the Town for generated by the Project is proposed to
economic development reasons.
be provided to the NYS Power Grid
Source: Shawn Doyle (H)
through arrangements with the NYISO.
The project will produce electricity that
will supply the NYS power grid through
its operating license granted by the
NYSPSC (Section 68 Certificate of
Public Necessity and Convenience).
The electricity generated by the project
will contribute to the States goals of
meeting the Renewable Portfolio
Standard goal of generating 25% of the
States electricity from renewable
sources by 2013.
In addition, the
Project will further State policies for
reducing greenhouse gas emissions from
electricity generation projects and
reducing New Yorks reliance on
foreign energy sources as well as
providing low cost energy for
ratepayers. At this time, the PILOT
agreement being negotiated between the
Project Sponsor and the Jefferson
County Industrial Development Agency
will provide a direct benefit to the local
taxing jurisdictions of approximately $2
million dollars in the first year of
operation, with provisions for annual
increases guaranteed, and potential
additional increases if the cost of
electricity increases.
3-104

Hounsfield Wind Farm


Final Environmental Impact Statement

Topic: Blasting
Comment
Comments
#
2.11-1
Turbine
foundations
will
be
excavated using blasting due to the
prevalence of bedrock on the island.
We believe this method of excavation
may be very disruptive to some forms
of wildlife, such as reptiles and
amphibians, small mammals, and
ground nesting birds. Additional
information should be provided on
the potential impacts to these
animals.
Source: USFWS

2.11-2

Responses
The potential impact from blasting for
foundations on wildlife such as small
mammals, reptiles, amphibians and
ground nesting birds will be minimized
through the use of contained blasting
methodology.
Contained blasting
involves the method of preparing the
blast site and setting charges in a
manner that directs and concentrates the
blast energy in the required direction
and minimizing the dispersal of debris to
surrounding area. It is anticipated that
small mammals will temporarily
relocates and find shelter once intensive
construction activities begin. The safety
horn blast warnings will also scare
animals away from the area of activity.
Seasonal and/or time of day restrictions
on blasting activities will be utilized to
minimize effects on nesting birds.
A revised blasting plan was prepared
and is attached to this FEIS as Appendix
L. The DEC guidance was adhered to
where applicable. The minimization of
noise and vibration are less of a concern
on Galloo Island as it is uninhabited.
However, all appropriate steps will be
taken to minimize vibration and noise.

The project now anticipates creation


of a small quarry for purposes of
providing
road-grade
gravel
materials. This operation will involve
blasting. The DEIS discussion on
blasting does not address blasting in
terms of the protocols to reduce
ground vibration, noise, etc. The
Blasting Plan should be revised to
incorporate DECs Guidelines for
Evaluating Mining Applications that
Propose to Use Blasting Including
Best Management Practices, Division
of Mineral Resources, June 2009.
Source: DEC
Topic: Decommissioning
Comment
Comments
Responses
#
2.12-1
It may be advantageous to ensure that A Decommissioning Plan and Bond will
proper financial security mechanisms be negotiated with the Town of
are in place to assure that the Hounsfield to ensure both adequate
proposed facility would be operated procedures and funding for the removal
in an adequate manner and that of project components if the Project is
3-105

Hounsfield Wind Farm


Final Environmental Impact Statement

sufficient funds and procedures are in


place to provide for decommissioning
of the proposed project.
Source: DOS

2.12-2

permanently
terminated.
The
Decommissioning Plan will be a part of
the Town Planning Boards site plan
review process and will be approved
prior to site plan approval being issued.
The Decommissioning Plan will also be
a part of the submission to the NYDPS
in the application for the Section 68
Certificate.
Comment Noted. The industry standard
has been to remove all WTG and any
below ground structure to 36 inches.
When evaluating the decommissioning
plan the Town should balance the
environmental benefits of restoring the
island to pre-construction conditions
with the potential environmental impacts
of such work.

It is stated in this section that a


Decommissioning Plan has been
prepared and would be put in place in
order to mitigate adverse impacts
from abandonment. For all other
wind farms in the state, this issue has
been handled at the local level,
usually through a local wind siting or
other ordinance. According to a
conversation with the Hounsfield
Town Supervisor, the developer will
prepare a decommissioning plan in
consultation with the Town, and this
issue will be fully addressed within
the Town Planning Boards site plan
review of the project. Nonetheless,
given the unique nature of this
project site, DEC would recommend
to the Town that complete restoration
of the site to pre-existing conditions
be evaluated, and development of the
final decommissioning plan should
be made only after consideration is
made of the activities that would be
necessary to accomplish complete
restoration. Complete restoration
would include, but not be limited to,
removal of all concrete structures,
buildings and maintenance facilities,
all underground interconnect cables
or transmission lines, and all
components
of
the
wind
tower/turbine.
Source: NYSDEC
Topic: FAA Lighting
Comment
Comments
#
3-106

Responses

Hounsfield Wind Farm


Final Environmental Impact Statement

2.13-1

2.13-2

We note that the color of the lighting


was chosen to minimize avian
impacts. To further reduce impacts
to migratory birds, we agree that
turbine lighting be installed only on
the minimum number of turbines as
required by the Federal Aviation
Administration.
Source: OPRHP
The DEIS states that " the
required FAA lighting will create a
visual impact to lake-borne, and
possibly, shoreline viewers that
cannot be mitigated without reducing
its safety objective, However, this
impact has been significantly limited
based on the location of the island."
Since the DEIS states that there will
be a visual impact to viewers, State
Parks requests further information on
the impacts to the night time
horizon.
Source: OPRHP

Comment noted. The plan in the DEIS


follows FAA Circular DOT/FAA/ArTN05/50 and lights only the perimeter
turbines at a separation distance of
approximately one-half mile between
lighted towers.

Three visual simulations were prepared


to evaluate the impact of nighttime
lighting on the night horizon. (See
Appendix J) The FAA lighting plan was
based on the FAA guidance and the
proposed lighting plan is presented in
Appendix J. Based on the simulation, it
can generally be stated that the
mandatory FAA lighting will be visible
at night from the same locations that
will be able to see the wind turbines
during the daylight hours. However, the
lights will be more than five miles away.
Since the State Parks where the turbines
will be visible are closed to the public at
dusk, it is not anticipated that any
diminished viewshed impacts will result
due to nighttime lighting located on the
turbines. The minimum number of
towers required by the FAA will be lit
and all lights will flash simultaneously
to reduce the visual impact.
Topic: Noise
Responses

Comment
Comments
#
2.15-1
Proposed permanent housing for
project employees will be within
close proximity to wind generating
turbines. Analysis of multiple turbine
noise levels and exposure predictions
should identify levels and durations
in accordance with U.S. Dept. of
Labor Occupational Safety and
Health
Administration
(OSHA)
standards and criteria, and identify
mitigation strategies as appropriate.
Source: DPS

3-107

According to the acoustic study,


included as Appendix N; the predicted
maximum sound level at the worker
housing area on Galloo Island is 58.1
dBA and safely in compliance with the
OSHA action level of 85 dBA .
Additionally the maximum predicted
sound
level
is
within
normal
conversational and activity ranges.

Hounsfield Wind Farm


Final Environmental Impact Statement

2.15-2

Predicted noise levels at the two


Galloo Island properties owned by
the State of New York should be
identified,
and
mitigation
as
appropriate to preserve potential use
of properties as recreational resources
should be discussed.
Source: DPS

2.15-3

Two Identical Comments:


The noise of the turbine and its gear
train is considerable, being listed in
the manufacturer's specification as
104 dBA.
Source: Albert H. Bowers III
Source: Herb Bowers (H)

2.15-4

Two Identical Comments:


Secondly there is the aerodynamic
noise of the blades of the turbine and
thirdly, the low frequency impulse
created each time one of the turbine
blades passes the supporting pylon.
Source: Albert H. Bowers III
Source: Herb Bowers (H)

2.15-5

Two Related Comments:


Comment 1: There is a field of
turbines installed in the water off the
Gaspe Peninsula, in the mouth of the
St. Lawrence River. Ship Captains
passing
these
turbines
have
commented to Mr. Metzger that they
are surprised how noisy the turbines
are as they pass them at a distance of
2-3 miles in the shipping channels. If
the wind turbines can be heard over
the typically high noise levels on the
3-108

There is no management plan in place


for the NYSDEC properties on Galloo
Island and no public uses are proposed.
In addition, the NYSDEC lands are not
currently accessible without permission
and access over private lands.
Therefore, there is no potential public
use of the NYSDEC properties at this
time and a separate noise assessment is
not warranted.
Comment noted. The Vestas 3.0 wind
turbine has been tested to have a noise
pressure level of 103 dBA at 5.5 m/s of
wind. The acoustic study modeled the
noise output as 109.4 dBA for a hub
height wind speed of 9 m/s. However,
the acoustic study included as Appendix
N of this FEIS has determined that there
will be no discernable impact to
mainland locations.
The situation the comment refers to is
addressed in the acoustic study in
Appendix N. The acoustic modeling
included the very low frequency 1/3octave bands of 16 Hz and 20 Hz
(infrasound).
The study compared the lowest three
1/3-octave band sound levels predicted
from Project operation to the human
hearing threshold and all three were
below the human hearing threshold and
thus the study concludes that there will
be no perceptible infrasound or very low
frequency sound from the Project.
The
comments
report
anecdotal
information with no reference to written
documentation or studies that could
elaborate on these comments, therefore
they cannot be corroborated or tested for
use in the context of this review. Refer
to Appendix N for modeling results
conducted for the project area based on
the equipment proposed for the project.

Hounsfield Wind Farm


Final Environmental Impact Statement

bridge of a ship, from a distance of 23 miles, the noise levels are


significant.
Source: Albert H. Bowers III

2.15-6

Comment 2: I have recently been


talking to Don Metzger, who is a
pilot on the seaway, and Don
described his conversation with some
of the ship captains that come up the
seaway, that in the Gaspe Peninsula
area, they have some offshore wind
turbines and he recounted that they
were surprised how much noise these
turbines make as they pass them at a
distance of about three miles in the
shipping channel. And my reaction to
that is if they can hear these things
sound noisy on the bridge of a ship
three miles away -- the bridge of a
ship is not a quiet place, I can tell
you, because in addition to all the
machinery noise that comes up
through the ventilating stacks and so
on, there is quite a bit of wind noise.
So if they can hear the noise on the
bridge of a ship three miles away, I
am not sure that we won't hear
significant and annoying noise
components at residences on Point
Peninsula five and a half miles from
the site.
Source: Herb Bowers (H)
It is necessary to do studies of the
noise that will be transmitted by the
turbines on Galloo to the nearby
points on the mainland, including
Point Peninsula (Lyme) and Pillar
Point (Brownsville). Such noise
studies should consider the condition
of a stable atmosphere where the
winds at ground level are still, but the
turbines are operating in the steady
winds at higher elevations. The
sound levels should be predicted for
the shoreline of the Lake on both the
A and C decibel scales. Unless
3-109

The acoustic study (included as


Appendix N) studied the sound effects
from the wind farm on the nearest
shoreline locations including:
South Shore Road Extension - Town of
Lyme,
Beach Road Town of Lyme,
Flanders Road Town of Lyme,
Fox Island Road on Fox Island, and
Pillar Point in Town of Brownville.
The acoustic study, calculated the
broadband sound power for both Aweighting and C-weighting scales as

Hounsfield Wind Farm


Final Environmental Impact Statement

predicted sound levels fall with 5


dBA of the ambient nighttime levels
on the lakeshore, the sound levels
generated by the Galloo project may
be unacceptable for the residents of
those areas.
Source: Albert H. Bowers III

2.15-7

2.15-8

111.4 dBA and 129.8 dBC, respectively.

The modeling results show the


maximum predicted wind farm sound
level at the five closest shoreline
receptors to be 14.3 to 32.5 dBA. These
levels were compared to ambient Leq
levels of 50.7 dBA for a combined
sound level of 50.8 dBA for a net
increase of 0.1 dBA at the closest
receptor, which is well within the 6 dBA
threshold for closer analysis in
residential areas established in DEC
guidance. An increase of 0.1 dBA
combined with the ambient noise would
be inaudible to the human ear.
Two Identical Comments:
Please refer to the Acoustic Study of the
Galloo Island Wind Turbines which is
Whereas the Impact Statement included in Appendix N. The results of
declares the noise generated by this the study are provided in the response to
project poses no significant noise comment above.
impact, the Town of Lyme
respectfully submits this letter
expressing its concern to the
contrary.
Considering
the
magnification of noise traveling over
water, and with a prevailing westerly
wind, the Board is concerned the
proposed 92 wind turbine project
with a threshold of 50 plus DBA, will
create a significant noise impact on
our residents living on Point
Peninsula, only five and one half
miles east of Galloo Island.
Source: Town of Lyme
Source: Warren Johnson (H))
Two Identical Comments:
The results of the acoustic study indicate
that net increase over ambient sound
We, as a Town Board, would like to levels will be 0.1 dBA. According to
respectfully request that you conduct the NYSDEC Program Policy on
a noise study, before and after Assessing and Mitigating Noise Impacts
completion of this project, to (DEP-00-01), increases in sound
determine the noise impact to our pressure levels ranging from 0-3 dB
residents on Point Peninsula. We should have no potential adverse impact.
hope if after study, if a significant The increase predicted for the Project is
impact is found, that you will at the lowest level of this range and
conform to the NYSDEC noise therefore it is not anticipated that the
3-110

Hounsfield Wind Farm


Final Environmental Impact Statement

standard of ambient plus 5 DBA.


Source: Town of Lyme
Source: Warren Johnson (H)

2.-15-9

2.15-10

Project will result in any significant


adverse noise impacts to receptors along
the mainland shoreline. An increase of
0.1 dBA combined with the ambient
noise would be inaudible to the human
ear.
I second Warren's idea to have a See Responses to Comments above.
sound study done to see just what
kind of noise would be transmitted to
Point Peninsula, which is really the
closest part of the mainland for this
project and happens to be part of the
Town of Lyme.
Source: Herb Bowers (H)
The Town of Lyme would like to see See Responses to Comments above.
noise level set at ambient +5 DBA, The modeled 0.1 dBA increase over
which is the New York State DEC ambient is significantly below the
standard and our standard set in our recommended +5dBA. An increase of
Zoning Law for Wind Farms and 0.1 dBA combined with the ambient
Wind Turbines.
noise would be inaudible to the human
Source: Warren Johnson
ear.

Topic: Alternatives
Comment
Comments
#
3.0-1
Consideration
of
alternative
arrangements of facilities to reduce
potential impacts on state wildlife
management land, and the old USCG
station property, and potential public
use of these lands, is appropriate in
an assessment of alternatives.
Source: DPS

3.0-2

Responses
The revised layout for Galloo Island
removes the turbine and related
improvements that were proposed for
the state wildlife management land.

In addition, no direct project impacts are


anticipated to the USCG station
property. Potential impacts due to the
proximity of the turbines located on
Galloo Island are discussed in Section
2.7. Given that, there is no public use of
the wildlife management land or the
USCG station, the remote location and
lack of funds to make improvements to
these parcels, no impact to public use is
anticipated.
Alternative project layouts to avoid An alternate layout for Galloo Island has
siting of project components in un- been developed and evaluated. This
3-111

Hounsfield Wind Farm


Final Environmental Impact Statement

invaded sites should be developed revision did not propose avoidance of


and assessed.
sites with invasive species. The goal of
Source: DPS
the comment is consideration of controls
that will insure that Project construction
or operational activities will not
contribute to the spread of invasive
species (pale swallow-wort) on the
island.
However, this invasive species is
already prevalent throughout the island.
While there do appear to be a few
remaining unaffected areas, given that
seeds from this species are easily
transported via air currents and readily
propagate, there can be no certainty
whether areas that presently appear
unaffected are indeed so or will not soon
be affected given the high mobility of
this invasive species Consequently,
selective siting of Project components is
unlikely to halt the spread of this highly
invasive plant, which, absent direct
intervention, over time is likely to cover
the island whether the Project is
constructed or not.
Consequently the approach that the
Applicant has proposed is to adopt best
management practices such as, washing
trucks and gear to ensure that
construction and operation activities do
not transport pale swallow-wort seeds
from contaminated areas to locations on
the island to do not appear to be
contaminated. In addition in an effort to
stem and reverse the ongoing spread of
this invasive species throughout the
island, The applicant is committed to
maintain (through mechanical and/or
chemical methods) those areas that
presently appear to be unaffected so that
they remain free of pale swallow-wort,
as well as reduce the spread of the
species in other areas (see, Pale
Swallow-wort Control Plan, Appendix
F).
3-112

Hounsfield Wind Farm


Final Environmental Impact Statement

3.0-3

An evaluation should be done of


alternative New York wind farm
locations
suitable
for
such
development without having to
sacrifice such an important Lake
Ontario island resource.
Source: Tomas E. Brown

3.0-4

Various alternatives were reviewed


by the project sponsor to determine
the most profitable project. The
applicant did lower the number of
turbines to reduce wetland loss. In
the Alternatives Summary, the
project sponsor has provided a range
in potential electricity generation
output but did not indicate the The estimation would likely is
minimum amount of electricity that dependent on a variety of factors
must be generated to make the project including power prices, financing costs,
3-113

The alternative analysis evaluated


alternatives that are feasible, considering
the objectives and capabilities of the
Project Sponsor. The objective of the
Project Sponsor as stated in Section 1.1
of the DEIS is to "maximize the energy
production from this unique wind
resource and other unique characteristics
of Galloo Island in order to deliver
clean, renewable, low cost electricity to
the utility grid, and provide economic
benefits to the local economy."
Therefore, an evaluation of other
locations suitable for a wind farm would
not meet the objectives of the project
sponsor. Along these lines, the project
site is unique. This proposed Project is
located in wind conditions similar to
offshore locations but will be located on
land, limiting impacts to submerged
lands. The project is also situated
remotely from local communities,
greatly reducing the impacts to
residents. No other project site in New
York State can replicate these unique
features. Such an analysis would also
not meet the capabilities of the project
sponsor as the project sponsor is a
private entity and does not at this time
own or control other sites suitable for an
industrial wind farm, which is why the
Final Scoping Document specifically
excluded consideration of alternate
Project locations from this SEQRA
analysis. (Final Scoping Document at
35.)
As noted by the comment, the minimum
amount of electricity that must be
generated to make a project viable on
Galloo Island has not been specifically
calculated. According to the project
sponsor, it would be difficult to generate
a reliable number.

Hounsfield Wind Farm


Final Environmental Impact Statement

viable. This information should be


provided in the DEIS. We know of
several projects in New York State
which are of smaller size, presumably
profitable, and approved by the New
York State Independent System
Operator for connection to the grid.
For example, the Fenner Wind
Project (30 MW), Madison Wind
Project (11 MW), and Prattsburgh
Wind Farm (79 MW) were all
approved and are much smaller in
size than this project. The data
supporting the project size has not
been provided.
We suggest the
project
sponsor
provide
that
information.
Source: USFWS

electricity
demand,
government
incentives and permitting costs among
other considerations.
However, relevant to SEQRA we note
that the DEIS evaluated six alternatives
in a resource-based analysis. These
included the no-build and preferred
alternatives and four other alternatives
that were either smaller projects or used
less efficient technology. As detailed in
the DEIS even when the number of
turbines on Galloo Island were reduced
from 84 to 51, this
significant
reductions in size did not result in
appreciable reductions to impacts on
wetlands, visual or noise impacts or
impacts on flora or fauna. However such
reductions would have significant and
disproportionate adverse impacts on the
Projects benefits including: renewable
energy; its contribution to achieving
NYs energy and environmental policy
goals and; its contributions to the health
of the local economy; Therefore these
alternatives did not warrant further
consideration.
Also, in response to comments from the
DPS and others addressing specific
resource concerns, an additional
alternative layout has been proposed
which further minimize the identified
potential impacts while preserving the
Project Benefits outlined above, through
modifications in the siting of 84
turbines.
Accordingly, as required by the SEQRA
regulations the alternatives discussion
has included a description and
evaluation of the range of reasonable
alternatives to the action. (6 NYCRR
617.14[f][5]).
In this regard the
alternatives analysis has appropriately
considered points along the continuum
of alternatives, comparing options and
weighing benefits against impacts.

3-114

Hounsfield Wind Farm


Final Environmental Impact Statement

Also, as required by SEQRA this


analysis took into account the goals and
objectives of the Project Sponsor. Here,
as noted in Section 1.0 of the DEIS, the
Project sponsors objective is to develop
utility scale energy projects for
distribution of low cost energy to the
public in the New York State energy
market using clean, renewable resources
such as wind. For this particular project
the project sponsor intends to maximize
the energy production from this unique
wind resource and other unique
characteristics of Galloo Island in order
to deliver clean, renewable, low cost
electricity to the utility grid, and provide
economic benefits to the local economy.
Topic: Coastal Zone Consistency
Comments
Responses

Comment
#
4.0-1
Policy 5 encourages development
where public services and facilities
essential to such development are
adequate. While the project is not
likely to require provision of
additional public services, other
essential facilities are proposed as
part of the development, including
ship docking, electric, water and
transportation
infrastructure
on
Galloo Island, and interconnection
facilities including the major electric
transmission facilities and supporting
communications
facilities.
Modifications to the transmission
facilities of NYPA must be made to
accommodate the interconnection of
the transmission facilities to the
NYPA system.
Source: DPS
4.0-2
Policy 7 addresses protection of
Significant Coastal Fish and Wildlife
Habitats.
Additional information
regarding potential effects of
transmission facilities related to the

3-115

The comment correctly notes that the


Project is not likely to require provision
of additional public services. The
privately financed services and facilities
discussed in regards to Policy 5 within
Section 4 of the DEIS were limited to
services and facilities that are part of the
wind farm project, defined in Section
1.0 of the DEIS. The interconnection
facilities noted within this comment are
part of the Upstate NY Power
Transmission Line and discussed in
depth in Upstate Powers Article VII
application, submitted to the New York
State Public Service Commission on
1/13/09. Like the components of the
project located on Galloo Island, these
facilities will be privately funded.

The Coastal Zone Assessment was


revised to include the information
provided in the Supplemental Filing to
the PSC and submitted to NYSDOS on
June 16, 2009. The revised Coastal Zone

Hounsfield Wind Farm


Final Environmental Impact Statement

4.0-3

Project was provided by the project


developer in a Supplemental Filing to
the PSC, which addressed Stony
Island and Calf Island Significant
Coastal Habitats, as well as several
streams that are tributary to Lake
Ontario and are designated as
Significant Coastal Habitats. That
information is not included in the
DEIS, but should be provided as an
amendment to the information in
Appendix W, the Environmental
Impact of the Upstate New York
Power Transmission Line Article VII
Application.
Source: DPS
Policy 35 addresses dredging and
filling in coastal waters. The
additional information referenced
above in discussion of Policy 7
includes
information
regarding
potential effects of dredging and
filling for transmission facility
installation.
Source: DPS

Assessment
contains
information
responsive to this comment and is
appended to the Final EIS in Appendix
O.

No dredging or filling associated with


the wind farm or the transmission line
will occur in SCFWHs. As already
described in Section 4.0 of the DEIS,
dredging and filling for the wind farm
will occur in coastal waters during
construction of the docking facility, the
water intake pipe and a wastewater
discharge pipe.
The construction and operation of the
transmission facilities will also require
work in coastal waters as indicated in
Appendix V of the DEIS, the Coastal
Management Program Federal
Consistency Assessment Form. HDD or
open cut will be used to install the
subaquatic cable within the transition
between onshore and subaquatic
cabling. Any excess material will be
removed and deposited upland. The
process for selecting a method to install
cable in transition areas will consider
environmental impacts, subsurface
conditions and cost consideration. Jet
plow technology will be used in
locations where the sediment depth is
greater than 6 feet. Jet plow embedment
places the cable in a trench
simultaneously with the plowing
operation.

3-116

Hounsfield Wind Farm


Final Environmental Impact Statement

4.0-4

The DEIS at Appendix V also


includes a review of consistency with
the Local Waterfront Revitalization
Plan (LWRP) for the Village of
Sackets Harbor. Policy 25, regarding
Scenic Resources of Statewide
Significance, should be considered
since the LWRP states in regard to
Policies 25-A and 25-B: "The scenic
views from the Sackets Harbor
Battlefield State Park are believed to
have potential statewide significance.
Accordingly,
all
government
agencies shall undertake their actions
in a manner which will enhance or, at
a minimum, not degrade or diminish
these vistas" (Sackets Harbor LWRP,
pg. 54).
Source: DPS

The revised Coastal Zone Assessment


appended to the Final EIS as Appendix
O indicates that the overland
transmission line will not require
dredging or filling in streams as poles
will be placed at a minimum of 100 feet
from streams associated with the Coastal
Zone.
The revised Coastal Zone Assessment
states A visual simulation of the wind
farm from Sackets Harbor State Historic
Site (Battlefield) was completed as part
of the Draft Environmental Impact
Statement and is included in Appendix
Q of that document. The visual
simulation indicates that the wind farm
will be visible from the Battlefield;
however, the visibility of the wind farm
is not expected to detract from the
enjoyment of those seeking a truly
historic experience upon visiting the
battlefield. The battlefield already has
modern
intrusions
including
a
subdivision adjacent to the battlefield, a
road and metal guardrail along the
waters edge of the battlefield, and
propane tanks. The mere visibility of the
wind farm at a distance of more than 10
miles will not have a significant
negative impact on the visitor
experience to the battlefield.
In addition potential off-set projects for
visual impacts could include:
Construction of educational kiosks,
signage and programming
discussing the historic significance
of the Battlefield site and
enhancing the visitors experience;
and
Rehabilitation and renovation of
facilities to enhance educational
and instructive opportunities,
including further development of
the 40 waterfront acres of the
original War of 1812 battlefield

3-117

Hounsfield Wind Farm


Final Environmental Impact Statement

4.0-5

The analysis provided by the DEIS


regarding this policy appears to
consider only in-water components of
the Project and related transmission
facilities as within the Coastal Area
and thus applicable to review under
this policy. The entire Project is
located within the designated Coastal
Area. Visibility of the numerous
wind turbines at the recently installed
Wolfe Island wind project in Ontario,
Canada, from the Battlefield bluffs
are possible under clear weather
conditions.
Source: DPS

recently acquired by OPRHP, and


improvements to the PickeringBeach Museum located directly
adjacent to the battlefield site.
As discussed in response to comment
2.6-1 and shown in Appendix J, visits to
the Sackets Harbor Battlefield State
Historic Battlefield did not identify any
visibility of the Wolfe Island wind
project in Canada.
The Coastal Zone Assessment that was
submitted as an appendix to the Draft
EIS and that served as the basis for
Section 4.0 of the DEIS, was revised
prior to its submission to the NY
Department of State. This revision
included the assessment that while the
turbines will be visible from areas along
the coastline, the visibility of the
turbines will not adversely affect the
enjoyment of those visiting the parks to
observe wildlife, hike or obtain peace
and quiet. The turbines, like other
modern elements such as motorboats,
roads
and
structures,
will
be
incorporated into the viewshed. This
assessment was based on the visual
impact analysis provided within
Appendix Q of the Draft EIS that
included visual simulations of the wind
farm from the following:
Sackets Harbor Battlefield State
Historic Site.
Nearby SCFWHs: Stony Island, Calf
Island, Little Galloo Island, Gull
and Bass Island, Stony PointLyme Barrel Shoals, El Dorado
Beach and Black Pond Wetlands.
Nearby State Lands: Robert G.
Wehle State Park, Westcott Beach
State Park, Southwick Beach State
Park, and Black Pond Wildlife
Management Area.

3-118

Hounsfield Wind Farm


Final Environmental Impact Statement

The revised Coastal Zone Assessment is


appended to this FEIS.
4.0-6
In March 2007, the Village of These
documents
have
been
Sackets Harbor issued a draft version incorporated in the Coastal Zone
of a document entitled Local Assessment.
Waterfront Revitalization Program
Heritage Area Management ProgramHarbor
Management
Plan
(LWRP/HAMP/HMP).
Several
components of those plans should be
considered in evaluating Project
consistency with Coastal Area
Policies, and LWRP consistency
specifically. Goals, objectives and
recommendations in these documents
identify additional measures to
develop public access to waterfront
locations, and protect important
vistas from those locations, including
the Battlefield Park Historic Site.
Source: DPS
Topic: Cumulative Impacts
Comment
Comments
Responses
#
6.0-1
Several wind energy projects have This section within the DEIS includes
been constructed in New York and nearby proposed wind developments in
several are planned for future northwestern New York that had
construction.
The Maple Ridge reached the stage of formal review
project is the closest to the project through
the
publication
of
site, yet many others are planned, as Environmental Impact Statements.
mentioned in the text. However,
projects may be proposed in the Currently the Town of Henderson is reTowns of Henderson, Hammond and examining its land use regulations and
Hounsfield. The tables and text in has a moratorium against wind
this section should be revised to development. The proposed Stone
reflect these projects.
Church Wind Farm, in the Town of
Source: USFWS
Hammond, St. Lawrence County is still
conceptual and has not been formally
presented to any government entity for
review and approvals. Within the Town
of Hounsfield, the Hounsfield Wind
Farm is the only currently proposed
wind farm. Additionally, the scope for
the DEIS identified which wind farms
would be evaluated in the cumulative
impact analysis.
3-119

Hounsfield Wind Farm


Final Environmental Impact Statement

6.0-2

Two Related Comments:


Comment 1: We note that the
Executive Summary, on Page ES-10,
indicated that impacts to State-listed
rare, threatened, and endangered
species are possible if the project is
constructed and operated on Galloo
Island. It is important to point out
that the project also includes a 50.6mile transmission line component,
which may impact State and/or
Federally-listed species. That portion
of the project is being evaluated
separately under the Public Service
Law Article VII process. Prior to any
permit decisions or project approvals,
the results of surveys and evaluation
of the transmission line component
should be completed and evaluated in
the Final EIS document.
Source: USFWS

6.1.1-2

Both the Hounsfield Wind Farm and


Upstate NY Power Transmission Line
will require permits from the US Army
Corps of Engineers and will be reviewed
cumulatively at the federal level under
NEPA, which applies to almost all
actions undertaken or approved by a
Federal agency, including funding,
licensing and permitting actions. A Joint
Permit Application to the US Army
Corps of Engineers under Section 10 of
the Rivers and Harbors Act of 1899 and
Section 404 of the Clean Water Act was
initially filed on June 16, 2009, and a
supplement was filed on July 14, 2009.
The Joint Application addresses the
environmental
impacts
of
the
transmission line and wind farm. As part
of the Joint Application process, Upstate
Power will complete an Endangered
Species Act Section 7 consultation
process in conjunction with the USFWS
to understand potential impacts to
federally listed species from the
operation of the both wind farm and
transmission line. It is not necessary to
include these studies in the FEIS since
studies of the wind farm and
transmission line will be evaluated
during the federal permitting process.

Comment 2: Further, the potential


impacts from the approximately 50mile transmission line should be
considered in this analysis. We
recommend that additional data be
gathered for the transmission line and
be included in the DEIS. Currently,
the DEIS does not provide a
complete picture of the potential At the state permitting level the
cumulative wildlife mortality.
construction of the approximately 50.6Source: USFWS
mile transmission line and other related
facilities is subject to the review
jurisdiction of the New York State
Public Service Commission (PSC) under
Public Service Law Article VII. As
such, it is a Type II action under
SEQRA (6 NYCRR 617.5(c) (35)) and
therefore not subject to SEQRA review
(6 NYCRR 617.5(a)). Because the
transmission line is not subject to
SEQRA review, it is not considered part
of the project evaluated in the
Environmental Impact Statement.
As we noted, detailed studies for Section 6.2 of the DEIS assesses the
3-120

Hounsfield Wind Farm


Final Environmental Impact Statement

most of the transmission line portion


of the project have not been
completed and, therefore, no data is
available on the impacts to resources;
however, this section summarized
conclusions on cumulative impacts.
It is also not clear why the text states
there will be no cumulative impacts
from transmission line and turbine
portions of the project because they
do not overlap geographically. To
understand cumulative impacts to
wildlife, information on both the
transmission line and wind turbine
projects needs to be included in this
section.
Source: USFWS

cumulative impacts of the wind farm


and transmission line using studies
completed on the island and Exhibit 4 of
the Article VII document filed with the
NYS Public Service Commission for the
transmission line. Exhibit 4 of the
Article VII application evaluated
publically available data and data
obtained from field studies. Further
studies on the potential environmental
impacts from the transmission line will
be completed as part of the Section 7
consultation process with USFWS in
accordance with the Endangered Species
Act. In the context of this SEQR review
it is not necessary to include these
studies in the FEIS since studies of the
wind farm and transmission line will be
evaluated during the federal permitting
process.
Topic: Cumulative Impacts Visual
Comments
Responses

Comment
#
6.1.2-1
Two Related Comments:

Comment 1: The cumulative VIA


the DEIS does not address the extent
of proposed project developments
along the Seaway Trail Scenic
Byway, either within the Jefferson
County segment of the Trail, or in
total with other existing and proposed
wind energy facilities.
The
Hounsfield Wind Project will include
the related 230 kV electric
transmission facility, which will
affect the Seaway Trail at a crossing
location proposed in the Town of
Henderson, and other areas visible
from the Seaway Trail near
Henderson Harbor. DPS notes that
the Town of Henderson has
reportedly proposed extending the
Seaway Trail designation to include
interconnecting roads to Henderson
Harbor and County Route 178 to the
3-121

The project sponsor prepared a map


showing the cumulative vegetative
viewshed of the major transmission line
located on the mainland and the wind
farm located on Galloo Island (See
Figure 2.18-1).
As shown on Figure 2.18-1, there is a
portion of views from the Lake that have
potential visibility of both the
transmission line and wind farm.
However, it is very unlikely that a
viewer from these in-water locations
would see both the major transmission
line and the WTG simultaneously.
Very little area on the mainland will
have views of both the transmission line
and wind farm.
According to the
cumulative vegetative viewshed (Figure
2.18-1) there is the possibility from
some locations of a simultaneous view
of the transmission line and wind farm.

Hounsfield Wind Farm


Final Environmental Impact Statement

Town of Henderson Public Boat


Launch.
Transmission
facility
visibility information is appropriate
for consideration of cumulative
impacts on the Seaway Trail
specifically, and designated Coastal
Areas generally.
Source: DPS

These areas of cumulative visibility are


generally along Henderson Harbor. Two
of these locations are along the Seaway
Trail at the intersection of Route 3 and
Route 178 and along Route 3 north of
this intersection. However. at these
locations the wind farm would be nearly
10 miles away and partially screened by
Stony Island. It is also of note that
Comment 2: A demonstration of the neither of these locations are the Seaway
cumulative effect of project visibility, Trail Scenic Byway Overlook.
indicating project scale and landscape
distance is appropriate for cumulative
assessment.
Source: DPS
Topic: Transmission Line
Comment
Comments
Responses
#
6.2-1
The DEIS does not clearly identify A new map has been developed and is
the location of the major electric included as Figure 3.0-3 of this FEIS.
transmission facility proposed to be
co-located in close proximity to other
proposed infrastructure, or natural
resources present on Galloo Island.
Source: DPS
6.2-2
The proposed major transmission In response to this comment and others,
facilities will be located within close the Project Sponsor is proposing a new
proximity of several large wind alternative layout for the Project
energy
generating
turbines. components as detailed in Figure 1.1-1.
Alternative arrangements of wind This alternative analyzes moving
energy turbines to avoid locations turbines, and transmission lines to
near transmission facilities within the conform to a 1.5 times the tip height
fall distance should be analyzed. setback
from
the
substation,
Likewise, alternative arrangements of transmission line and fuel storage areas.
overhead
electric
transmission Where a 1.5 tip height setback could not
facilities to avoid wind turbine fall be met the transmission line has been
distances (1.5 times maximum moved underground with a 1.1 tip height
turbine facility height, in accordance setback. Please see section 1.13.3 of this
with PSC policy should be evaluated. FEIS for more information.
Source: DPS
6.2-3
The analysis of impacts does not Comment Noted.
As discussed in
include the additional locations of response to comment 6.2-2, the Project
facilities associated with the major Sponsor has proposed a revised
overhead
electric
transmission alternative layout that relocates and
facilities proposed for Galloo Island. shortens the length of the major
DPS acknowledges that those transmission line on the island thereby
3-122

Hounsfield Wind Farm


Final Environmental Impact Statement

facilities are subject to Public Service


Law Article VII, but asserts that the
environmental impacts related to the
transmission facilities should be
addressed in appropriate detail in the
EIS (and to interested federal
agencies, including the U.S. Army
Corps of Engineers and U.S. Fish and
Wildlife Service) to provide the
cumulative
impact
analysis
envisioned in the project scope. The
maps of electrical system and project
facilities layouts in relation to
habitats, wetlands and other resources
should clearly indicate the location of
the proposed major transmission
facilities within the project area
encompassing Galloo Island.
Source: DPS

6.2-4

The
Nature
Conservancy
is
concerned
about
impacts
on
spawning areas and shoals used by
lake trout, lake herring and whitefish
in the vicinity of Galloo Island and
between Galloo Island and the
mainland. Any underwater cables
need to be located away from these
areas. These areas also should be
protected during the construction
phase. In addition, we express
concern about the exact design of the
transmission cables, and urge that
final design be required before
permits are considered.
Source: Nature Conservancy

3-123

reducing potential cumulative impacts.


Section 1.4 discusses the potential
impacts associated with the new layout
and indicates the location of the
proposed major transmission facilities
within the Project area encompassing
Galloo Island. The Project Sponsor has
discussed the appropriate level of review
required for compliance with NEPA
with the USACE and it was determined
that the DEIS, FEIS and Article VII
documents will provide sufficient
information to fully assess the
cumulative impact of the transmission
line and the wind project.
The
information provided in Section 1.4
also meets the detail as proposed in the
Final Scoping Document for the
Hounsfield Wind Farm. For a figure
showing all on-island components see
Figure 3.0-3 of this FEIS.
Assessment and potential impact to fish
from the construction of the underwater
cable is discussed in Appendix W of the
DEIS. Appendix W is taken from
Exhibit 4 of the Project Sponsors
Application to the DPS pursuant to
Article VII of the Public Service law
and discusses environmental impacts of
the proposed transmission line. The
review of the major transmission line,
including the Galloo Island, underwater
and mainland portions, are subject to the
jurisdiction of the Article VII review
process led by the Department of Public
Services. According to Appendix W,
page 61, Direct impacts to the twelve
existing protected areas and habitats
within eastern Lake Ontario will be
avoided to the extent practicable. In
addition, the impacts are anticipated to
be localized, temporary and short term
resulting from direct or indirect
sediment disturbance.
Several
measures will be implemented to
minimize the impact of the Project on
fish, as discussed in Appendix W, and

Hounsfield Wind Farm


Final Environmental Impact Statement

6.2-5

After the power lines ruin many of


our open agricultural fields, more
wind farms will be built along the
power line corridor exacerbating the
degradation of the area. The local
Towns are ill-equipped to regulate
these large projects and will be taken
advantage of. Many local politicians
own much of the land and will be the
ones to profit and therefore will be
easily swayed to say yes. Some
people will profit from the towers
and others will just have to look at
them every day.
Source: Mike Contino

6.2-6

How safe will the power line be


under the lake? The bottom of the
lake between the Henderson shore
and Galloo Island has many rocky
shoals that must be traversed. It is not
flat. That is why the fishing is so
good.
Source: Mike Contino

6.2-7

There are many places such as the


Tug Hill that have low value property
where wind towers are more
appropriate.
Source: Mike Contino
3-124

the Project Sponsor will consult with


NYSDEC regarding time of year
restrictions for in-water construction
work.
The process for review of the major
transmission line, including the Galloo
Island, underwater and mainland
portions, are subject to the jurisdiction
of the DPS pursuant to Article VII of the
PSL.
The potential environmental
impacts of the transmission line portion
of the Project are discussed and
addressed in Appendix W of the DEIS
and the Article VII application.
However, the design of the major
transmission facilities and potential
environmental impacts are beyond the
scope of the SEQRA review process. In
addition, cumulative impacts associated
with the transmission line are discussed
in Section 6.2 of the DEIS.
Within Lake Ontario, subaquatic cable
installation will be constructed by jet
plow embedment in areas with
appropriate substrate conditions. In
other areas not conducive to this
technique, subaquatic cable installation
will be anchored to the lake floor by
concrete pillows. This will allow for the
restoration of the Lake bottom to near
preconstruction conditions.
The
potential environmental impacts of the
transmission line portion of the Project
are discussed and addressed in
Appendix W of the DEIS and the Article
VII application. However, the design of
the major transmission facilities and
potential environmental impacts are
matters for the Department of Public
Service in the Article VII review and
beyond the scope of the SEQRA review
process.
The process for review of the major
transmission line, including the Galloo
Island, underwater and mainland
portions, are subject to the jurisdiction
of the DPS pursuant to Article VII of the

Hounsfield Wind Farm


Final Environmental Impact Statement

PSL. However, the design of the major


transmission facilities and potential
environmental
impacts,
including
proposed alternatives, are beyond the
scope of the SEQRA review process.
However, alternatives layouts for the
transmission line are provided in Section
3 of the Article VII application.
The process for review of the major
transmission line, including the Galloo
Island, underwater and mainland
portions, are subject to the jurisdiction
of the DPS pursuant to Article VII of the
PSL. However, the design of the major
transmission facilities and potential
environmental
impacts,
including
proposed alternatives, are beyond the
scope of the SEQRA review process.
They are subjects for the DPS Article
VII proceeding.
The process for review of the major
transmission line, including the Galloo
Island, underwater and mainland
portions, are subject to the jurisdiction
of the DPS pursuant to Article VII of the
PSL.
The potential environmental
impacts of the transmission line portion
of the Project are discussed and
addressed in Appendix W of the DEIS
and the Article VII application.
However, the design of the major
transmission facilities and potential
environmental impacts are beyond the
scope of the SEQRA review process.

6.2-8

If they build the Galloo Island wind


farm, more are sure to follow along
the power line corridor.
Source: Mike Contino

6.2-9

I live in Henderson Harbor, NY on


the water but I also own property on
Route #3, 8155 is the address where
my barn is located. If I am correct the
line is directly over my property and
crosses route #3 continuing right
through my neighbors property where
he has an approved sub-division to be
developed.
I, will not give permission to cross
my land, I'm not in favor of this
newly purposed route and will join
my neighbor across from me, the
Henderson Gun Club, who I, also
understand told NY State that they
don't want the transmission line going
across their property.
Surely, there is a better solution to
the routing of this power line, than
the one you have purposed going
over my property, with all of the
undeveloped land in the north
country, why pass through populated
area's?
Source: Raymond Walty
I am also concerned about why we The process for review of the major
could not find a way to transmit the transmission line, including the Galloo
3-125

6.2-10

Hounsfield Wind Farm


Final Environmental Impact Statement

6.2-11

6.2-12

power underground through a cable


in the Lake Ontario area. I know -- I
am an employee of one of the nuclear
plants -- that the power could be
accepted right down there at the high
transmission lines there which go to
the center -- to the grid. There would
be less disruption if this power line
was put underwater. They are already
going eight miles.
Additional 20, 22 miles I don't think
would be very harmful, because the
transmission line is going to harm a
lot more otherwise going across
several of our townships and right
through the heart of my village.
Source: Shawn Doyle (H)
I own approx. 35 acres of land on the
south east corner of the intersection
of NYS route 3 and NYS route 178. I
have not been approached however a
map exists at our public library that
depicts
the
Galloo
Island
transmission line going through the
center of my land with a 200' ft wide
right of way. I vehemently oppose
this route for two major reasons. I
have two approved subdivisions, one
commercially zoned subdivision on
route NYS 3 with a storage facilty in
place and approved for six more
structures, the proposed routing
would limit the growth of my
approved project, therefore having a
negative effect on my ability to make
a living. The other subdivision is
residential, the proposed routing
would take away my ability to
develop one approved lot of which I
have made underground power,
telephone, and cable TV available.
Source: Pete Price
Two Related Comments:

Island, underwater and mainland


portions, are subject to the jurisdiction
of the DPS pursuant to Article VII of the
PSL. The design and potential impacts
of the transmission line, including
proposed alternatives, are not being
reviewed as part of the SEQRA review
process. However, the design of the
major transmission facilities and
potential
environmental
impacts,
including proposed alternatives, are
beyond the scope of the SEQRA review
process.

The process for review of the major


transmission line, including the Galloo
Island, underwater and mainland
portions, are subject to the jurisdiction
of the DPS pursuant to Article VII of the
PSL.
The design of the major
transmission facilities and potential
environmental
impacts,
including
proposed alternatives, are beyond the
scope of the SEQRA review process.
However, alternatives layouts for the
transmission line are provided in Section
3 of the Article VII application.

The process for review of the major


transmission line, including the Galloo
Comment
1:
The
proposed Island, underwater and mainland
transmission line connects to the portions, are subject to the jurisdiction
mainland on Stony Point. This area is of the DPS pursuant to Article VII of the
3-126

Hounsfield Wind Farm


Final Environmental Impact Statement

heavily infested with swallow-wort, a


highly invasive plant. Swallow-wort
needs to be listed in Upstate New
York Power Corporations EIS as a
priority invasive species. The Nature
Conservancy is concerned that the
transmission line could become a
vector for the further spread of
swallow-wort. Upstate New York
Power Corporation will need to make
sufficient investment to monitor and
control swallow-wort and other
invasive plants at Stony Point and
along the entire right-of-way of the
transmission corridor. Any permit
also should include strict regulations
regarding hygiene of construction
vehicles, including boats and barges,
to prevent spreading of invasive plant
materials.
Source: Nature Conservancy

6.2-13

PSL.
The design of the major
transmission facilities and potential
environmental
impacts,
including
proposed alternatives, are beyond the
scope of the SEQRA review process.
The Project Sponsor has proposed a plan
to address invasive species along the
transmission line in Appendix E of the
Article VII application. For the island
portion of the Project, the Project
Sponsor has included a revised Invasive
Species Control Plan which responds to
comments received during the SEQRA
process. The invasive species plan
includes mitigation measures such as
vehicle washing to control the spread of
pale swallow wort from the island. (see
Pale Swallow-wort Control Plan
attached as Appendix F)

Comment 2: There does not appear


to be any mention of the need to
insure that both construction and
maintenance of the transmission line
should not contribute to the spread of
invasive species, in particular,
swallow-wort. For example, the area
where the line begins on land is
infested with swallow-wort and if
construction
and
maintenance
activities take place during late
summer or early fall, when swallowwort was gone to seed, the chances
on inadvertent transmission off site
are very great. Measures should be
incorporated into the Vegetation
Management
Plan
and
the
Environmental Management and
Construction Plan to insure that
invasive seeds and plants are not
inadvertently carried to other sites.
Source: OPRHP
According to Appendix W four State The process for review of the major
Park facilities are listed as visually transmission line, including the Galloo
sensitive resources within the study Island, underwater and mainland
3-127

Hounsfield Wind Farm


Final Environmental Impact Statement

6.2-14

area including;
Robert Wehle State Park
Southwick Beach State Park
Selkirk Shore State Park
Stony Creek Boat Launch Site
It is not possible to tell the locations
where the line-of-sight confirmations
were conducted in Appendix W. We
request information on the specific
location from which the line-of-sight
field confirmations were taken,
preferably GPS coordinates. Once
we receive this information, we may
request additional photo simulations
to assist in determining visual
impacts of transmission facilities.
We
request
additional
photo
simulations, with GPS coordinates,
from the Park, with site locations
determined in consultation with State
Parks staff.
The proposed
transmission line on the properties
adjacent to Wehle will introduce a
significant new visual feature to this
rural and relatively remote landscape.
This line will be potentially visible to
hikers along the northern border of
the Park. Park visitors using either
Schoolhouse Road or Military Road
on their way to the Park will cross
under this line and experience an
adverse visual impact as they
approach the Park. We recommend
that to maintain the undeveloped
character of this peninsula there
should be further assessment on this
transmission line being installed
underground until it is beyond Wehle
State Park.
Source: OPRHP
According to page 16 of the
Hounsfield Wind Farm Draft
Environmental Impact Statement, the
proposed
route
is
located
approximately 1 mile north-northeast
of the Robert G. Wehle State
Park. However, our calculations
3-128

portions, are subject to the jurisdiction


of the DPS pursuant to Article VII of the
PSL.
The design of the major
transmission facilities and potential
environmental
impacts,
including
proposed alternatives, are beyond the
scope of the SEQRA review process.
However, visual impacts of the line are
discussed in Appendix W. The Project
Sponsor will provide GPS coordinates to
the commentator through the Article VII
process.

The commenters quote is not found on


page 16 however, page 6-35 of the
DEIS states:
The Proposed Route is located
approximately 1 mile north-northeast of
the Robert G. Wehle State Park and the
Henderson Shores Unique Area, which

Hounsfield Wind Farm


Final Environmental Impact Statement

indicate that the transmission line


will be within approximately 1000
feet of two different sections of the
eastern boundary of Wehle State
Park.
Source: OPRHP

is a reforestation area and not a unique


geologic feature.
The Upstate New York Power
Corporations
proposed
major
transmission line is subject to the review
jurisdiction of the New York State
Public Service Commission (PSC) under
Public Service Law Article VII. As
such, it is a Type II action under
SEQRA (6 NYCRR 617.5(c) (35)) and
therefore not subject to SEQRA review
and is not included within the Project
subject to this DEIS. However, a
description of the mainland transmission
line is presented in Section 6.0
Cumulative Impacts of the DEIS.

The distances between the upland


portion of the transmission line and the
eastern boundary of the Robert G.
Wehle State Park (the Park) have been
calculated and are shown on Figure 3.04 which depicts the below ground and
overhead portions of the transmission
line. The distance between the overhead
transmission line and the eastern
boundary of the Park varies along the
proposed route. The closest distance
between the overhead transmission line
and the eastern boundary of the Park is
213 feet where the transmission line
crosses Military Road.
The
transmission line runs underground
approximately 0.15 miles from the
shoreline to a transition station where it
begins the overhead portion of the route.
The transition station is 693 feet from
the eastern boundary of the Park.
Topic: Other
Responses

Comment
Comments
#
9.0-1
Stop and look at what you are doing
before approving this project. Look at
the former Miller Brewing site and
ethanol. Already in Chapter 11. If
wind was a cost efficiency [sic]

3-129

The Project Sponsor, Upstate Power, is


a corporation formed under New Yorks
Transportation Corporations Law and is
not a governmental entity. Upstate
Powers mission is to develop utility

Hounsfield Wind Farm


Final Environmental Impact Statement

project, some entrepreneur would


have already invested in it, because it
made economic sense and money was
made. I have not seen many project
where the government made the
correct choices. Do NOT ruin a
beautiful island in the eastern basin
of Lake Ontario.
Source: Doug McClellan

scale energy projects for distribution of


low cost energy to the public in the New
York State energy market using clean,
renewable resources such as wind. This
particular Project intends to maximize
the energy production from this unique
wind resource and other unique
characteristics of Galloo Island in order
to deliver clean, renewable, low cost
electricity to the utility grid and provide
economic benefits to the local economy.
Upstate Power has the professional
expertise and financial support to
successfully plan, license and develop
the Project. Upstate Power has invested
a significant amount of capital assessing
the wind resource at this location and
assembling a team of consultants in
various technical fields necessary to
complete the design and permitting
tasks. Further discussion of the wind
resource at this location and the Project
Sponsors goals, capabilities and
experience is provided in Section 1.0 of
the DEIS.
Comment Noted. With regard to the
characterization of the island as
pristine, it should be noted that Galloo
Island has been inhabited and used by
humans for various recreational and
commercial activities for over 150 years.
During this time the landscape of the
island has been altered by lumber
harvesting, sheep farming and the
introduction of non-native species
including pale swallow-wort and white
tail deer. Therefore, the use of the term
pristine should not be intended to
mean unchanged.
Comment Noted.

9.0-2

The Eastern Lake Ontario Salmon


and Trout Association wishes to
convey to you in the strongest
position possible that we are opposed
to any such development on this
pristine island.
Source: Eastern Lake Ontario Salmon
and Trout Association

9.0-3

New York State is one of the few


states with the opportunity to protect
the Great Lakes.
Source: Eastern Lake Ontario Salmon
and Trout Association
Our Governor and representatives are Comment Noted.
plunging headlong into development
of energy producing alternatives that
3-130

9.0-4

Hounsfield Wind Farm


Final Environmental Impact Statement

9.0-5

9.0-6

9.0-7

are based upon nothing more than


thoughtless green generated knee jerk
reactions.
The proposed Galloo
Island wind farm is a glaring
example.
Source: Eastern Lake Ontario Salmon
and Trout Association
To date existing wind farms have
proven to be inefficient unreliable, a
tremendous burden on the tax paying
community through Pilot's and other
subsidies and their ugly appearance
totally destroys the landscape on
which they sit as will be the case on
our beautiful Galloo Island.
Source: Eastern Lake Ontario Salmon
and Trout Association

Comment noted. The efficiency and


reliability of the wind farm will be
reviewed by the Department of Public
Service prior to the wind farm being
granted operational approvals.
The
proposed PILOT payments to the
county, Town and School district are for
approximately $2.14 million.
The
remote location of the project will limit
the use of local services and therefore
not likely impact the community.
Finally, the view and appearance of the
wind farm is subjective. While some
may find wind turbines unattractive,
others may find them appealing. The
visual impact of the project was
evaluated in the DEIS and further in the
FEIS in Appendix J.
I am thrilled to think the wind farm is Comment Noted.
being built on Galloo Island. Not
only will it begin the long overdue
change to non-polluting power, but it
will also help with the taxes in our
township where we own property.
There are no negatives that we can
see. The fishing will still be good
(thanks to the cormorant control
program), and the boating will not be
affected.
Source: Gerald Allen
Under SEQRA, an EIS must contain a
Two Related Comments:
discussion of reasonable alternatives.
Comment 1: The land is too unique Alternatives are discussed in Section 3.0
to cover it with windmills, there is of the DEIS. The alternatives analysis
plenty of open land in the area which evaluates alternatives that are feasible,
would be better choice for 84 wind considering
the
objectives
and
turbines.
capabilities of the Project Sponsor. (See
Source: Janice McClellan
6 NYCRR 617.9[b]5[v]). In this case,
as noted in Section 1.0 of the DEIS, the
Comment 2: NY State could find a Project Sponsors objective is to develop
3-131

Hounsfield Wind Farm


Final Environmental Impact Statement

better place other than beautiful


Galloo Island, to build a wind power
project.
Source: Raymond Walty

9.0-8

9.0-9

9.0-10
9.0-11

9.0-12

9.0-13

9.0-14

utility scale energy projects for


distribution of low cost energy to the
public in the New York State energy
market
using
clean,
renewable
resources, such as wind.
For this
particular project, the project sponsor
intends to maximize the energy
production from this unique wind
resource and other unique characteristics
of Galloo Island in order to meet the
Projects goals.
The alternatives
analysis required by SEQRA is limited
to property under the control of the
Project Sponsor.
I believe putting that many turbines Comment Noted.
on such a beautiful shoreline is
equivalent to putting oil rigs off the
beaches of Florida.
Source: Janice McClellan
It would be desirable for the Comment Noted. The Department of
Department of State to be included State has been listed on the SEQRA
on the distribution list for all future service list.
monitoring reports regarding this
proposed project.
Source: DOS
No to wind farm, it is not needed.
Comment Noted.
Source: Mickey G. Gorman
Galloo Island, the Thousand Island Comment Noted. This environmental
area and the eastern shore of Lake review process is only related to the
Ontario is not an appropriate area for construction of 84 wind turbines on
hundreds of wind farms.
Galloo Island.
Source: Mike Contino
We ask you to recommend that this Comment noted.
site not be approved for wind power
projects.
Source: Onondaga Audubon Society
I do not support a wind farm on Comment Noted
Galloo.
Source: Raymond Walty
My concern is once again here we are Comment Noted. The power that is
exporting power from our region. being generated on Galloo Island will be
Why is it that everything that we transmitted to Mexico, NY were it will
produce here power-wise is exported enter the New York State electrical
for the benefit generally of southern transmission grid and sold on the
New York State?
energy market per New York State
Source: Shawn Doyle (H)
Public Service Commission regulations
and the New York State Independent
3-132

Hounsfield Wind Farm


Final Environmental Impact Statement

9.0-15

I feel the overriding omission in this


DEIS, is its failure to adequately
assess the scarce natural resources,
visual and open space impacts of the
proposed wind farm development.
Source: Thomas E. Brown

9.0-16

The DEIS needs to evaluate the


environmental impact of converting
this scarce and undeveloped island to
an industrial site.
Source: Thomas E. Brown

9.0-17

Not only does the DEIS inadequately


address the local environmental
impact, it fails to assess the impact
from a lake wide, state wide and
multi-state perspective.
Source: Thomas E. Brown

9.0-18

System Operator tariffs. Based on this


system, Based on this system, the
project sponsor cannot predict where the
energy will be distributed to and
ultimately used.
The DEIS and FEIS adequately assessed
the natural, visual and open space
impacts of the project. Detailed studies
were completed for avian species, bats,
turtles, historic and cultural resources,
and visual impacts. These impacts have
been identified and where possible
quantified.
In their statement of
findings the lead agency and the various
involved agencies will determine if the
impacts that will occur are adequately
minimized to the extent practicible, offset and balanced by the benefits of the
project.
The DEIS thoroughly evaluated both the
current conditions on the Island as well
as the potential impacts from the
construction of a wind farm and support
facilities. As detailed in the Land Use
Section of the DEIS, Section 2.2, the
construction of the wind farm will only
impact approximately 160 acres of the
nearly 2,000 acre island.
The DEIS thoroughly evaluated both the
current conditions on the Island as well
as the potential impacts from the
construction of a wind farm and support
facilities. In addition, cumulative
impacts were assessed in Section 6.0 of
the DEIS.
Comment Noted

I'm writing to express that we are


most emphatically in favor of the
Galloo Island wind turbine project.
Source:
Town
of
Hounsfield
Planning Board
Topic: Environmental Impact of the Upstate Power Transmission Line Article VII
Application Exhibit 4
Comment
Comments
Responses
#
AVII-1
It is stated in this section that Exhibit E-3 is attached to this FEIS as
construction of the subaquatic cable Appendix P.
will be conducted by jet plow
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Hounsfield Wind Farm


Final Environmental Impact Statement

embedment in the bottom of Lake


Ontario and details regarding the
installation of the subaquatic cable
and associated transitions are
provided within Exhibit E-3. This
exhibit should be included as an
attachment to Exhibit 4. Additionally,
during a recent conference call with
the project sponsor, it was stated that
due to concerns for thermal
dispersion, the project will involve
placement of four smaller subaquatic
cables rather than one larger cable.
Placement of four cables would result
in 4X the disturbance of sediment
than a single cable route. This needs
to be addressed further and associated
impacts of multiple cable routes
analyzed in greater detail.
Source: DEC

The Project Sponsor has indicated that


the use of four cables is still under
review and has not been determined.
A configuration for the subaquatic cable
has not been finalized and will be
determined during the detail design and
EM&CP phase of the Article VII
process. The environmental impacts of
installing a configuration where four
separate conductors are installed depend
on the type of installation.
It is
technically feasible to install four;
separate conductors in one embedment
operation in which case the impacts
would be the same as described for the
single bundled cable. If the cables were
to be installed in four separate jet plow
embedment passes, it is anticipated that
the impacts to resources of concern are
similar to a single pass embedment.
Since the impacts to resources of
concern are anticipated to be minor if
there are negligible environmental
impacts from a single cable then, even
though there would be three additional
cable jet plow embedment passes, each
would have the same impact as the
proposed single cable and therefore
negligible additional impacts would be
expected from the multiple cable
scenario.
Exhibit 4 of the Article VII, Sections
4.9, 4.10.1.2, 4.10.1.3, 4.10. 1.4 and
4.10.1.5 describe the anticipated minor
impacts from the cable jet plow
embedment. This report was attached as
Appendix W to the DEIS.
However, the review of the transmission
line, including the Galloo Island,
underwater and mainland portions, are
subject to the jurisdiction of the Article
VII review process led by the
Department of Public Services. The
design and impact of the transmission

3-134

Hounsfield Wind Farm


Final Environmental Impact Statement

line is not under review in the EIS


process.
Topic: Bat Report
Comments
Responses

Comment
#
BR 1
Appendix O, at Table 7, page 40 of Comment noted. DPS is correct the
70, reports an average of 170.3 total average should be 138 days. This
days of monitoring for the North correction does not change any of the
Tower. The reported average is in findings or data in the Bat Risk
error, as it is higher than any of the Assessment
and
Pre-Construction
monitoring periods for the three Monitoring Report.
tower heights monitored. The average
of the three periods reported should
be calculated as 138.0 days.
Source: DPS
BR 2
Observation (I) reported in Section Comment noted. The statement on page
8.9 may not necessarily be supported 52 is a typo. Bat activity was correctly
by the data summarized in graphic displayed in Figure 24 and correctly
form. The statement at page 52 is summarized in Section 9.0. No further
"Most of the bat activity near the analysis or review of the data is
rotor sweep zone occurred early in required.
the evening and declined rapidly by
00:00." Review of Figure 24 at page
51 indicates that the peak activity
observed
was
at
20:30
(approximately 200 recordings); and
that a decline to half of that level
occurs, and then a reasonably
sustained level of activity is
maintained through about 4:15. The
number of recordings should be
analyzed over the reporting period to
characterize activity levels. DPS
notes that the conclusion in Section
9.0 notes this observation: "bat
activity...remained relatively stable
until the early morning" (App. O, pg.
53).
Source: DPS
Topic: Visual Resource Assessment
Comment
Comments
Responses
#
VIA - 1
The VIA in the DEIS presents a Comment noted. The weather setting
range of viewpoints of project setting used in the assessment of visual impacts
and
project
appearance.
The is the worst-case or most visible
depiction and discussion of setting weather setting, i.e. the conditions when
3-135

Hounsfield Wind Farm


Final Environmental Impact Statement

VIA - 2

and atmospheric conditions does not


address the full range of atmospheric
conditions inherent in the project
setting, such as the dramatic effects
of weather fronts and massive scale
of cloud formations that form over
Lake Ontario, and which contribute
significantly to the scenic setting of
many of the waterfront resources of
interest to the state.
Source: DPS
The discussion of visual impact
mitigation at Appendix Q, Part 5.0,
includes an incomplete discussion of
"Down-sizing" as a mitigation
strategy. While turbine height
reductions are discussed briefly,
down-sizing typically refers to a
smaller-scale project, such as with
fewer turbines in the project array.
Source: DPS

the turbines would be the clearest, a


bright day without haze. It is not
feasible to simulate the full range of
weather conditions and therefore a worst
case analysis is appropriate.

A thorough discussion of potential


down-sizing of the project is in the
Alternatives Section of the EIS. The
alternatives provided in that section
address both the potential for a smallerscale project as well as lower turbine
heights.
The alternatives section
concludes that a smaller-scale project
and lower turbine heights will not
significantly minimize the visual effect
of the project and does not justify the
resulting lower output and loss of
benefits of the project.
VIA - 3
The
discussion
of
Alternate The Alternatives section of the DEIS
technologies includes a discussion of analyzed the use of a 1.5 MW turbine.
750 kW wind turbines and related This discussion analyzed both the land
emissions reductions. This is curious, and visual impact of the use of a 1.5
given the proposed project is based MW turbine. The discussion of 750 kW
on using 3.0 MW turbines, rated at turbine in the VIA was analyzing the
four times the generating output of full range of commercial technology
the 750 kW turbines reported.
available but could be utilized for a
Source: DPS
commercial wind farm. Comparing a
750 kW to 3 MW machine offers the
full spectrum of possible machine sizes.
Note that changing turbine sizes from a
1.5 to 3.0 turbine would be generally
indiscernible from distant views.
Topic: Ecological Resources Report
Comment
Comments
Responses
#
ERR-1
Discussion
of
Significant The calcareous pavement barrens are
Communities in Appendix N, Section located in the Town of Henderson and
3.4.1.3, identifies two significant will not be impacted by the transmission
natural communities identified in the line.
ecological assessment of the project
3-136

Hounsfield Wind Farm


Final Environmental Impact Statement

site. There is a brief discussion of one


of these habitats the calcareous
shoreline outcrop community. There
is no discussion of the other
identified significant community
the calcareous pavement barrens.
Both habitats are noted as being
located "in close proximity to the
proposed underwater transmission
line" (Appendix N, page 24). These
communities are ranked as S2 rare
or vulnerable to extirpation from
New York State. The Ecological
Resources Report does not include
any identification of project impacts,
consideration of impact minimization
or avoidance, or mitigation measures
appropriate for consideration in
project or facility siting. Additional
information regarding the potential
for adverse effects of the proposed
project and transmission facilities on
these significant natural communities
should be developed and provided to
reviewing agencies for consideration
prior to development of an FEIS.
Source: DPS

ERR-2

The Breeding Bird atlas data for at


least 2000-2005 surveys for Galloo
Island, as referenced on pages 1-2 of
this report, is limited as only two
small parcels were covered. There
was not good coverage on the island
as a whole. This limitation should be
noted in the report and subsequent
survey reports.
Source: DEC

3-137

Nearly the entire perimeter of Galloo


Island may be considered Calcareous
Shoreline however the area has not been
officially designated.
(Figure 3.0-5
indicating Rocky shorelines or cliffs)
The shoreline will only be impacted in
one location by construction of the wind
farm, at the site of the slip.
The slip was located to minimize impact
to submerged shoreline, aquatic habitat,
and calcareous shoreline habitat. The
location was chosen that minimizes
submerged land impacts (blasting) due
to steep slopes; minimize impact to
horizontal extent of calcareous shoreline
by avoiding the cliff area; and also need
engineer requirements of construction of
a slip of sufficient draft depth and
vertical offloading height.
In all, approximately 700 feet of
approximately 50,000 total feet of
potential Calcareous Shoreline will be
affected on the island. Of this only
approximately 225 feet will be directly
impacted by excavation. The remaining
portion of potentially impacted shoreline
(475 feet) is calculated based upon the
proximity of upland activities, such as
the permanent laydown area for the slip,
and will not result in direct impacts to
shoreline.
The limits of the 2000-2005 Breeding
Bird Atlas information are noted.
Information similar to the survey data
provided in the Bird Atlas can be found
in Breeding Bird, Diurnal Movement,
Acoustic Monitoring and Ecological
Resources Reports. The inclusion of the
data from the Bird Atlas was intended to
further document the presence of
wildlife on Galloo Island from all
relevant sources. However, this data
was only intended to supplement a
number of Galloo Island field studies

Hounsfield Wind Farm


Final Environmental Impact Statement

ERR-3

that were conducted by the Project


Sponsor and included in the EIS.
(Appendix T of DEIS and Appendix H
of FEIS).
The report states that a turtle trapping In response to comments from the
survey was conducted on July 21-24, NYSDEC, a nesting survey and
2008 (page 4). Four (4) days of turtle additional
turtle
trapping
were
trapping is not adequate to determine undertaken in June 2009 on Galloo
the presence or absence of these Island that focused on determining the
species. DEC has advised the project presence of the Blandings Turtle. 300
sponsor, in a memo to the project trap nights and 21 nights of nesting
attorney dated 06/08/09, to include a surveys were conducted. No Blandings
2009 trapping study work plan that Turtles were caught in the traps, and no
will provide additional data sufficient Blandings turtle nests were identified
to determine which species of turtles on Galloo Island.
This work was
inhabit the study area.
undertaken at the request of the DEC
Source: DEC
and accordance with the scope of work
provided by Region 6 biologists. The
scope of work and the report are
attached as Appendix G to this FEIS.
Topic: Invasive Species Control Plan

Comment
Comments
#
IS-1
Two Related Comments:
Comment 1: The Invasive Species
Control Plan included as Appendix M
to the EIS only addresses three
species generally limited to wetlands
and waterways. The prevalence of
other highly invasive species on
Galloo Island as discussed in
Appendix N at pages 7-8, should be
further noted, and indications of the
extent and prevalence of those
species should be mapped and
analyzed.
Swallowwort
and
Canada thistle stands are ubiquitous
in portions of the island. Invasive
species appear to be less dominant in
other habitats, and those areas should
be noted.
Source: DPS
Comment 2: Additionally, a survey
should be conducted to quantify the
3-138

Responses
As discussed in the Pale Swallow-Wort
Control Plan (Appendix F), mapping the
extent of this invasive species will be
done while the plant is flowering, prior
to construction beginning on the island.
Because the seeds are transported by
wind the areal extent of coverage could
change
annually.
Therefore,
undertaking the survey as close as
possible to the commencement of
construction will ensure that control
measures are focused on the most recent
survey data.
The only other significant invasive
species on the island is Canada Thistle.
No control methods have been
proposed. The areas of thistle infestation
are much smaller than the pale swallowwort and not a significant concern.

Hounsfield Wind Farm


Final Environmental Impact Statement

IS-2

current areal extent of this species


(pale swallow-wort) on the property
under control by the project sponsor.
Source: DEC
Pale swallow-wort is already prevalent
Two Related Comments:
throughout the island. While there do
Comment 1: Efforts to avoid appear to be a few remaining unaffected
additional spread of invasive plant areas, given that seeds from this species
species should be a goal of project are easily transported via air currents
development,
and
mitigation and readily propagate, there can be no
measures appropriate to effectuate certainty whether areas that presently
that goal should be developed. For appear unaffected are indeed so or will
instance, the meadow and wet not soon be affected given the high
meadow sites at the southwestern end mobility of this invasive species.
of the island do not appear to be Certain areas of the island area more
significantly affected by the invasive conducive to pale swallow-wort, in
plant species. (Attached Photo 1 particular shallow soils over limestone.
depicts the view north at meadow and Other areas, such as the agricultural
wetland site toward turbine site 5.) field are less conducive to pale swallowIdentification of strategies to avoid wort propagation.
importing invasive plants into sites
such as that grassland meadow are The approach that the Applicant has
recommended.
proposed is to adopt best management
Source: DPS
practices such as, washing trucks and
gear to ensure that construction and
Comment 2: On page 2-60 of this operation activities do not transport pale
subsection, it cites: It is important to swallow-wort seeds from contaminated
note that Galloo Island does not areas to locations on the island to do not
represent a pristine type of habitat or appear to be contaminated. In addition
support highly diverse wildlife in an effort to stem and reverse the
populations since this island has ongoing spread of this invasive species
historically been disturbed by throughout the island, The applicant is
agricultural
activities,
deer committed to maintain (through
management practices, clear cutting mechanical and/or chemical methods)
of cedar forests and pervasive those areas that presently appear to be
invasions by pale swallow-wort unaffected so that they remain free of
(Cynanchum rossicum), an invasive pale swallow-wort, as well as reduce the
plant species. This invasive species is spread of the species in other areas (see,
found throughout the island and Pale Swallow-wort Control Plan,
wherever it is found it dominates and Appendix F).
out-competes all other ground cover
plants important to wildlife species.
The Invasive Species Control Plan
included as Appendix M in the DEIS
fails to mention pale swallow-wort
and the measures needed to manage
this invasive species. Measures
3-139

Hounsfield Wind Farm


Final Environmental Impact Statement

proposed to remove and control the


spread of this invasive plant within
the project development area should
be described and included in this
plan.
Source: DEC
IS-3
We note that the DEIS states that the Because the invasive species control
applicant's plans call for participation plan was focused on wetland sites, a
in non-toxic programs to curtail this separate Pale Swallow-wort Control
invasive plant as well as other Plan has been prepared for upland areas
introduced species. Swallow-wort and is included in this FEIS as
should be listed in the Invasive Appendix F.
Species Control Plan in the DEIS.
Control of this plant and the spread of
its seeds from the island to other
areas should be a priority both during
and after construction.
Source: OPRHP
Topic: Appendix B: Conceptual Design Report for Selected Infrastructure Improvements on
Galloo Island, Water Intake Structure and Pipeline
Comment
Comments
#
CDR-1
In this report, it is stated that the
water intake structure and pipeline
would be constructed to draw Lake
Ontario water from an offshore
location at a recommended depth of
30 feet below the mean lake water
level.
The
offshore
distance
necessary to achieve this depth is
approximately 400 to 500 feet. The
water intake would consist of a 12inch diameter pipeline extending out
into the lake. A single intake pipe
would be used for potable water and
for fire protection (pages 22-23).
DEC will require, as part of permit
review for this project, that a plan to
sample lake sediments at the intake
location be prepared and submitted to
DEC, consistent with the sampling
requirements of TOGS 5.1.9, unless
it is determined that no sediment
exists at the potable water intake
location.
Source: DEC
3-140

Responses
As stated in the DEIS on page 2-34 and
as shown in Figure 3 of the Bathymetry
Report attached as Appendix K to the
DEIS, the location of the proposed
intake pipe is within an area of exposed
bedrock or bedrock near the lakebed.
Therefore, there is very little to no
sediment in the proposed disturbed areas
for this portion of the Project. Based on
the results of the Bathymetry Report, no
additional sediment sampling is
proposed.

Hounsfield Wind Farm


Final Environmental Impact Statement

CDR-2

The design report additionally states


that a screen would be installed on
the end of the pipeline intake to
prevent seaweed or fish from being
drawn into the pipe. The screen
would be constructed of a metal alloy
that is designed to resist biofouling
by zebra mussels or other nuisance
plants or animals. Eastern Lake
Ontario is a prime spawning area for
lake trout, walleye and alewife, and
the proposed water intake location is
important in particular due to the
offshore shoal created by the island.
DEC will require a water intake
screening system with no greater than
openings and intake velocity of
foot/sec or less, to prevent
impingement of juvenile fish into the
system. A screen of this size is likely
to require periodic cleaning to
maintain water flow.
Source: DEC

The water intake system is designed to


provide an adequate supply of fresh lake
water to both the potable water system
and fire protection system for use at the
housing and operations & maintenance
complex.

The
intake
pipe
will
extend
approximately 575 feet underwater from
shore. At the inlet location the pipe will
be buried and terminated with a six foot
diameter precast concrete pipe section
set vertically with the top approximately
1 foot above the existing lake bed at a
water depth of approximately 30 feet.
An intake screen cap will be attached to
the top of the precast section to prevent
debris, fish, and other organisms from
entering the intake. The cap will consist
of a non-metal bar rack frame which
will support a finer alloy screen with 2
millimeter maximum openings.
A
chemical feed line will be routed inside
the intake pipe and terminated within
the intake structure. This would allow
for periodic removal of biological
growth should it become a problem. To
ensure that small fish are not impinged
on the intake screens, the overall area of
the screen will be sized such that flow
velocities through the screen do not
exceed 0.5 feet per second.
Topic; SPCC
Responses

Comment
Comments
#
SPCC-1
Overall, the report appears written
specifically to address federal
requirements of the Oil Pollution Act
and Clean Water Act. The report
should address NYS Navigation and
Environmental Conservation Laws as
well.
Source: DEC
SPCC-2
A broad question to answer is the
States definition of Facility.
Generally under NYS Petroleum

3-141

The SPCC Plan has been revised to


incorporate
provisions
of
NYS
Navigation
and
Environmental
Conservation Laws. This is included in
Appendix B.

For purposes of this SPCC Plan, the


Facility constitutes the entire limits of
Galloo Island as well as the slip area. In

Hounsfield Wind Farm


Final Environmental Impact Statement

SPCC-3

Bulk Storage (PBS) regulations


(promulgated pursuant to Article 17
Environmental Conservation Law
Title 10), Facility means the entire
site where >1,100 gallons of
petroleum is stored in bulk. This
definition has ramifications in terms
of spill reporting and cleanup.
Whereas typically wind farms are
located primarily on leased private
land, the Hounsfield Wind Farm is
proposed to be located on land
wholly owned by the project sponsor.
Therefore,
the
entire
project
development area would constitute a
Facility for purposes of this
regulation.
The main difference
between this situation and a typical
wind power project is that anyone
with knowledge of spill event is
obligated to notify DEC according to
established reporting procedures (see
Sec. 2.7, below).
This includes
contractors or other personnel who
may not be directly employed by or
represent the project sponsor.
Source: DEC
Page 1-2 states that, Even though
the facilitys total oil capacity will be
greater than 42,000 gallons and it will
receive oil over water, the checklist
in Appendix A determined that the
facility will not require a Facility
Specific Response Plan (40 CFR 112
Appendix F) because the ASTs are
greater than 1.8 miles inland from the
slip, and the amount of oil transferred
over water is less than 5,000 gallons
per week. DEC has contacted the
U.S. Coast Guard to get a clearer
understanding of this regulatory
requirement, and will provide
additional guidance following this
consultation. However, somewhere
between a few 90-gallon spill kits
and a full-blown FRP, the facility
needs to maintain appropriate
3-142

Section 2.1, Page 2-1 of the revised


SPCC Plan, Facility has been
redefined to include all of Galloo Island
and slip area.

The SPCC Plan has been revised to


identify the location and equipment that
will be included in spill response kits.
For example, the following spill
response equipment will be located
adjacent to the slip to address any
potential petroleum spills:
A CONEX box will be located
approximately 30 feet from the
shoreline directly northeast of the
permanent slip, and will contain the
following spill response equipment:
SPCC Plan.
500-Foot harbor boom.
100 Petroleum absorbent pads.
500 Foot Petroleum absorbent boom.
4 Mushroom anchors.
4 Boom buoys.
4 55-gallon 1A2 steel drums.
3 12-Foot duck boat with outboard

Hounsfield Wind Farm


Final Environmental Impact Statement

resources for response to significant


spills. Spills may occur due to
accidents with fuel delivery vehicles,
even when the actual transfer of fuel
is not in progress.
Source: DEC

SPCC-4

SPCC-5

Page 2-1 Sec. 2.1 Definitions This


section should cite Article 12
Navigation Law and should include
its legal definitions of petroleum
and discharge.
Source: DEC
Page 2-2 Listing of stored
petroleum This section lists (5)
6,000 gallon above ground tanks. All
tank storage of petroleum will be
regulated by PBS Regulations at 6
NYCRR Parts 612-614, and must be
registered with the Department.
Tanks must meet SPOTS (Spill
Prevention
Operations
and
Technology Series) Memo #14 for
secondary containment requirements
due to the proximity to surface
waters. The Department accepts four
specific double-wall above ground
tank models as complying with this
requirement.
These models are
specifically designed to provide
overfill protection. Most double-wall
tanks do not meet this standard.
Although the plan does not specify
the tank model, the description of the
tank systems appears to be of a type
that does not comply with DEC
requirements.
This should be
3-143

motor and personal floatation devices.


4 Pitch forks.
100 Contractor trash bags.
100 Pair of disposable coveralls or
Tyvek suits.
100 Pair of disposable gloves.
Figures 7, 8 and 9 were added to the
SPCC Plan to illustrate the above
ground petroleum storage tank systems
proposed for the project as well as the
location of spill response kits.
In
addition, text was included in the plan to
indicate how equipment on barges
would be refueled and that petroleum
products would be delivered to Galloo
Island by tanker truck and storage tanks
would be refueled on land.
Agreed. Article 12 of the Navigation
Law has been included in the revised
SPCC Plan and the definitions have
been amended to reflect the specific
legal definitions of petroleum and
discharge.
Section 2.4 of the revised SPCC Plan
has been modified to reflect the current
proposed petroleum storage tank
systems and include four 10,000 gallon
diesel fuel storage tanks, one 8,000gallon diesel fuel storage tank, one
6,000-gallon gasoline storage tank, one
2,000-gallon gasoline storage tank, one
1,200 gallon waste oil above ground
storage tank, and one 550-gallon diesel
storage tank. In addition, Section 2.4
now indicates that each of the petroleum
above ground storage tanks (ASTs),
piping, inventory control system,
dispensers, and associated secondary
containment
will
comply
with
applicable NYSDEC Petroleum Bulk
Storage regulations and guidelines.
Figures 7, 8, and 9 also specify the
various state of the art tank equipment
that would conform to NYSDEC PBS
regulations. As a condition of DEC
permits for this project, the SPCC Plan,
including the proposed tank designs,

Hounsfield Wind Farm


Final Environmental Impact Statement

SPCC-6

SPCC-7

SPCC-8

SPCC-9

clarified, and/or changed to meet


DEC requirements.
Source: DEC
Page 2-3, Sec. 2.7 The correct local
phone number for NYS DEC Spill
Response is 315-785-2513. DECs
preference is to strike this number for
any part of the SPCC Plan that
discusses
proper
reporting
procedures. The only number that
should be used to report a spill is 1800-457-7362.
Source: DEC
Page 4-1, Sec. 4.1 describes potential
routes for spills to reach surface
water. This section neglects the
potential for spills to follow a
subsurface path, either directly to
surface water, or via groundwater
migration. State regulations clearly
address spills to the land and spills to
groundwater, in addition to spills to
surface water.
Source: DEC
Page 4-10, Sec. 4.10 This section
states that drums are not refilled.
What about used motor oil? If
equipment will be maintained on the
island, drums will be filled with spent
petroleum. This should be clarified
or revised as appropriate.
Source: DEC

Pages 4-12 & 13, Sec. 4.12.1 The


term Discharge, as it is used in this
document, does not conform to the
definition in Article 12 Navigation
Law.
In addition, the PBS
regulations use a distinct definition
for Spill. Reporting of discharges
is discussed further in the appendix
on page 83 of 92. The Departments
guidance states, All petroleum spills
3-144

will be reviewed by DEC to ensure that


all elements of the plan conform to
DEC requirements.
Upon further consultation with the
Division of Remediation, it has been
determined that the preferred phone
number to report spills is (518) 4577362, due to the fact that the 800
number would only work in NYS, and
cell phones on the island may route
through a Canadian cell tower. The
SPCC Plan will be revised accordingly.
Section 4.2 of the SPCC Plan has been
modified to reflect the potential of spills
directly to surface water or migrating to
surface water by flow over land,
migration through groundwater, through
the unsaturated subsurface soil or
bedrock, or through storm water
transport.

Section 4.10 of the SPCC Plan has been


modified to reflect the potential reuse of
steel drums during the Construction and
Startup
Phase
to
temporarily
containerize used oil on secondary
containment structures prior to off-site
disposal. It should be noted that a
1,200-gallon used oil above ground
storage tank will be used during the
Operations Phase for management of
used oil. This section was also revised
to include the use of on-site spill kits to
address drum spills as required.
Section 4.12 has been revised
accordingly, and Section 2.1 of the
revised SPCC Plan includes definitions
of a spill event and discharge that reflect
the
above-mentioned
comments.
Additionally, DEC will require that a
contractor be identified that will be
called to respond to spills when an
outside contractor is required. The
contractor must be familiar with the

Hounsfield Wind Farm


Final Environmental Impact Statement

that occur within New York State contents of the SPCC and existing
(NYS) must be reported to the NYS conditions on the site.
Spill
Hotline
(1-800-457-7362)
within 2 hours of discovery, except
spills which meet all of the following
criteria:
1. The quantity is known to be less
than 5 gallons; and
2. The spill is contained and under
the control of the spiller; and
3. The spill has not and will not reach
the State's water or any land; and
4. The spill is cleaned up within 2
hours of discovery.

SPCC-10

A spill is considered to have not


impacted land if it occurs on a paved
surface such as asphalt or concrete.
A spill in a dirt or gravel parking lot
is considered to have impacted land
and is reportable. Therefore, ALL
spills to the land are reportable.
Essentially, the only spills that do not
need reporting are those spills <5
gallons that are to a properly
designed and maintained secondary
containment system AND which are
cleaned up within two hours.
Source: DEC
The SPCC Plan does not describe a
Spill Kit in detail. A typical spill
kit uses a 90-gallon poly overpack
drum (which can be used to pack a
standard 55-gallon drum inside),
which is filled with absorbent booms,
pillows, and/or pads, safety glasses,
and gloves. The potential for large
spills exists both in the construction
and operation phases of the project.
In lieu of a full-blown Facility
Response Plan, the SPCC plan should
describe, in a reasonable level of
detail, the resources available to
respond to these spills. Due to the
location of the facility, it is unlikely
that contracted spill response services
3-145

Section 4.3.1 of the revised SPCC Plan


describes spill kits in detail including
spill kits that service the petroleum
storage tanks and the boat slip.
Locations and applications of these spill
kits have been mentioned throughout the
revised SPCC Plan.
During
construction,
excavators,
backhoe/loaders and dump trucks will
be on-site full time and will be utilized
for spill cleanup on an as-needed basis.
In addition, a limited quantity of site
work equipment will remain on site
during the Operations Phase including a
backhoe/loader, dump truck, etc. The
purchase and operation of a facility

Hounsfield Wind Farm


Final Environmental Impact Statement

can arrive in a reasonable time frame. specific vacuum truck is being


Some of the equipment and materials considered by Upstate New York Power
that should be on hand include:
Corporation.
For Spills to Land:
Tracked Excavator (likely present
during construction, but less likely
during operation)
Backhoe/Loader
(likely
present
during all phases of operation)
Dump Truck
Vacuum Truck (minimum 3,500
gallon) Though expensive, this is a
critical piece of equipment needed to
respond to any spill larger than 100
gallons, and the facility should
consider having one available on site
at all times.
For Spills that affect Water:
Harbor Boom (at least 500 feet)
Absorbent Boom (at least 500 feet)
Work Boats (at least 3)

SPCC-11

If this equipment is not immediately


available, spills that reach the water
will likely be unrecoverable.
Source: DEC
The cleanup of spills at the facility
will result in the generation of
cleanup debris (oil soaked booms,
pads,
speedi-dry,
soil,
etc.).
Generally, the owner is allowed 60
days to effect proper disposal,
provided the debris is stored
properly. It is recommended that
provisions be made for the storage of
a rolloff container stored in a pole
barn or under a pavilion. This would
allow for accumulation of small
quantities of debris as it is generated,
and then hauling the rolloff for
proper disposal. In addition, it may
be a good idea to provide a 6,000gallon tank for waste liquid
containment and storage.
3-146

Comment noted. The purchase and


operation of a facility specific roll off
and waste liquid AST is being
considered by Upstate New York Power
Corporation.

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Final Environmental Impact Statement

SPCC-12

SPCC-13

Source: DEC
Secondary Containment (other than The final design of the transformers and
for petroleum storage tanks):
associated secondary containment and
above ground petroleum storage tank
The containment structures for systems has not been completed. Once
transformers should be described in the final design is complete, details
greater detail. Often the challenge regarding the AST specifications (i.e.,
lies in providing an adequate specific models, installation plans, etc.)
containment capacity while keeping and ancillary containment structures will
the containment structure free from be incorporated into a revised SPCC
storm water.
Plan. In addition, once construction of
the facility is complete, the SPCC Plan
While the SPCC Plan describes will again be revised to reflect any
containment for above ground changes between design specifications
storage tanks, this containment does and record drawings (i.e. as-builts). All
not protect against all types of spills, storage tank systems and secondary
especially delivery overfills. The containment will be designed in
Plans should provide specific tank accordance NYSDEC PBS regulations
models and installation plans.
contained in 6 NYCRR Parts 612
through 614 as well as federal
The Plan does not reference regulations. Secondary containment for
containment for the fuel delivery the delivery trucks will consist of spill
placed
beneath
any
vehicles. The greatest chance for buckets
spills is during product transfer. connections/valves during oil transfers;
Federal SPCC requirements may this is described in Section 4.5 of the
include secondary containment for SPCC Plan.
the delivery vehicle.
Source: DEC
Spill Reporting and Documentation: Section 4.12.2 of the SPCC Plan has
DECs experience with other wind been modified to maintain a written
farms shows that spills can be summary of any spills that occur
expected during the construction and including the spill date, time, product,
operational phases. Though many of quantity, GPS location. Section 4.12.2
these spills may be small, they must of the SPCC Plan has been modified to
be properly reported, cleaned up, and address reporting of debris quantity,
documented. The DEC Regional confirmation sampling results, and
Spill Response Unit lacks the disposal confirmation. This information
resources to respond to Galloo Island will be made available to NYSDEC in
to oversee the cleanup of every spill. ESRI GIS format with a geographic data
Therefore, the project sponsor must and data tables.
develop procedures for DEC
approval
that
address
proper
reporting,
cleanup,
and
documentation.
This includes a
requirement to keep a written
summary that includes Spill Date,
Time, Product, Quantity, GPS
3-147

Hounsfield Wind Farm


Final Environmental Impact Statement

Location,
Debris
Quantity,
Confirmation Sampling Results, and
Disposal Confirmation.
This
information should be made available
to the Department in ESRI GIS
format with a geographic data and
data tables.
Source: DEC
Topic: Diurnal Bird Movement
Comment
Comments
Responses
#
DBM-1
The Diurnal Bird Movement Study An additional diurnal bird movement
states that five migrating bird survey was conducted in 2009 in
stations were operated for 20-30 accordance with requests made by
minutes (page 3). According to the NYDEC in a letter dated June 6, 2009.
Guidelines, observations should be This latest survey included different
made throughout the day until two regions of the island than reported in
hours before sunset from a series of 2008 and specifically included the
prominent points within the project northwest side of the island. The data
area. This deficiency should be from this 2009 study confirms the avian
addressed with additional surveys. flight patterns document in the 2008
On page 5 of the report, it is stated diurnal bird movement study and
that of the Five-Point Surveys supports the idea that these are annual
conducted for migrating species, patterns. Concurrence with the scope of
there were no count sites at the work by NYDEC is noted.
northwestern end of the island.
Clarification needs to be made as to
why all of the five count sites were
on the southeastern edge of the
island. The project sponsor has
provided a work plan for an
additional Breeding Bird Survey to
be conducted in 2009. In a memo to
the project attorney dated 06/08/09,
DEC concurred that the scope of this
plan, which includes a Breeding Bird
Survey and an additional Diurnal
Bird Movement Study (including a
requirement to address the comment
regarding location of count sites), is
satisfactory to provide supplemental
information necessary for DEC to
fully assess avian impacts for these
resources.
Source: DEC
Topic: 2007-2008 Winter Bird Studies
3-148

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Final Environmental Impact Statement

Comment
#
WBS-1

Comment
#
BBS-1

Comments

Responses

This report states that no Shorteared Owls were observed during


the diurnal perimeter surveys or
during the dusk surveys of the
islands grassland areas that
occurred on the December 20 and
January 16 visits (page 7). Two
days of dusk surveys are
inadequate to detect short-eared
owls. Additionally, the TES report
including the observations of
Short-Eared Owls (see comment
on the Avian Risk Assessment,
above) should be included in
background information used for
preparation of the 2009-2010
Winter Bird Survey report. The
project sponsor has provided a
work plan for an additional Winter
Bird Study to be conducted from
November 2009 through March
2010. In a memo to the project
attorney dated 06/08/09, DEC
concurred that the scope of this
study is satisfactory to provide
supplemental
information
necessary for DEC to assess avian
impacts for these resources.
Source: DEC

Refer to Response ARA-1 concerning the


sightings of Short-eared Owl and the
additional 2009 winter survey that was
conducted. Upstate Power will proceed to
conduct the 2009-2010 survey using the
approved scope of work.

Topic: Breeding Bird Survey


Comments
The Breeding Bird Survey (BBS)
states that there were 176 point
counts at 84 turbine locations with
each point count visited about twice
during the breeding season (page 2).
DECs Guidelines for Conducting
Bird and Bat Studies at Commercial
Wind Energy Projects (Guidelines)
state that point counts should be
conducted at least once per week
from May-June and September. This
3-149

Responses

At the request of the NYSDEC, a


second breeding bird survey was
conducted by Old Bird, Inc on Galloo
Island. The study addressed specific
survey requests made by NYDEC.
Those requests included the additional
survey that focused the point count and
transect survey on detecting New York
State listed species.
The following species detected in the

Hounsfield Wind Farm


Final Environmental Impact Statement

Comment
#
ARA-1

deficiency should be addressed with 2009 survey are listed by NYDEC:


additional breeding bird surveys. On Pied-billed Grebe, Bald Eagle, Northern
page 3 of this report, it states that the Harrier, Upland Sandpiper, common
objective is to collect baseline Loon, American Bittern and Coopers
breeding species data that can be Hawk. No NY listed grassland birds
compared to similar data collected were documented in the 2009 survey
after construction to determine the except for those also noted in 2008,
project impacts. That is one of the namely Northern Harrier and Upland
objectives, but another objective is Sandpiper. The study is included in the
to collect breeding bird data so we FEIS at Appendix H.
know what species are nesting there
or utilizing the area and determine The study adds more certainty to the
how we can avoid impacting the understanding of the potential impact of
species especially when we consider the Project on the avian population and
endangered and threatened species. more confidence that only two listed
An additional limitation to this study species would potentially be affected.
is identified on page 10, where it There is also more confidence that only
states, Weather conditions on Big one pair of Upland Sandpiper and one
Galloo tend to be windy and limit pair of Northern Harriers would
the range of acoustic bird surveys. potentially be affected.
While several of the mornings in
which this bird survey was
conducted had substantial wind and
surf noise, and therefore limited
acoustic survey capabilities at some
point counts, the bulk of the point
counts and transect surveys in this
study were carried out under good
bird survey conditions. Additional
point counts need to be conducted to
offset the number of point counts
conducted in these poor survey
conditions. Source: DEC
Topic: Avian Risk Assessment
Comments
Responses
On page 2 of the Avian Risk
Assessment, it is stated that Shorteared Owl (NY: Endangered) could
be subject to collision risk. No
Short-eared Owls were found in the
2008 bird surveys on Galloo Island
but the species is likely a regular
migrant and occasional wintering
resident on the Island. The Avian
Risk Assessment failed to reference
3-150

The Ecological Report prepared by TES


did indicate observation of short-eared
owls and the Avian Risk Assessment
takes into account that this species is
likely
a
regular
migrant
and
occasionally winters on Galloo Island.
The additional winter bird survey
performed in 2009 did not document
any Short-eared Owl and only one
Northern Harrier was observed. While it

Hounsfield Wind Farm


Final Environmental Impact Statement

ARA-2

the Ecological Resources Report


(DEIS Appendix N), which states
that Short-eared owl, northern
harrier, and Caspian tern were all
observed by TES on the Galloo
Island site (page 23 & Table 3, p. 3).
The TES report including the
observations of Short-Eared Owls
should be referenced in a revised
Avian Risk Assessment. This
reference should also be included in
background information used for
preparation of the 2009-2010 Winter
Bird Survey report.
Source: DEC
On page 15, it is stated that Based
on the 2008 data, Galloo may have
the highest usage of wintering Bald
Eagles of any currently proposed or
existing wind project site in New
York State, and No incidences of
Bald Eagle fatalities have been
documented in North America.
While bald eagles do not nest on
Galloo Island, eagles are observed in
the vicinity during the summer
months. Of equal or greater concern
might be the number of eagles
counted on the island during the
months of February and March. A
high count of 12 recorded on
February 14, 2008 indicates that the
area provides important winter
habitat for the eagles. The findings
note that, because of weather
conditions it wasn't possible to
determine if their use is limited to
feeding and perching on the island
or if it is also an important winter
night roost location for the birds as
well. This is an important question
which needs to be answered. In
addition to the collision danger,
which is unknown at this time, but
could prove to be high, taking away
traditional winter habitat used by
foraging and or roosting bald eagles
3-151

is too early to make any firm


conclusions, the two initial winter
surveys appear to document lower ratios
of NYS listed raptors than other nearby
regions. The third survey (2009-2010)
will acknowledge the presence of the
owl during the TES survey and further
help elucidate the situation on Galloo
Island for listed raptors.

Surveys (though weather limited) have


not shown that the island is a winter
night roost site. The 2008-2009 Winter
Bird Study (Appendix X) data for Bald
Eagle indicated only a few Bald Eagles
were present in winter 2008-2009. It is
possible that a small number of eagles
may be displaced or at worst case killed
in collision impact -- as stated in the
ARA.
The significance of the
displacement is currently small because
this is the first US wind project on Lake
Ontario
that
may
cause
such
displacement and the area of potential
displacement is relatively small
compared to the amount of available
resource currently available to Bald
Eagles on Lake Ontario. As stated in the
ARA (P.18), displacement is only a
potential as much of the eagle activity
occurs along the ice edge offshore.
Regarding the bald eagle fatality:
In spring 2009 an injured three-year old
Bald Eagle was apparently found on the
ground beneath one of the wind turbines
at the Erie Shores Wind Farm in
southern Ontario. The bird reportedly
had one of its wings nearly cut off,
strongly suggesting a collision with a
wind turbine blade. The bird was
euthanized and the Ontario Ministry of

Hounsfield Wind Farm


Final Environmental Impact Statement

should be addressed. Also, it has


recently been reported that there was
a Bald eagle killed by turbines on
Lake Erie shores, Ontario (personal
communication, P. Nye). In light of
this, potential impacts to this species
on Galloo Island should be reevaluated.
Source: DEC

ARA-3

ARA-4

Natural Resources (OMNR) apparently


picked up the bird for autopsy in early
June 2009. The news of this fatality has
since circulated informally among
Canadian and US wildlife officials. As
of November 8, 2009, there has been no
public announcement of this fatality by
OMNR or Canadian Wildlife Service.
Until there is a formal announcement of
the details of this fatality, it may be
premature to formally speculate on how
this event might affect the assessment of
potential Bald Eagle collision fatalities
at the proposed Hounsfield Wind
Energy Project on Galloo Island, NY.
However, such a fatality would not
affect the current assessment of
potential Bald Eagle impact for the
project. The 2008 Avian Risk
Assessment for the Hounsfield Wind
Energy Project clearly stated that there
is collision risk for Bald Eagles from
wind turbines on Galloo, assuming Bald
Eagles continue their occasional
presence on Galloo after the wind
project is built.
On page 17, it is stated that the Presence of 2,500 nesting pairs vs. the
Double-crested Cormorant nesting stated goal of 1,500 pairs is
population on Little Galloo is acknowledged.
managed by NYDEC to be around
1,500 pairs. DECs goal or target is
to have 1,500 nesting pairs, but there
are currently 2,500 nesting pairs
with little reproduction (due to egg
oiling).
Source: DEC
Page 21 of the Avian Risk Reintroduction of fox is no longer being
Assessment includes the statement, contemplated for the Project.
Reintroducing fox and allowing
coyote to repopulate Galloo will
help reduce the size of vole
population maxima and may lead to
lower winter raptor numbers.
Though note that adding additional
predators to the Island could
adversely
affect
the
Upland
Sandpiper and Harrier. Introducing
3-152

Hounsfield Wind Farm


Final Environmental Impact Statement

ARA-5

Comment
#
RS-1

fox and coyote to the island to


control vole populations is not an
option. NYS Standard Operating
Procedures do not allow for the trapand-transfer of coyotes. In addition,
this is not a well thought-out
recommendation. What will keep
these mammals from leaving the
island? Even if they did target voles
and not the ground nesting bird
species, what happens when the vole
numbers decrease? Source: DEC
Also on page 21, the statement that Upstate Power will conduct a pale
the overall effect of the wind project swallow-wort control program in open
(including the transmission line areas and forest understory areas and a
corridor) will increase habitat for mowing program in areas currently in
these species (Upland Sandpipers agricultural production to increase
and Northern Harriers - both NY available habitat for grassland and forest
threatened species), and potentially understory species. Because the
benefit their status in the region, understanding of avoidance behavior on
needs to be supported by a more the part of certain grassland bird species
thorough rationale. For example, is incomplete at this time, this success of
does the project anticipate clearing these measures for various species will
large patches of habitat and be confirmed through post-construction
managing them for grasslands? It is monitoring.
also recommended on Page 22,
Eliminate agricultural operations at It is not expected that any clearing or
the north end of Galloo to reduce or maintenance associated with the
eliminate foraging areas for Canada proposed transmission line route would
Geese and migratory shorebirds. be sufficient to provide significant
This action might presumably additional habitat for the grassland
decrease the amount of grasslands species identified in this comment.
on the island and reduce habitat for
these
species.
These The agricultural operations will be
recommendations
should
be terminated and for mitigation, Upstate
revisited in light of these questions, Power will control swallow-wort on the
and be discussed in the context of an island and mow as specified above.
overall habitat management plan for
the island (see State Lands and Open
Space Conservation Plan, below).
Source: DEC
Topic: Spring 2008 Radar Survey Report
Comments
Responses
Provide a graph of flight heights and The graph is provided as Figure 3.0-6 in
passage rates for the Spring Radar this FEIS.
3-153

Hounsfield Wind Farm


Final Environmental Impact Statement

Survey similar to the one in the Fall


Radar Survey (Fig. 14 in the Fall
Radar Study).
Source: DEC

3-154

Hounsfield Wind Farm


Final Environmental Impact Statement

4.0 Comments Received on DEC Permits


The comments in this section were received during the public comment period for the
following permits deemed complete by the DEC on November 2, 2009. The permit
review included a 30-day public comment period which closed December 4, 2009.
Article 17 Titles 7 & 8 P/C/I SPDES - Surface Discharge
Article 24 Freshwater Wetlands
Article 15 Title 5 Excavation & Fill in Navigable Waters
Article 23 Title 27 Mined Land Reclamation
Section 401 - Clean Water Act Water Quality Certification

Comment
#
CDP -1

Comments

Topic: Comments on DEC Permits


Responses

Two Related Comments:


Comment One: Our concerns are
many but mainly stem from our
initial review of the massive DEIS
when compared with the Public
Scoping Document published in
Draft form May 14, 2008 and
finalized on September 17, 2008.
The process of comparison is
overwhelming, especially when we
cannot be directly involved in the
project; since the Wind Project is
under the Town of Hounsfield
jurisdiction and the Transmission
line is considered a Type II action
under
SEQRA
with
little
information available to our Town.
Source: Karl R. Williams
Comment Two: We have many
concerns not the least is the review
of the huge amount of DEIS
material as compared to the Public
Scoping
Document
initially
published in draft form on May 14,
2008 and finalized September 17,
2008. The process of comparison is
massive, considering that the Wind
Project is under the auspices of the
Town of Hounsfield jurisdiction and
4-1

On February 27, 2009 the NYSDEC


accepted the DEIS as adequate for
public review and published the Notice
of Completion of the DEIS indicating
the document was available for review
by agencies and the public. The public
comment period was extended to 90
days and remained open until May 29,
2009. During this period a public
hearing was held on May 18, 2009 in
Hounsfield, New York to allow for
public comment. In addition to the
public hearing, the public and various
local, state and federal agencies
submitted written comments to the Lead
Agency regarding the Project. The
comments recently received by the
NYSDEC were in response to the permit
application submitted by the project
sponsor and NYSDEC has agreed to
include these comments in the SEQRA
record and provide responses herein.
Although the Town of Henderson and
Henderson Harbor Area Chamber of
Commerce are not involved or interested
agencies as defined by SEQRA, having
no discretionary approvals for the
Hounsfield Wind Farm, comments from
the public were accepted and
encouraged.

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -2

the Transmission Line is considered


a Type II action under SEQRA.
Very little information is available
to the Town of Henderson.
Source: Heart of Henderson
I believe the developer did what was
legally necessary to complete his
DEIS, but I also believe that many
people were not aware of the time
line and the activity going on for the
past couple of years. Why did this
project not receive more press? How
many people attended the meetings?
Were the people who own camps in
the view shed informed? Was the
full
intention
of
expanded
development revealed, i.e. wind
farms on other islands and in the
offshore waters in the "Golden
Crescent"?
Source: Donald Peters

The public comment period for the


Hounsfield Wind Farm DEIS closed on
May 31, 2009. The DEIS comment
period was extended to 90 days to
facilitate public participation.
The
public comment period for the
Hounsfield
Wind
Farm
Permit
applications closed December 4, 2009.
Notice of the public scoping meeting,
publication of the DEIS and public
hearing on the DEIS were noticed as
required by SEQRA statute. The notices
were published in the Watertown Daily
Times and the DEC Environmental
Notice Bulletin. All documents related
to the SEQR and DEC permitting
processes have been made available to
the public at local libraries in the Towns
of Hounsfield and Henderson, and the
Town of Hounsfield Municipal Office.
These documents have also been made
available for review online, both on the
DEC
website
at:
http://www.dec.ny.gov/permits/54687.ht
ml and the Upstate NY Power Corp.
website
at:
http://upstatenypower.com/index.html
The proposed action, including DEC
decisions, hearings and public comment
processes,
have
been
covered
extensively by regional media outlets.
The Project Sponsor and DEC have no
control over the local press coverage.
However, it should be noted there have
been at least 30 articles in the
Watertown Daily Times about the
project.
The scope of the project under review
by the DEC is the construction of the

4-2

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -3

Two Related Comments:


Comment One: The Heart of
Henderson is extremely alarmed
regarding the dearth of information
available, or even attainable as part
of the public record. And what was
placed in local libraries promptly
disappeared.
Source: Heart of Henderson

CDP -4

Comment Two: We are gravely


concerned about the information that
is not available, attainable, or part of
the public record.
Source: Karl R. Williams
Two Related Comments:
Comment 1: Portions of Galloo
Island are included in the NYSDEC
Open Spaces Plan, as are close
proximity islands, Little Galloo, and
Gull Island. How does this affect the
request by the developer, Upstate
NY
Power
Corporation
to
completely cover Galloo Island with
an industrial VVTG complex? Has
the NYSDEC modified their Open
Spaces Plan to accommodate the
substantial industrial complex cited
very close to three (3) notable sites?
Source: Henderson Habor Chamber
of
Commerce
Economic
Development Committee
Comment 2: Portions of Galloo
Island are included in the NYSDEC
Open Spaces Plan, as are close
proximity islands, Little Galloo, and
Gull Island. Several years ago, the
NYSDEC considered a purchase of
Galloo Island. During the NYSDEC
4-3

WTG and related infrastructure to be


located on Galloo Island. DEC has not
received any proposals involving wind
turbines proposed on other islands or in
Lake Ontario as part of this Project.
All information that was part of the
environmental review for the project
was available in two libraries in the
Town of Hounsfield, the Town clerks
office and on the web on both the DEC
and the Applicants websites. The DEC
was not made aware of any documents
being removed from the libraries.

See response in Section 3.0


Comment 2.2-5 and CDP-2, above.

to

Hounsfield Wind Farm


Final Environmental Impact Statement

review of such action, the island was


considered to be 'fragile and
delicate" and the recommendation in
the report was that the island should
remain it its current state. Such
analysis is highly inconsistent with
the allowance of industrial wind
turbine projects on the island and
proximate to other islands in the
Open Space Plan. This issue must be
addressed in the DElS and the public
must be allowed to comment
Source: Peter Price
Two Identical Comments:
Many of us have only recently
learned that portions of Galloo
Island are included in the DEC open
space plans and that the DEC had
attempted only a few years ago to
acquire and preserve Galloo Island
because of its habitat significance
for a wide variety of living
creatures. Similarly near by islands
are also included in the open space
plan for similar ecological reasons.
Source: Robert Ashodian
Source: Albert Bowers
CDP -5

Several years ago, the NYSDEC


considered purchase of Galloo
Island and proceeded with a final
negotiation that did not result in the
purchase. During the NYSDEC
review of Galloo Island leading up
to their purchase offer, we
understand from discussions, the
island was considered, fragile and
delicate and shall remain in its
current state. Has this previous
determination and review by the
NYSDEC been considered, or made
available to the present NYSDEC
evaluating team? If so, has the
NYSDEC found new information to
consider the island suitable for an
4-4

Many environmental considerations


have been assessed in the SEQRA
process, including the potential for the
project to impact avian species, flora
and fauna and land use. As stated in the
DEIS environmental conditions on
Galloo Island have been significantly
altered by human activity since the
1800s. This includes clear cutting of
the cedar trees that once covered large
portions of the island, converting large
portions of the island for use as sheep
grazing and converting the northern end
of the island for agricultural use. The
nature of the proposed impacts were
evaluated along and the existing ecology
and wildlife identified, based in this

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -6

industrial WTG complex?


Source: Henderson Harbor Chamber
of
Commerce
Economic
Development Committee
The serene, beautiful, natural,
waterfront viewshed in eastern Lake
Ontario provides public enjoyment
for millions of viewers and serves to
attract property ownership and
commerce, in the form of tourism, to
the whole 1000 Islands Region in
Northern
New
York
State.
Developing one natural resource,
namely the harnessing of wind, for
alternative energy should not come
at the expense of sacrificing an
already existing and critically
important natural resource, our
waterfront viewshed.
Hounsfield Wind Farm will clearly
violate the NYSDEC visual policy
on aesthetic impact, and will harm
the public enjoyment and quality of
life of our residents and businesses
Source: Louise Shim

CDP -7

historical context.

The Visual Assessment Report prepared


for the DEIS indicated there not would
be a significant adverse effect, therefore
the waterfront viewshed will not be
sacrificed. Although the turbines will be
visible from portions of the shoreline of
the Region, based on DECs Visual
Assessment Policy, that does not
necessarily mean it is a significant
negative impact for all viewers.
Comment noted. The DEIS included a
visual analysis prepared according to
DECs visual policy, which addresses
the potential for visual impacts to
designated aesthetic resources, such as
parks, historic sites and scenic byways.
Comments on the DEIS included
concerns for changes in the visual
setting at these designated aesthetic
resources. These comments were
considered and the FEIS includes
proposed activities to offset the
proposed changes in visual setting at
these locations. See also response to
comments on 2.6-12, 2.6-14 and 2.6-18.

On page 2- 13 6 and 2- 13 7 of their See response to CDP-6.


Draft EIS, UNYPC falsely states,
"Given the significant distance of
the project from virtually all
publicly accessible vantage points,
the project will not cause the
diminishment of public enjoyment
and appreciation of an inventoried
resource, or impair the character or
quality of such a place." UNYPC's
own photo simulations in their Draft
EIS "Appendix Q: Visual Resources
Report
and
Line-of-Sight
Drawings", verify the clear visibility
of the wind turbines from Ellisburg
to Henderson (including simulations
specifically at Association Island) to
4-5

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -8

CDP -9

Sackets Harbor and Cape Vincent in


Exhibits A5-a to A14-b. Source:
Louise Shim
The wind farm will damage the
aesthetic appeal, public enjoyment,
and character of the waterfront
enjoyed by the millions of visitors to
4 nearby state parks (Southwick
Beach, Robert G. Wehle, Westcott
Beach, Sackets Harbor Battlefield)
and the Seaway Trail, to the
thousands of annual visitors to
Association Island, and to the
thousands of homeowners and
businesses in the region.
Source: Louise Shim
In the Draft E1S on page 2-127,
UNYPC fails to fulfill the
requirement that states "The DEC
Visual Policy requires that all
aesthetic resources of Statewide
Significance by identified with any
potential adverse effects on those
resources resulting from the
Project." In Table 2.6-1 Potential
Aesthetic
Resources,
they
inaccurately
characterize
Association Island as only having
"local significance". Association
Island has been rated by Woodalls, a
leading ratings agency in the RV
industry, in the top 3% of over 8200
private campgrounds that Woodalls
rates across the United States and
Canada. The negative impact of
wind farms to our business is not
just of "local significance", but will
have
far-reaching
"state-wide
significance" particularly when you
factor in the 7-to-1 multiplier
impact. Not only will businesses
suffer, but the county and state will
lose the sales taxes, gasoline taxes,
highway tolls, and income taxes
generated by the revenues from our
customers during their stays at, and
while enroute to and from,
4-6

Based on DECs Visual Assessment


Guidance the mere visibility of the
WTGs does not mean that the project
will have a significant negative impact
on the region. See response to CDP-6.
See also responses to comment at 2.618.

A letter from the SHPO dated June 23,


2009
determined
that
although
Association Island was determined an
eligible historic district within the
survey area, it was not identified by that
agency a receptor where visual impacts
should
be
carefully
assessed.
Association Island is not listed as a
resource because it does not meet the
criteria listed below in the DEC Visual
Policy for Statewide Significance. The
criteria for being a resource of Statewide
Significance is one or more of the
following categories:
1) A property on or eligible for inclusion
in the National or State Register of
Historic Places
2) State Parks
3) Urban Cultural Parks
4) The State Forest Preserve
5) National Wildlife Refuges
6) National Natural Landmarks
7) The National Park System,
Recreation Areas, Seashores, Forests
8) Rivers designated as National or State
Wild, Scenic or Recreational
9) A site, area, lake, reservoir or
highway designated or eligible for
designation as scenic
10) Scenic Areas of Statewide
Significance [of Article 42 of Executive

Hounsfield Wind Farm


Final Environmental Impact Statement

Association Island.
Source: Louise Shim

CDP -10

CDP -11

CDP -12

CDP -13

These projects will forever destroy


some of the most scenic property in
our State.
Source: Alex James
The view has changed minimally in
all those years with our westerly
views of gorgeous sunsets off the
end of Galloo Island, the night sky
full of stars, the blinking of the
Stony Point light and the more faint
Galloo Island light. It would be a
shame to destroy such a sight and
the pristine beauty of eastern Lake
Ontario for the benefit of a few land
owners and purveyors of wind
generating machinery. One can only
imagine what a plethora of blinking
red and white strobe lights, certainly
visible for at least a 30 mile radius,
would do to this scene!
I just believe there are better and
more isolated places in Northern
NYS away from an area having such
raw beauty and rich recreational
assets.
Source: Donald Brandt
There is concern about the
destruction of the view-shed, the
recreational use of the Lake, its
islands and beaches, including the
many State Parklands that will be
adversely affected
Source: Albert Bowers
The photo simulations fail to depict
how the FAA required red-blinking
lights will turn our waterfront
4-7

Law]
11) A State or federally designated trail,
or one proposed for designation
12) Adirondack Park Scenic Vistas;
13) State Nature and Historic Preserve
Areas;
14) Palisades Park;
15) Bond Act Properties purchased
under Exceptional Scenic Beauty or
Open Space category.
Comment noted. The commenter does
not provide any factual data for this
opinion and therefore DEC can not
respond to this substantively.
The DEC acknowledges that the FAA
mandated lights would be visible from
many of the locations that will have a
view of the island. No white strobe
lights are proposed for Galloo Island.

Although the turbines will be visible


from much of the shoreline of the area,
the wind farm will not preclude or
impact use of the Lake, other islands,
beaches or state parks.

Three visual simulations were prepared


to evaluate the impact of nighttime
lighting on the night horizon. (See

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -14

horizon into an industrial red-light


zone at night a severely negative
aesthetic impact. The wind farm
project at Galloo Island will forever
damage our waterfront and direct
westward sunset views, a waterfront
horizon that has been lauded for its
un-touched beauty since the historic
battles of the War of 1812.
Source: Louise Shim

Appendix J) Based on the simulation, it


can generally be stated that the
mandatory FAA lighting will be visible
at night from the same locations that
will be able to see the wind turbines
during the daylight hours. However, the
lights will be more than five miles away.
The minimum number of towers
required by the FAA will be lit and all
lights will flash simultaneously.

Comment 2: UNYPC failed to show


simulations of the FAA-required
red-blinking lights which must flash
in unison on top of the 400-+ feet
wind turbine towers. We ask that
regulators and public officials
require that UNYPC to provide
these same photo simulations
showing the red-blinking lights, and
we ask that the regulators and public
officials imagine having the same
red-lights blinking in their backyard
as they make their decision
regarding the development of the
wind farm.
Source: Louise Shim
UNYPC expects to use L-864
lighting, which they suggest are low
intensity red lights emitting 2000
candelas, on 23 of 84 wind turbines.
The FAA requires the red lights to
all flash in unison. UNYPC suggests
that these lights will have limited
visual impact due to the distance of
5.6 miles to the nearest shoreline
and due to earth's curvature. In late
summer and fall of 2009, when
water levels were lower, the red
lights blinking from the wind
turbines at Wolfe Island (required to
have red lights on -30 out of 86
wind turbines and situated -20 miles
north-west) were clearly visible
from Association Island's shoreline.
We countered our customers
complaints about the obnoxious red-

As shown on the figure in Appendix J,


the lights will be visible from many of
the same locations that see the towers in
the daytime.

4-8

The concern of impact during sunset is


not clear as the sunset will diminish the
impact of visibility of the FAA lights for
those looking to the west.
The 200 candela difference between the
turbines on Wolfe Island and the
proposed turbines on Galloo Island
would be insignificant at 8.2 miles (the
distance between Association Island and
Galloo Island).
The 200 candela
difference is roughly equivalent to the
brightness of 200 candles at a one foot
distance, however this difference will be
viewed from at least 8.2 miles away.

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -15

CDP -16

blinking lights by saying that at least


the red-lights are not obstructing our
westward sunset views over Lake
Ontario and they are only visible
during periods of low lake levels
(due to the earth's curvature). With
the much closer proximity of 5.6
miles to Galloo Island (versus 20
miles to Wolfe Island), distance and
earth's curvature will not diminish
the negative aesthetic impact. The
wind turbines and FAA-required red
lights will clearly be visible year
round by all areas along our
shoreline, especially when you
consider that the lights at Galloo
Island will be at a stronger 2000
candelas than the lights at Wolfe
Island, which have brightness of
1800 candelas.
Source: Louise Shim
Counter to the NYS DEC
requirement, UNYPC completely
failed to include the analysis of the
adverse economic impact for the
inventoried resources that they
already listed with statewide
significance (including the state
parks at Southwick Beach, Robert G
Wehle, Westcott Beach, Sackets
Harbor Battlefield), and they failed
to characterize Association lsland as
having statewide significance. We
ask that you require UNYPC to
complete this analysis of the
potential adverse impact on
inventoried resources of statewide
significance" both aesthetically and
economically, and in an accurate
manner.
Source: Louise Shim
Two Related Comments:

Although Association Island does not


meet the criteria for Statewide
Significance, the potential impact was
still assessed in the Visual Resource
Asessment (VRA) included in as
Appendix Q of the DEIS.

The VRA contains visual simulations


from 22 different viewpoints, both in
Comment One: Also, the scoping Lake Ontario and on land. Specifically
study
promises
view
shed six of these locations were in the Town
simulations from at least 10 vantage of Henderson.
points which are not offered in the
4-9

Hounsfield Wind Farm


Final Environmental Impact Statement

DEIS, including many


Township.
Source: Karl Williams

CDP -17

in

our

Comment Two: The scoping study


also promises simulations from ten
vantage points. These are not
offered in the DEIS, many of which
are in the Town of Henderson.
Source: Heart of Henderson
In their Draft EIS Appendix Q page
8, UNYPC inaccurately states '"This
portion of New York State is
generally rural with [only, my words
not theirs] two (2) village centers
located within the study area; Cape
Vincent and Sackets Harbor. The
Village of Cape Vincent (population
760) is located more than 14 miles
from the nearest turbine . . . The
Village
of
Sackets
Harbor
(population 1,386) is approximately
12.2 miles east of Galloo Island.
"UNYPC completely failed to
recognize Henderson within its
study area when Henderson is the
closest mainland town at only 5.6
miles east of Galloo Island with a
population of 1,377 which is larger
than Cape Vincent and equivalent to
Sackets Harbor. How could UNYPC
neglect to recognize Henderson as
an effected population when
Henderson is the closest town to
Galloo Island, when Henderson is
the
location
where
their
infrastructure for transmission lines
and telecommunications will come
on-shore,
when
Henderson's
properties will be dissected by their
transmission lines, and when
Henderson's viewshed is the most
closely and directly impacted?
While Galloo Island somehow falls
under the jurisdiction of the Town of
Hounsfield, how can UNYPC
neglect to recognize Henderson as a
4-10

The intent of the statement in the VRA


is that there are two villages in the Study
Area.
The VRA was analyzing
population centers, specifically village
centers.
Additionally, the DEIS does not identify
the Town of Henderson as an involved
Town because the Town does not have
any discretionary approvals for the
project specifically under review by the
DECs SEQR process.

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -18

CDP -19

critically important jurisdictional


authority?
Source: Louise Shim
The Draft EIS does not address the
issue of Environmental Justice as it
relates to the low income residents
of Jefferson County, New York. If a
major energy project were proposed
for an urban area in downstate New
York the DEC's environmental
justice policies would be applied.
This project and its associated
projects and transmission lines will
permanently deface a large swath of
northern New York in order to
provide power to largely downstate
interests. If the tables were turned
and a power generation project was
proposed for Brooklyn, the Bronx,
or Long Island in order to deliver
power to Jefferson County the DEC
would analyze the environmental
justice issues during its SEQR
review. Your failure to include this
issue in the DEIS reveals a selective
and discriminatory application of the
DECs
environmental
justice
requirements and deprives the local
community members of equal
protection under the law.
Source: Peter Price
The developer provides no in-depth
economic impact analysis in their
project data, and we respectfully
request this data be provided for the
benefit of review by the DPS, DEC
and the affected Towns. The
decision by our New York State lead
agencies should be delayed, until
which time adequate factual data
can be provided by the developer
and analyzed by said parties. If this
project is as robust technically and
commercially as the seasoned
developer Upstate NY Power claims
in their project data, this request
should be easily and timely
4-11

According
to
the
NYSDEC
Environmental Justice Policy, Lowincome community means a census
block group, or contiguous area with
multiple census block groups, having a
low-income population equal to or
greater than 23.59% of the total
population and Low-income population
means a population having an annual
income that is less than the poverty
threshold. For purposes of this policy,
poverty thresholds are established by the
U.S. Census Bureau.
In addition,
Minority community means a census
block group, or contiguous area with
multiple census block groups, having a
minority population equal to or greater
than 33.8% in a rural area of the total
population.
The Total poverty in
Jefferson County was shown in the
DEIS to be 13.3% and minority
populations make up 13.4% of Jefferson
County. The Town of Hounsfield has
lower percentages on both poverty and
minority status. Based on this criteria,
NYSDECs environmental justice policy
does not apply to this area.
An economic impact analysis is not part
of SERQA and was not identified during
the public scoping period as a required
component. The potential economic
impacts
are
assessed
in
the
socioeconomic section of the DEIS.

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -20

CDP -21

CDP -22

CDP -23

submitted.
Source: Henderson Harbor Area
Chamber of Commerce
The creation of jobs and supply
chain
associated
with
the
construction of this project is also an
unknown benefit/impact.
The WTG project will have many
components from foreign sources, or
supplied within the developer's
overall corporate structure. This is a
contentious issue, one which has
received
national
attention,
especially the recent request from
Senator Schumer to halt a project in
west Texas due to large Federal
subsidy essentially creating jobs on
foreign shores.
Source: Henderson Harbor Area
Chamber of Commerce
The proposed project will severely
harm our ability to follow our
Town's
Plan
for
Economic
Development, limit our Committee's
ability to attract or maintain
business, and degrade our tax base
by an expected sharp decline in
property values, and thus business
viability.
Source: Henderson Harbor Area
Chamber of Commerce
If this project proceeds, we will be
faced with an irreversible and
devastating
effect
to
our
environment, local business, dairy
and agricultural economies, a
degraded tax base and sharply
declining real estate value.
Source: Henderson Harbor Area
Chamber of Commerce

Three Related Comments:


4-12

It is beyond the scope of the DEIS and


SEQRA to discuss benefits associated
with turbine manufacturing. Also, the
Project sponsor has not referred to those
benefits from this project.

The commenter does not specifically


identify why or how the project would
harm the Town of Henderson. No
substantive data is provided to allow the
DEC to further consider this comment.

The commenter does not specifically


identify why or how the project would
harm the Town of Henderson. No
substantive data is provided to allow the
DEC to further consider this comment.
There is no evidence that the wind farm
will negatively impact businesses of the
region or degrade the tax base in the
manner suggested by this comment. In
fact, a recent published study by the
Department of Energy concluded that
wind farms do not affect property values
for nearby property.
There is no factual evidence to support
the conclusion that the visibility of the

Hounsfield Wind Farm


Final Environmental Impact Statement

Comment One: Any decline in project will negatively impact the RV


Association Island's business will association.
negatively impact our vendors and
payroll needs, and subsequently
reduce county and state tax
revenues.
Source: Louise Shim
Comment Two: Our studies showed
that the economic impact of our
business has a 7-to-1 multiplier
impact. In other words, for every $1
dollar spent at our resort, $7 dollars
are spent in the local area. Any
decline in Association Island's
business as a result of the
diminished waterfront viewshed will
have a 7-fold negative impact on
local businesses, with the potential
of a more than a million dollar hit to
the local economy, along with the
loss of associated county and state
tax revenues.
Source: Louise Shim

CDP -24

Comment Three: Association Island


is the largest taxpayer in the Town
of Henderson and one of the largest
taxpayers in Jefferson County. After
vacationing at Association Island,
many of our customers have bid on
and/or purchased properties and
businesses in Henderson and other
local towns. Our business and our
customers help improve property
values and contribute significantly
to the town and county's property
tax base. A decline in Association
Island business will ultimately
negatively impact the town and
county's property tax base
Source: Louise Shim
Two Related Comments:
An economic impact analysis in not part
of SEQRA and was not identified during
Comment One: We request that the public scoping period as a required
regulatory
authorities
require component. Potential economic impacts
UNYPC to conduct and submit a are assessed in the socioeconomic
4-13

Hounsfield Wind Farm


Final Environmental Impact Statement

full Economic Impact Statement,


representing not only the positive
effects of the wind farm on the local
and state economy, but also the
negative impact on local businesses
and tourism to the region and NY
state.
Source: Louise Shim

CDP -25

Comment 2: UNYPC has neglected


to analyze the negative impact to
tourism to the 1000 Islands Region.
Source: Louise Shim
On page 2-1 5 1 of the Draft EIS,
UNYPC states that "Due to the
remote location of the Project, no
impact to tourism or tourism-related
employment on the mainland is
anticipated. Regardless, a survey
conducted in 2003 for the East
Haven Windfarm in Vermont
revealed that 95 percent of visitors
to the state's Northeast Kingdom
would not be deterred from further
visits by the existence of wind
turbine generators. The survey was
conducted by the Institute for
Integrated Rural Tourism." We
argue that the survey results in
Vermont should not be taken into
consideration here, since they were
evaluating a rural in-land area
without the unique waterfront
viewshed which we have here on the
Great Lake of Lake Ontario. We ask
that prior to approving the
development of the Galloo Island
wind farm, regulators must require
UNYPC to engage an independent
consultant to conduct a survey to
determine the impact of tourism to
the Cape Vincent area, which is
situated directly across from the
newly built Wolfe Island wind farm,
and to conduct a survey to
Association Island's customers of
the perceived impact of wind
4-14

section of the DEIS.


Also it should be noted that there are no
peer-reviewed studies that indicate the
presence of a wind farm negatively
affects tourism. This is particularly
salient due to the distance of the project
from the mainland.

An economic impact analysis in not part


of SEQRA and was not identified during
the public scoping period as a required
component. Potential economic impacts
are assessed in the socioeconomic
section of the DEIS.
DEC is not familiar with the details of
this study and cannot comment on the
relevance of this study to the proposed
Galloo Island project.

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -26

CDP -27

CDP -28

CDP -29

turbines and their red lights on the


waterfront horizon.
Source: Louise Shim
Furthermore, UNYPC does not
expect the wind turbines to generate
increased tourism, and due to the
remote offshore location of Galloo
Island
and
their
proposed
development
of
internal
infrastructure
(onsite
housing,
commissary,
transportation
of
employees via helicopter, shipping
via the port of Oswego), their
employees
will
have
little
opportunity to spend time nor
patronize businesses in Jefferson
County. UNYPC's arguments that
the wind farm project will only add
positive benefits to the economy
without any negative impacts to
tourism and local business are
capricious at beat, and authorities
must require UNYPC to provide a
more accurate and comprehensive
analysis of the economic impact.
Source: Louise Shim
The project on Gallo Island in my
estimation will decrease all of my
property values. It is also my
opinion that such a project will
dramatically decrease the tourism
revenues that the area currently
enjoys.
Source: Rich Mangan
We have studied knowledgeable
reference sources such as, Beacon
Hill Institute's Cost Benefit Analysis
of Wind Projects and Appraisal
Group One Wind Turbine Impact
Study to postulate the extent of
negative socio-economic impact to
our business members and to this
diverse area commonly referred as
the Golden Crescent.
Source: Henderson Harbor Area
Chamber of Commerce
If built, this wind development
4-15

Construction employees would be


housed on the island. However, the
permanent employees would work shifts
on the island where they would stay in
onsite housing. The workers would
have a separate residence, likely in the
Jefferson County Area.
Additionally, the Port of Oswego will be
used during construction not for
everyday operations.
Transport of
permanent employees would occur from
Jefferson County.

Comment noted. The commenter does


not provide any factual data for this
opinion and therefore DEC can not
respond to this substantively. In fact, a
recent published study by the
Department of Energy concluded that
wind farms do not affect property values
for nearby property.
DEC is not familiar with the details of
this study and cannot comment on the
relevance of this study to the proposed
Galloo Island project.

Comment noted.

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -30

CDP -31

project will forever change the


quality of life and the vistas that the
people of Jefferson County and the
many thousands of people who
come to our area have come to
enjoy. It seems to me that there must
be areas, even in Jefferson County,
that could be potential sites for such
development that would not have
such a negative impact on the
economy, tourism and quality of
life.
Source: Robert Gamble
The proposed telecommunications
towers and transmission lines will
likely interfere with satellite
reception
and
over-the-air
transmissions,
not
only
for
Association Island's customers but
also for local residents in the
Henderson Harbor area. We ask the
PSC to stop UNYPC's interference
with satellite TV communications
and FCC regulated and protected
airwaves. We also ask the PSC to
require UNYPC to thoroughly
analyze, disclose the impact of, and
eliminate any impairment resulting
from their project on satellite TV,
over-the air DTV, radio, NOAA
emergency weather service, cellular
service, and wireless internet data
service signals.
Source: Louise Shim
Under Section 3.0 of the Draft EIS
page 3 - 1, the SEQRA must contain
a discussion of alternatives to the
proposed action.
No Action: there are approximately
21 wind power projects currently
operating or under construction in
New York State. There are already 4
project proposals for wind farms, all
within a 40-mile radius to Galloo
Island: including 1) the Cape
Vincent Wind Farm with 140
turbines on 335 acres situated 1 0.5
4-16

As stated in both the DEIS and Exhibit


E-5 of the Article VII application the
WTG and transmission line will not
interfere with over the air transmission
for TV or radio.
Satellite
communication is a line-of-sight
transmission by the receiving dish,
therefore WTG and transmission
structures will not interfere with satellite
TV reception.

The alternatives analysis reviewed the


range of reasonable alternatives to the
action which are feasible, considering
the objectives and capabilities of the
project sponsor.
Proposals of other wind farm developers
are not reasonable alternatives to the
discussion of impacts on Galloo Island.
See also response to CDP-36, below.

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -32

miles north of Galloo Island, 2) the


St. Lawrence Wind Power Project
with 86 turbines on 289 acres
situated 15 miles north of Galloo
Island, 3) the Horse Creek-Clayton
Wind Farm with 62 turbines on 71 4
acres situated 20 miles northeast of
Galloo Island, and 4) the Roaring
Brook Wind Project with 39
turbines on 211 acres situated 39
miles east southeast of Galloo
Island. With all these alternative
locations which are situated on inland properties, the need for a wind
farm at this particular location,
situated offshore on an island 5.6
miles into the waters of eastern Lake
Ontario, is greatly diminished. We
ask that the regulators and public
officials recognize NO Action" as
the Preferred Action, to save our
natural resource of the beautiful
waterfront viewshed. We further ask
that regulators and public officials
force developers to seek the
development of alternative energy
away from offshore locations, which
will
irreparably
damage
the
viewshed of eastern Lake Ontario, to
onshore and in-land locations.
Source: Louise Shim
b. Lower Turbine Height: UNYPC
provides a discussion of using
shorter turbines at a maximum tip
height of 339.5 feet versus the
current proposal of 410 feet. Even at
339.5 feet, the project will be
required to have the FAA-required
aviation obstruction lights. We ask
that the regulators request that
UNYPC propose an alternative
solution at much lower turbine
heights that will not be required to
have the FAA-required lighting and
that will not impair the visual
aesthetics of our viewshed.
Source: Louise Shim
4-17

The Project Sponsor analyzed a lower


turbine height that was still a
commercially viable machine.
Any
machine that would be low enough not
to require FAA lighting would not
produce enough electricity for a
commercially viable project.

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -33

CDP -34

CDP -35

Based on the numerous negative


aesthetic and economic impacts
listed in Associations Island's
previous Points #1-10, UNYPC's
wind farm proposal may be in
violation of New York State's
Coastal
Management
Program
Policy #18: To Safeguard the Vital
Economic.
Social
and
Environmental Interests Of The
State and Of Its Citizens, Proposed
Major Actions In The Coastal Area
Must Give Full Consideration To
Those Interests, And To The
Safeguards Which The State Has
Established To Protect Valuable
Coastal Resource Areas (see Draft
EIS page 45). Contrary to UNYPCs
opinion, the Project will adversely
affect the social, economic or
environmental interests of the State
and its Citizens.
Source: Louise Shim
Also, as reported in the Watertown
Daily Times on November 29, 2009,
the New York Independent System
Operator is currently conducting a
study
of
renewable
energy
development, to address the
significant
issue
of
energy
deliverability.
These
results,
expected in early 2010, should be
available for rational and pertinent
public comment on the Galloo
Island project. In fairness to the
public, who are much more
impacted than 250 white-tailed deer
on Galloo Island, the public
comment period should be extended.
Source: John Irwin
Three Related Comments
Comment One: There are many,
many
unanswered
questions
especially related to the potential
total destruction of the delicate
ecosystem on Galloo Island, the
4-18

The Project will not adversely affect


coastal natural resources, water levels
and
flows,
shoreline
damage,
hydroelectric power generating facilities
or recreation nor will it adversely affect
the social, economic or environmental
interests of the State and its citizens. It
will provide beneficial economic
impacts and increase renewable energy
availability in the State. The Project is a
wind energy project that furthers the
States goals of reaching 25 percent
renewable sources by 2015.

The deliverability of the power and


energy use is appropriate for
consideration by the Department of
Public Service in the Article VII review
of the proposed transmission line..

The FEIS has identified potential


impacts to natural resources on Galloo
Island and has provided for further
consultation with DEC to avoid and
mitigate those impacts through the
Article 11 process. The wind farm and
related infrastructure will be constructed

Hounsfield Wind Farm


Final Environmental Impact Statement

nearby islands, the area's fisheries


and the much feared negative impact
on lake front property valuations
and the seasonal based businesses
that are so significant to the local
economy.
Source: Robert Ashodian
Comment Two: There are many,
many unanswered questions about
the effects of these multiple
proposed projects. Some of our
concerns are related to the potential
destruction of the delicate ecosystem
of Lake Ontario, Galloo Island, the
nearby islands, the Lakeshore and
the rivers and streams flowing into
the Lake.
Source: Albert Bowers

CDP -36

in accordance with specifications in


state and federal permits that will result
in the project not negatively impacting
the fisheries in Lake Ontario (See DEIS
Section 2.5.6).
The only impact to a stream is the one
stream on Galloo Island and this impact
has been avoided and mitigated to the
extent practicable. The Project Sponsor
will comply with permit requirements
contained within state and federal
permits to ensure that impacts to this
resource are minimized.

Comment Three: There will be a


serious devaluation of lake front
property and the seasonal based
businesses such as cottages,
campsites and marinas that are so
significant to the local economy.
This will also reduce the assessed
values of the regions most valuable
properties causing a painful
realignment of tax revenue for the
towns.
Source: Albert Bowers
Two Related comments;
SEQR regulations at Part 617.7 cited in
this comment refer to making a
Comment One This project, when determination of significance prior to
considered cumulatively with the preparation of a DEIS, not to the
other five (5) Jefferson County cumulative analysis. The cumulative
projects, and the public agency analysis prepared for the Hounsfield
announcement by NYPA of an DEIS was conducted to include
additional 1,000 WTG, should be consideration of existing and proposed
considered under the New York wind projects under the control of
State Environmental Quality Review unrelated developers in multiple
Act regulations, Part 617.7.(c)(l)(xii) jurisdictions, and are not related actions
as a whole. Specifically we cite "two undertaken, funded or approved by an
or more related actions undertaken, agency.
funded or approved by an agency,
none of which has or would have a At this time, no details are available
4-19

Hounsfield Wind Farm


Final Environmental Impact Statement

significant
impact
on
the
environment, but when considered
cumulatively would meet one or
more of the criteria in this
subdivision".

regarding any proposals to respond to


the NYPA plan for wind power projects
in the Great Lakes, therefore any
discussion of these would be purely
speculative in the context of this
cumulative review. Any specific
proposals that are developed in response
to this plan would be subject to the
SEQR process, including consideration
of cumulative impacts.

We ask the NYSDEC to complete


the impact analysis to their
satisfaction, as to the cumulative
effects of these multiple projects as
suggested in SEQRA Part 617.7.
Source: Henderson Habor Chamber The cumulative analysis in the
of
Commerce
Economic Hounsfield DEIS included a discussion
Development Committee
of avian/bat impacts and visual impacts.
The avian/bat analysis concluded that
Comment
Two:
The
Draft the risk to Upland Sandpipers is high at
Environmental Impact Statement for Galloo Island (and will result in DEC
the Project does not consider a exerting jurisdiction under Article 11),
thorough analysis of the cumulative but that risk to this species is low at
impacts of all five (5) planned other proposed wind farms and therefore
projects in the affected area. it is not to be considered a cumulative
Amongst other projects, the New impact. Based on post-construction
York Power Authority has publicly study results from the Maple Ridge
announced its intention to construct Wind Farm, potential for cumulative
a massive wind farm in the same impacts likely exists for Red-Tail
region. Although the NYPA plan Hawks and Sharp-shinned Hawks as
was announced prior to completion they migrate throughout the region, and
of the public comment period for the medium impacts are expected to
Hounsfield Wind Power Project EIS Caspian Tern from both the Hounsfield
the document fails to address this Wind Farm and the Cape Vincent
large project proposed by a sister projects, but these impacts are not
state agency. The wind power expected to threaten species viability of
projects currently proposed for the any of these species.
eastern end of Lake Ontario and the
St. Lawrence River will collectively The potential cumulative visual impact
change the face of this important of the build-out of all existing and
region forever. This is particularly formally proposed wind projects in the
true
where
the
associated Lake Ontario/St. Lawrence River region
transmission lines are already (Hounsfield Wind Farm, St. Lawrence
segmented from the project by Windpower, Cape Vincent Wind Farm,
virtue of a legal technicality. The Horse Creek Wind Farm, and Wolfe
failure to address the cumulative Island Wind Farm) would include
impacts of the other large wind approximately 350 utility-scale wind
projects and the transmission lines generating turbines spread throughout
renders the DEIS for the Hounsfield the region, each likely exceeding 390
Wind Power Project an improper feet in height. While not continuously
exercise of selective environmental visible, wind-generating turbines would
4-20

Hounsfield Wind Farm


Final Environmental Impact Statement

review. The spirit and the letter of


SEQR demand that DEC conduct an
honest assessment of these projects
on a cumulative basis.
Source: Peter Price

CDP -37

CDP -38

be a dominant and widespread visual


feature from local roadways, homes and
various places of interest. Turbines
would also be visible on the horizon
from vantage points on Lake Ontario
and the St. Lawrence River along
approximately 50 miles of waterway,
from Clayton west and south to
Southwick Beach State Park in Jefferson
County. At this point only the Wolfe
Island project has been completed, and
DEC has received applications for
permits for one other wind project, the
proposed 53-turbine St. Lawrence
Windpower project in the Town of Cape
Vincent. It should also be noted that
wind turbines on the mainland present a
larger foreground visual impact than
those proposed on Galloo Island;
nonetheless the Galloo Island turbines,
although distant, would represent a
change to the visual setting on the
horizon at vantage points along the Lake
Ontario shore.
Proposals
bringing
cumulative See comments above.
change of this magnitude need to be
considered very carefully in their
entirety before any decisions are
made to proceed with any of the
individual projects. Please extend
and appropriately augment your
review. The residents of the area call
upon the DEC to conduct a proper
review of the cumulative effects of
these proposed actions.
Source: Albert Bowers
Adding further insult, UNYPC's Comment noted. The siting of the
plans for transmission lines do not transmission line is being reviewed in
physically enter or lie within any the Article VII process under the
portion of the mainland of the Town jurisdiction of the New York State
of Hounsfield. Hounsfield will Department of Public Service (DPS),
receive all the financial benefit of which is currently accepting comments
the wind farm, without any on the transmission line proposal.
disruption to the municipality's Information on the DPS review is
infrastructure
or
residents' available on their website at:
properties.
http://documents.dps.state.ny.us/public/
Source: Louise Shim
MatterManagement/CaseMaster.aspx?
4-21

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -39

CDP -40

MatterCaseNo=09-t-0049.
The commenter is referring to a
statement regarding the socioeconomic
impact of the transmission line and
potential uses of eminent domain along
that corridor. This issue is not part of
the DEC permits, nor the SEQR process
as this is an issue related to the Article
VII process under the jurisdiction of the
PSC.

The socioeconomic impact section


of the DElS is highly misleading
when compared to the actual
intentions of the project sponsors. In
discussions of the project and its
associated transmission line the
DElS seems to indicate that the
project will "negotiate" with land
owners when in fact, as the sponsors
have since confirmed, they intend to
utilize the power of eminent domain
to take land from its rightful owners
against their will. The taking of
property against the will of
landowners would be a highly
impactful
event
upon
the
socioeconomic make up of northern
New York.
Source: Peter Price
Two Related Comments:
The Scoping Document and DEIS did
not contain significant details regarding
Comment One: The Scoping study the Transmission Line and associated
offers very little information about alternatives because the transmission
the single 230kV transmission line line is a Types II action under SEQRA
that is now planned to intersect our and governed by the Article VII process.
Town, plus now proposed to handle The Article VII process is under the
two 230kV transmission lines. The jurisdiction of the PSC, and is currently
scoping study also does not offer underway.
any alternatives of consideration of
a subaquatic transmission line more
directly to the NYS Power Grid,
avoiding the intersection and
destruction of historic, agrarian and
recreational use lands in several
townships.
Source: Karl Williams
Comment Two: The Scoping study
gives little information about the
single 230kV transmission line that
planned to cut though the Town of
Henderson, now proposed to handle
TWO 230kV transmission lines.
There are no alternatives presented.
The alternative consideration of a
sub aquatic transmission directly to
4-22

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -41

CDP -42

CDP -43

the NYS Power Grid is not


explored. Doing so would avoid
destruction of historic, agrarian and
recreational use lands all the way to
the Grid.
Source: Heart of Henderson
Our Board and the business
members we represent are opposed
to the project adjoined with Case 09T-0049 and find many sources of
expected negative socio-economic
benefit if the DPS determines public
need of said Case. We also are
opposed to the project based on the
environmental incompatibility when
considering the ecological and
environmental resources that will be
devastated, damaged, or irreversibly
altered.
After review of the published data
associated with this Case, as well as
WTG project DEIS, and data
available from knowledgeable third
party reference sources, we are very
concerned about the negative impact
to our area's delicate economy,
highly dependent on tourism,
recreation and agricultural sectors,
should the subject project proceed.
Source: Henderson Harbor Area
Chamber of Commerce
We implore the DPS to consider
both the WTG project and the
transmission line construction as
one project when determining job
creation, effective use of federal
money and long-term economic
impact to the host area.
Source: Henderson Harbor Area
Chamber of Commerce
Regarding the agricultural and dairy
industry, prevalent in the area, and
essential to the routing of the
proposed Upstate NY Power
Corporation's transmission line, we
have interviewed several farmers, a
4-23

Comment Noted.
Although the
comment was submitted in regards to
the Article VII process, the comments
applicable to the Wind Farm and its
permits are answered below.

As required by SEQRA and State Law,


the review of the Wind Farm and
associated impacts is under the
jurisdiction of the Lead Agency, in this
case DEC. The Article VII process
governing the transmission line is under
DPS jurisdiction.

The routing of the Transmission Line is


being reviewed in the Article VII
process under the jurisdiction of the
DPS.

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -44

few of which are candidates for the


routing of the transmission line.
Overwhelmingly, their feelings to
this project are very negative and
considered a personal attack on their
freedoms, as a small family owned
business owner. They cite disruption
to their crops and livestock as highly
probable outcomes, both of which
may force several of these
businesses to the brink of extinction.
We
understand
from
these
interviews that the small subsidy
they would receive for either lump
sum settlement or lease payments
would be outstripped several fold by
loss of revenue due to decreased
milk production.
Source: Henderson Harbor Area
Chamber of Commerce
The project as proposed is
inconsistent with the petroleum and
spill hazards presented in the DEIS.
It is my understanding that each
wind turbine may contain up to 320
gallons of a petroleum lubricant that
is highly toxic to aquatic
environments. The grouping of these
petroleum storage devices in one
small area surrounded by a sensitive
aquatic habitat should, at a
minimum, require permitting under
the
DECs
petroleum
and/or
chemical bulk storage regulations.
On this basis alone, the project must
be denied a permit outright. If any
other business owner were to
propose locating over 100 hundred
300+
gallon
storage
petroleum/chemical
storage
containers on Galloo Island it is
inarguable that the DEC would deny
them the right to do so. There does
not appear to be an exemption for
wind turbines in the petroleum or
chemical bulk storage regulations
and yet the DElS ignores the issue
4-24

The DEIS contained a Conceptual Spill


Prevention,
control
and
Countermeasures
Plan
(SPCC).
Attached as Appendix B to this FEIS is
a SPCC that was revised to account for
comments submitted on the conceptual
plan by DEC. Both the DEIS and FEIS
acknowledge that a Bulk Petroleum
Storage Registration will be required
prior to the storage of any petroleum
products on Galloo Island.
By Federal law, once in operation the
facility must prepare, execute and
periodically update a SPCC plan. The
purpose of the plan is specifically to
prevent accidental release of oil into the
waters of the United States.

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -45

CDP -46

and no permits have been required.


Source: Peter Price
As a summer resident of Henderson
Harbor, I wholeheartedly agree with
Robert Ashodian, whom you have
recently heard from. Please don't let
the momentum associated with
"green energy" (the political
correctness du jour) move the
Galloo Island wind project ahead
before the very real concerns raised
by Mr. Ashodian have been
examined thoroughly by both the
public and the DEC.
Source: Charles Clarkson
The unintended consequences of
supporting wind farms as a source of
alternative energy are many and will
be extremely costly to Association
Island, to the region's homeowners,
to the region's tourism-related
businesses, and to the local, county,
and state taxing authorities. Not
withstanding
the
fact
that
Association
lsland
generally
supports the development of
alternative clean energy to reduce
our country's reliance on fossil fuels,
Association Island overridingly
advocates that the development of
alternative energy must not come at
the expense of an existing and
critically important natural resource,
at the expense of obstructing our
existing
telecommunications
systems, nor at the expense of the
quality of life in and tourism to New
York State's 1000 lslands Region. In
closing, please stop UNYPC's
development of the Hounsfield
Wind Farm at Galloo Island. The
regulators and public officials who
have the power to approve or deny
the wind farm can afford to force
prospective developers to pursue
alternative forms of energy in
alternative locations, but we can not
4-25

Comment noted.

Impacts are minimal from this site as


documented in the DEIS/FEIS, due in
part to its location.
Nevertheless,
simply shifting the remaining impacts to
another community is not mitigation.
See responses to comments CDP-24 and
CDP-30.

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -47

CDP -48

CDP -49

afford to lose this critical and


irreplaceable natural resource of our
beautiful waterfront viewshed here
on the eastern shores of Lake
Ontario.
Source: Louise Shim
Building wind farms to replace the
country's reliance on fossil fuels and
foreign oil should not come at the
expense of sacrificing an existing
natural resource and harming a
region's business activity and
livelihood. There are many forms of
alternative energy and you can build
a wind farm in many alternative
locations, but you will never again
be able to build such a beautiful
waterfront viewshed as we currently
have here in the waters of eastern
Lake Ontario, and particularly in the
Henderson Harbor and Golden
Crescent area. As a public service to
our community and the whole
region, we ask the Public Service
Corporation (PSC), the New York
State Department of Environmental
Conservation (NYS DEC) and the
many other local, county, state and
federal regulators and public
officials to deny the request of
UNYPC, or any developer, to build
a wind farm an Galloo Island, or an
any other property, in the waters of
eastern Lake Ontario.
Source: Louise Shim
This project will have a major
impact on businesses, personal
property values and a way of life on
the eastern end of the lake and many
of us are just now becoming
informed about it. There are still
many, many unanswered questions.
Source: Jay Wason
I must express strong opposition to a
current proposal to erect wind
turbine structures in the eastern
region of Lake Ontario, especially
4-26

Comment Noted.

Comment noted.

Comment noted.
A visual assessment was conducted for
this project, with additional visual

Hounsfield Wind Farm


Final Environmental Impact Statement

on Galloo Island or elsewhere in the


Towns
of
Hounsfield
and
Henderson. Not only do these
devices pose an ugly intrusion on
the natural beauty of the region, they
inevitably will bring substantial
decreases in local property values
and result in other negative
economic impacts. The area's
recreational fishing attractions and
its renown tourism industry --based
on its historic importance in the War
of 1812 -- and the popular Seaway
Trail are certain to suffer from the
intrusion of such ungainly structures
slashing the skyline.

CDP -50

CDP -51

simulations provided in the FEIS. While


the proposed project would result in a
change in visual setting on the horizon
from vantage points along the Lake
Ontario shore, the distance of this
project to most on-shore observers is
such that the change will be small to
modest, particularly during daytime
hours, with some noticeable change at
night because of FAA-required lighting.
Additionally, to offset this change in
visual setting at inventoried visual
resources, such as state parks and
historic resources, enhancements at
these settings have been proposed by
local and state agencies that can serve to
mitigate impacts related to the change in
Your agency must heed its visual setting. In particular, see response
environmental obligation to protect to comments 2.6-18 and 2.7-8.
and preserve this unique "Golden
Crescent" of Lake Ontario. The
DEC must altogether reject this
offensive scheme.
Source: James Cosgrove
I am concerned about the impact this Comment noted. Environmental issues
project will have on environmental were thoroughly evaluated as part of the
issues, agricultural use of land, DEIS; the wind farm will not impact any
property valuation, and tourism. agricultural use other than that on
This project will benefit the Town of Galloo Island; there is no factual
Hounsfield financially, without evidence to support the concern that
impacting their farm land, their tourism will be impacted by the
property
values,
or
their windfarm. Studies evaluated in the
infrastructure. It will impact all DEIS did not demonstrate this as a
those areas, excepting, financial likely outcome. The concerns regarding
gain, within the Town of Henderson. property values and infrastructure are
This does not seem fair or unclear.
reasonable, and therefore I believe
more time is needed to assess the The DEC does not have any input on
costs to Henderson, both financial where project benefits will be obtained
and otherwise, before a decision is from the construction of the wind farm.
reached.
Source: Mary Hoffman
The DElS does not include an The commenter does not indicate what
assessment of the impacts upon would be impacts to the local people.
local people who have lived in the See response to comment CDP -49.
same view shed for generation upon
generation, and which will now be
4-27

Hounsfield Wind Farm


Final Environmental Impact Statement

CDP -52

changed forever without even a


cursory
discussion
of
those
socioeconomic impacts by the New
York DEC.
Source: Peter Price
Two Identical Comments:
Comment noted.

CDP -53

The project if it goes forward will


have a profound effect on everyone
that makes the eastern end of Lake
Ontario their home, an area referred
to for decades as the Golden
Crescent because of the beauty and
uniqueness of the area
Source: Robert Ashodian
Source: Albert Bowers
Two Identical Comments:
Comment noted.

CDP -54

CDP -55

The potential implications were not


recognized until very late in the
approval process, only recently has
there been any community reaction
and only recently have the citizens
of these communities begun to push
back.
Source: Robert Ashodian
Source: Albert Bowers
I am thoroughly against the wind Comment Noted.
mill
project
that
you
are
encouraging to be done. I am a
sailor and spend summers on the
beautiful waters of Lake Ontario. I
would greatly appreciate you
looking into this matter more
carefully and do what is best for the
residents and travelers in that area. I
would hate to see you ruin such a
wonderful, peaceful area.
Source: Maureen Johnson
Two Related Comments
See response to CDP-37.
Comment One: As I and others
around me have learned more about
this situation, we are appalled at the
prospect that turning Galloo Island
into an industrial complex for wind
generation, regardless of so called
4-28

Hounsfield Wind Farm


Final Environmental Impact Statement

mitigating actions, will virtually


destroy the ecology of Galloo Island
and can't help but have a negative
impact on other nearby islands.
Source: Robert Ashodian

CDP -56

Comment Two: As I and others in


the area have learned more about
this developing situation, we are
appalled at the prospect of turning
eastern Lake Ontario and Galloo
Island, as well as many of our towns
into an industrial complex for wind
generation. Regardless of any so
called mitigating actions, the
combined effect of these proposed
projects, on top of the already
accomplished destruction on Wolfe
Island, will seriously and negatively
impact our local economy as well as
the ecology and natural beauty of
Eastern Lake Ontario and Galloo
Island.
Source: Albert Bowers
Two Related Comments
The public comment period for the
Hounsfield
Wind
Farm
Permit
Comment One: We are a very small, applications closed December 4, 2009.
struggling
community, These comments do not reference issues
overwhelmed with the immediate discussed in the application or provide a
need to assess and provide substantive reason to extend the
appropriate input to you regarding comment period on these applications .
the very large, complex Hounsfield
Wind Power Project. Only very Reference to Interested Party Status is
recently was the Town of Henderson related to the Article VII process which
named an interested party; to be is under the jurisdiction of the New
involved in the project processes.
York State Department of Public
Source: Karl R. Williams
Service (DPS). These and other similar
comments requesting extension of the
Comment Two: As a small SEQR and DEC Permit Application
community only recently having comment periods appear to have
become an interested party in the resulted from initial hearings conducted
Hounsfield Wind Power Project, we by DPS in reference to the proposed
find ourselves in the unenviable transmission line associated with the
position of having to analyze a very action. While DEC recognizes that
large and complex amount of data. ultimately the proposed project will
Since we are so newly an interested include both a generation project and a
party due to circumstances beyond transmission project, state law requires
4-29

Hounsfield Wind Farm


Final Environmental Impact Statement

our control, we are asking to have


time to review all pertinent
information.
Source: Heart of Henderson

CDP -57

Multiple Related comments


Please urge extension of the public
comment time for the wind
generator project.
Source: Steve & Julie Dixon
Please extend the public comment
period for the projects in Eastern
Lake Ontario area (Town of
Houndsfield, Jefferson County, etc.)
that involve wind turbines and
power transmission lines.
Source: Karen West
Please extend the public comment
period on the Hounsfield Wind
Farm Project (Galoo Island) By six
(6) months. We are not registered as
interested parties but, we do have an
interest in this huge project that has
come to our attention only within
the last few weeks. We have
suddenly realized that this massive
project is well along in the approval
process and it will have an
enormous negative effect on us
personally, as well as the ecology,
4-30

that the transmission project associated


with the generation project be reviewed
and approved by DPS, not DEC. As
stated above (in response to CDP -2),
DEC has conducted an open SEQR
process that has run for nearly two
years,
provided
timeframes
for
comments that have exceeded minimum
requirements, and provided ample
notification sufficient to inform the
general public about the process.
The public process for the Article VII
process covering the transmission line is
ongoing, and DPS, like DEC, is
providing extensive opportunity for
public comment as that agency
considers routing of the proposed
transmission line.
The public comment period for the
Hounsfield Wind Farm DEIS closed on
May 31, 2009. The DEIS comment
period was extended to 90 days to
facilitate
public
participation.
Following the Notice of Complete
Application for DEC permits associated
with construction of the Galloo Island
wind generation facility, a 30-day public
comment period was initiated on
November 4, 2009 and closed December
4, 2009. In order for DEC to consider
an extension of this comment period,
comments received during this time
would have had to raise substantive
issues that were not previously
considered in either the DEIS or
application documents. None of the
comments received addressed specifics
of the applications under review. Those
comments that addressed issues
previously considered in the DEIS have
been responded to above. Comments
related to the proposed transmission line
are not part of this review process, and
are appropriate for review by DPS as
part of the Article VII process, which is
ongoing.

Hounsfield Wind Farm


Final Environmental Impact Statement

the economy and the history of this


region.
Source: David G. and Polly P.
Brown
I've just started to review the
documents on line and it will be a
time consuming event to thoroughly
review them all in detail. Please
consider this request to extend the
review period so I can have more
time to review and to allow
concerned citizens to notify
stakeholders of the impending
development.
Source: Donald Peters
The Henderson Harbor Area
Chamber of Commerces (HHACC)
Economic Development Committee
is writing this letter to you to request
a six-month extension to the
comment period, extending the
deadline from the current December
4, 2009 to the requested June 4,
2010.
Source: Karl R. Williams
I encourage you to grant an
extension for the comment period on
the Galloo Island Wind Farm
Project. For whatever reason the
activity associated with this was
initially very poorly publicized thus
limiting
the
opportunity
for
interested parties to provide
comments. The impact of this initial
project and the proposed expansion
of it will have a significant short and
long term impact on the economy of
the area and therefore all impacted
parties should have the opportunity
to be heard.
Source: W. J. Arnold
I strongly urge the DEC to extend
the public comment period for an
4-31

Hounsfield Wind Farm


Final Environmental Impact Statement

additional 6 months and take a


strong stance against this project.
The Eastern basin of Lake Ontario is
a wonderful Natural resource- let's
not destroy it.
Source: Rich Mangan
The purpose of this letter is to
request an extension to allow public
comment on the Hounsfield Wind
Farm Project.
Source: Mary Hoffman
I am writing to request and
extension on the public comment
period for the Hounsfield Wind
Farm project on Galloo Island.
As a summer resident, I am opposed
to this project and hope that we can
somehow stop it from happening. A
wind farm would detract from the
beauty of the area as well as effect
our property values on the lake.
Source: Janet Salovitch
I am writing to request the DEC
extend by 6 months the public
comment period for the Hounsfield
Wind Farm Project (Galloo Island).
Source: Donald Brandt
I accordingly urge you to extend for
six months the scheduled public
hearings for comments on the
matter.
Source: James Cosgrove
I urge you to grant a 6 month
extension to the public comment
period for the Galloo Island wind
turbine project. This project will
change the future of the eastern end
of Lake Ontario, affecting the
livelihood of the region. It is
imperative that the public is given
enough time to discuss the
implications of the project. Please
4-32

Hounsfield Wind Farm


Final Environmental Impact Statement

extend the public comment period!


Source: Sara Wason
As a summer boating resident of
Henderson Harbor, NY for the past
28 years I request that you extend
the Public Comment Period
regarding the project for six months.
Source: Lee Cagwin
Please extend the public comment
period to allow local residents to
research the impact.
Source: David Poulin
I strongly urge you to extend the
public comment period for the
Galloo Island wind power project to
allow more people to express their
views on this enormous project.
Source: Robert Gamble
I am writing to respectfully request
that the time for comment to the
DEC on this project be extended for
at least 6 months to provide a fairer
opportunity for every concerned
person to more fully study the
implications of the proposal and
make their informed comments
known to the DEC before an
irrevocable decision is made.
Source: Dennis and Gail Baldwin
I am writing to request an extension
to allow additional public comment
on the Hounsfield Wind Farm
Project (Galloo Island). I believe a
six (6) month extension would be
appropriate.
Source: Jay Wason
As chairman of the Henderson
Harbor Citizen's Committee to
Review "wind laws" I politely
request that you extend the time to
"the public comment period" r.e. the
4-33

Hounsfield Wind Farm


Final Environmental Impact Statement

Galloo Island Project. This project is


altered almost daily by the
developer. We desperately need the
time to study same.
Source: Alex James
Please agree to a 6 month extension
to the Galloo Island Wind Farm
Project. The importance of this
project deems it necessary to extend
time for public comment.
Source: James & Barbara Webe
I am writing you to request that the
DEC give a six month extension to
allow additional public comment
before developers alter the scenic
landscape of eastern Lake Ontario
forever.
Thank you for considering the
responsible action of providing at
least a 6 month extension for further
consideration of this very complex,
and also devisive and controversial
issue, that will not only affect
energy, but will also affect the
future of this beautiful area that we
are so fortunate to enjoy and
appreciate.
Source: Melanie Chapman
I'm requesting a six week extension
on the public comment forum.
Source: Kristin King
We need more time to connect with
the DEC and the PSC to adequately
state our concerns. We implore the
DEC to give us the time we need to
adequately prepare our concerns.
We fear without that time, our
community will be devastated by the
Hounsfield Wind Power project.
Source: Heart of Henderson
The
Heart
of
Henderson
organization is writing this letter to
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Final Environmental Impact Statement

request a six-month extension to the


comment period, extending the
deadline from the current December
4,2009 to the requested June 4,2010.
Source: Heart of Henderson
I urge you to extend the public
comment period for the Galloo
Island Wind Farm by six months.
This project is inextricably tied to
the transmission line southward, and
as you know, the developer is not
required to notify property owners
that they are affected. Many are just
now discovering what is happening,
and should have an opportunity to
be heard. The public hearing for the
transmission line, conducted by the
Public Service Commission on
November 16, 2009, alerted many
stakeholders for the very first time.
Source: John Irwin
Two identical comments:
Please extend the public comment
period on the Hounsfield Wind
Farm Project (Galloo Island) by six
(6) months. I am not registered as an
interested party, but I surely have an
interest in this massive project that
has come to my attention only
within the last few weeks. Like
many others in this community, I
have suddenly realized this project
is well along in the approval process
and will have an enormous impact
on me personally, and the ecology,
history and economy of this region.
Our most significant natural
resource, the very reason I live here,
is at stake.
The reasons why we were not fully
aware that this project was so far
along in the approval process are
many. Regardless of that issue, a
thirty (30) day public comment
period is simply not sufficient for
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Final Environmental Impact Statement

me or my community to evaluate the


impact. I urge the DEC to extend the
public comment period which is
scheduled to end on
December 4,2009, by six months, to
June of 2010.
Source: Barbara James and John &
Beverly Rowe
My wife and I are vehemently
against wind turbines being placed
on Galloo Island since it will cause
more problems for Henderson
residents than for those of the town
of Hounsfield. Our view both from
the water as well as from land will
be destroyed by the size and number
of the turbines which also will cause
property values, tourism, and quality
of life to decline.
REQUEST THAT THE PUBLIC
COMMENT
PERIOD
BE
INCREASED SIX MONTHS to
insure a rational and well thought
out decision is made.
Source: Hilton Bicknell
I request that the DEC extend the
public comment period on the
Galloo Island project. At first
glance, we have significant concerns
regarding what I perceive as the
"industrialization" of the area.
Without doubt, the project will have
significant negative effects on the
area and its residents and visitors.
The question in my mind is if the
benefits outweigh these negative
effects. For that reason, and
knowing that many others are just
now becoming aware of the
significance of the project, we ask
that the public comment period be
extended so that we can become
more knowledgeable and offer more
informed comments.
Source: James & Christine Farrell
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Hounsfield Wind Farm


Final Environmental Impact Statement

I am requesting an extension of the


decision on the Galloo Island wind
farm power project for 6 months.
There are answers to questions such
as economic and environmental
impacts which have yet to be fully
explored.
Source: Charles Mackey

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Final Environmental Impact Statement

5.0 References
New York Independent System Operator, Alternate Route: Electrifying the
Transportation Sector, June 2009.
New York Governor David Patterson, Executive Order No. 24: Establishing a Goal to
Reduce Greenhouse Gas Emissions Eighty Percent by the Year 2050 and Preparing a
Climate Change Action Plan, August 2009.
New York State Department of Public Service, The Renewable Portfolio Standard: Mid
Course Report, October 2009.
New York State Energy Planning Board, 2009 State Energy Plan Draft, August 2009.

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