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FINAL ENVIRONMENTAL IMPACT STATEMENT

PROPOSED ST. LAWRENCE WINDPOWER PROJECT


TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

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

1.1 State Environmental Quality Review Process


SLW submitted a Full Environmental Assessment Form (EAF) to the Town of Cape Vincent
Planning Board, the Lead Agency, on November 8, 2006, which initiated the SEQRA process for
the proposed action. The DEIS was submitted to the Town of Cape Vincent Planning Board on
January 10, 2007, which was accepted as complete by the Lead Agency on January 24, 2007.
The Lead Agency filed a Notice of Acceptance of the DEIS and Notice of Public Hearing on
February 7, 2007. Copies of the DEIS were distributed to all interested and involved agencies
and made available to the public at the Town of Cape Vincent Town Clerk’s Office, the Public
Library, and SLW’s local office in Cape Vincent, NY. SLW also posted the entire DEIS on the
Project’s website (www.stlawrencewind.com). On March 24, 2007, the Town of Cape Vincent
Planning Board held a public hearing on the DEIS at the Cape Vincent Recreation Center on
South James Street. The public comment period ended on June 15, 2007.

After the public comment period on the DEIS, the Town of Cape Vincent Planning Board
requested preparation of a SDEIS. The SDEIS was submitted to the Lead Agency on January 14,
2009 and accepted on March 25, 2009. The Lead Agency filed a Notice of Acceptance of the
SDEIS and Notice of Public Hearing on April 4, 2009. A public hearing on the SDEIS were held

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

on May 16, 2009 at Recreation Park, Cape Vincent. The public comment period on the SDEIS
ended on May 30, 2009.

This FEIS has been prepared to comply with the requirements of SEQRA (6 NYCRR 617). The
purpose of the FEIS is to incorporate information pertaining to the proposed Project’s design and
likely impacts that was made available subsequent to the issuance of the SDEIS. This additional
information is provided in Section 2.0 below. Section 3.0 of this FEIS contains a summarized
list of all comments received. Comments in their entirety are provided in Appendices D (public
meeting transcripts) and E (written comments). A Response Summary was also prepared as part
of this FEIS to address all substantive oral and written comments received on the SDEIS and
DEIS and is provided in Section 4.0. It contains responses to the comments and questions posed
at public hearings and/or received in writing during all public comment periods for the Project.

Additional studies and plans have been prepared in support of the Project. They provide detailed
information on specific issues associated with the Project and were prepared to assist in the
SEQRA evaluation. They include the following:
x Supplemental Wetland Delineation Report, St. Lawrence Windpower, LLC, St. Lawrence
Wind Farm, Towns of Cape Vincent & Lyme, Jefferson County, New York
x 2009 Pre-Construction Grassland and Sensitive Bird Species Study
x Biological Assessment
x Final Shadow Flicker Analysis
x Final Noise Modeling Assessment
x Final Off-Air TV Station Assessment
x Transportation Route Evaluation Study
x Transmission Line Engineering Study Scope
x Draft Wildlife Protection Plan (WPP)
x Residential Well Study and Mitigation Plan
x Storm Water Pollution Prevention Plan (SWPPP)
x Spill Prevention, Control, and Countermeasure (SPCC) Plan
x Unanticipated Discoveries Plan
x FAA Final Lighting Plan
x Revised Complaint Resolution Plan
x Draft Outline of Construction Environmental Monitoring Plan

The final steps in the SEQRA process for the Saint Lawrence Windpower Project will include
the following:

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

x FEIS acceptance by the Cape Vincent Planning Board


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

1.2 List of Required Permits and Approvals


Development of the proposed Project will require the following permits and/or approvals from
local, state, and federal agencies:

Table 1-1 (Sheet 1 of 2)


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

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 1-1 (Sheet 2 of 2)


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

NYSOPRHP (SHPO) Cultural Resources Consultation.

FAA Notice of Construction and Aviation Lighting Plan.


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

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

2.0 PROJECT MODIFICATIONS AND SUPPLEMENTAL INFORMATION


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

2.1 Revised Project Layout/Details


The revised Project layout, shown in Figures 1 and 2, includes 51 turbines, approximately 16.5
miles of temporary access roads, 14.7 miles of permanent access roads, 36 miles of buried cable
and an Operations and Maintenance Exhibit 2.1.1 – Example of Acciona-built O&M
(O&M) Building. An example of a Building at EcoGrove Wind Farm, IL
potential design for the O&M building is
illustrated in Exhibit 2.1.1. A maximum
of five meteorological towers will also be
installed during the construction and
operations phases of the Project to
monitor wind resources. They will be
supported by three to four guy wires and
rest on concrete footings. SLW will add
bird deflectors to the supporting guy
wires to increase visibility to avian
species. Placement of these deflectors is
shown in blue in Exhibit 2.1.2.

The proposed Project includes relatively minor modifications to the layout presented/described
in the SDEIS. These modifications include elimination of two wind turbine generators (WTGs),
selection of the alternate location for one WTG, revised locations for most WTGs, and relocation
of associated roads and underground interconnects. In addition, the rotor diameter for WTG 28
was reduced to 77 meters to accommodate turbulence interference. Most proposed locations for
WTGs in the revised Project layout were only shifted about 100 feet from the locations
previously provided in the SDEIS. Although substitution of one WTG for the alternate WTG
location resulted in a 2.9 mile change from its original location.

Specific changes were made to minimize impacts associated with noise, agriculture, wetlands,
New York State Department of Environmental Conservation (NYSDEC) Wetland Adjacent
Areas, or sensitive species including:
x Elimination of WTG 11 to reduce noise impacts below reasonable thresholds;

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

x Elimination of WTG 38 in response to a


Exhibit 2.1.2 – Met Tower Bird Deflector
Placement NYSDEC request to move turbines
outside of a state endangered species
habitat area.
x Relocation of WTG 3, 14, 16, 17, 24,
25, 37, 39, 40 and 41 to address wind
turbulence.
x Rerouting of cables connecting WTG 23
to 26 to avoid wetlands.
x Rerouting of cables connecting Turbines
26 and 28 to reduce wetland impacts.
x Modification of cable routes and access
roads associated with WTGs 14, 24, 25,
32, 39, 40, 41, 47, and 53 to
accommodate turbine relocations or
eliminations.
x Relocation of access roads to WTGs 32,
48, 50, 51, and 52 to reduce wetland and
agriculture impacts.
x Relocation of work pad for WTG 28 to
reduce wetland adjacent area impacts.

The revised Project layout complies with, or exceeds, the following Planning Board of Cape
Vincent’s setback criteria stipulated in their June 11, 2007 letter to SLW (See Figure 3):
x 1,500 feet from the Village of Cape Vincent boundary line;
x 1,000 feet to a non-participating property line;
x 1,250 feet to a non-participating residence; and
x 750 feet to a participating residence.

2.2 Environmental Setting, Impact Analysis and Mitigation Measures


2.2.1 Water Resources
2.2.1.1 Supplemental Existing Conditions Information
Groundwater
SLW conducted a pre-construction survey of residential wells. This survey involved
determining the location of groundwater wells within 500 feet of the proposed wind turbine
locations. A total of 22 wells have been documented within the study radii. SLW will conduct

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

x Elimination of WTG 38 in response to a


Exhibit 2.1.2 – Met Tower Bird Deflector
Placement NYSDEC request to move turbines
outside of a state endangered species
habitat area.
x Relocation of WTG 3, 14, 16, 17, 24,
25, 37, 39, 40 and 41 to address wind
turbulence.
x Rerouting of cables connecting WTG 23
to 26 to avoid wetlands.
x Rerouting of cables connecting Turbines
26 and 28 to reduce wetland impacts.
x Modification of cable routes and access
roads associated with WTGs 14, 24, 25,
32, 39, 40, 41, 47, and 53 to
accommodate turbine relocations or
eliminations.
x Relocation of access roads to WTGs 32,
48, 50, 51, and 52 to reduce wetland and
agriculture impacts.
x Relocation of work pad for WTG 28 to
reduce wetland adjacent area impacts.

The revised Project layout complies with, or exceeds, the following Planning Board of Cape
Vincent’s setback criteria stipulated in their June 11, 2007 letter to SLW (See Figure 3):
x 1,500 feet from the Village of Cape Vincent boundary line;
x 1,000 feet to a non-participating property line;
x 1,250 feet to a non-participating residence; and
x 750 feet to a participating residence.

2.2 Environmental Setting, Impact Analysis and Mitigation Measures


2.2.1 Water Resources
2.2.1.1 Supplemental Existing Conditions Information
Groundwater
SLW conducted a pre-construction survey of residential wells. This survey involved
determining the location of groundwater wells within 500 feet of the proposed wind turbine
locations. A total of 22 wells have been documented within the study radii. SLW will conduct

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

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

Surface Waters and Wetlands


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

2.2.1.2 Revised Impact Analysis


Groundwater
Construction activities can generate ground-transmitted vibration forces that may result in
ground disturbance and potentially affect existing groundwater features proximal to the activity.
These generated vibrations attenuate over distance from the source. The magnitude of the
vibration and the attenuation rate are related to the construction method used for excavation (e.g.,
mechanical, blasting), type of construction equipment (e.g., hydraulic excavators, front end
loaders), and conductivity of the surface and subsurface substrates (e.g., sands, clays, frozen
soils, bedrock). In determining the distance from turbines for pre-construction surveys of private
water supply wells, it was assumed that standard excavation equipment would be used and no
blasting would be required. Using such equipment and techniques vibration effects typically are
below levels of perception at distances of 500 feet from the source (Amick and Gendreau, 2000).
Even considering the use of controlled blasting, construction vibrations would be well below the
threshold for residential damage at a distance of 500 feet from the blasting activity. However,
since site-specific geologic and hydrogeologic investigation has not been performed in the
Project Area, the radius to be used for the pre- and post-construction well survey will be
established based upon the results of the site-specific surveys and the final choice of construction
method for each foundation. The radius to be used for those surveys may be adjusted either
nearer or further from the source.

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Surface Waters and Wetlands


Based on modifications to the Project layout there is a slight decrease in overall temporary and
permanent wetland impacts as compared to the layout evaluated in the SDEIS. Permanent
filled/excavated wetlands amount to 13,816.3 square feet (0.32 acre) while temporary
filled/excavated wetlands amount 49,637.7 square feet (1.14 acres). This represents a total
reduction of 23,666 square feet (0.54 acre) of fill/excavation impacts to wetlands, 558.5 square
feet (0.01 acre) of which are permanent impacts and 23.107.5 square feet (0.53 acre) of which
are temporary impacts, since the submission of the SDEIS.

2.2.1.3 Supplemental Mitigation Measures


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

Surface Waters and Wetlands


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

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

and overflowing of Kent’s Creek. The


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

2.2.2 Ecological Resources


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

Threatened and Endangered Species


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

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

and overflowing of Kent’s Creek. The


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

2.2.2 Ecological Resources


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

Threatened and Endangered Species


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

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 2-1
1
Approximate Area of Vegetation Disturbance

Sub-Station/ Collector Construction


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

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Nationwide Permit authorization for facilities of the proposed Project to cross waters of the U.S.
The BA is provided in Appendix C-3.

Grassland Birds – An additional summer breeding bird survey was conducted during 2009 in
the proposed Project Area to determine the presence, absence, and site use by rare, threatened or
endangered (RTE) bird species. Target RTE species were either state-listed threatened species or
state species of Special Concern in New York associated with grassland habitats. Survey
locations were selected to maximize the detection of target RTE species through selection of
sampling points within the best available habitat present within and adjacent to the Project Area.

The study provided data for describing the temporal and spatial use by sensitive bird species
primarily affiliated with grassland communities in the Project Area. The survey protocol was
based on the NYSDEC Region 6 Grassland Bird Survey Protocol and survey points were
established in consultation with NYSDEC Region 6 biologists. A copy of the report for this
survey is provided in Appendix C-2.

Henslow’s sparrow was detected during the surveys, including four individuals in three groups
during the point count surveys and one individual during time spent on site by the observer.
Vesper sparrow and upland sandpiper were also observed infrequently during both point counts
and incidentally. Sedge wren was not observed. These results, coupled with those from
previous pre-construction survey efforts (Kerns et al 2007), suggest these species are rare within
the Project area. However, northern harrier and grasshopper sparrow were observed with
relative frequency.

2.2.2.2 Revised Impact Analysis


Vegetation
The revised Project layout will result in impacts to 162.44 acres of grassland/pasture/hay (29.87
acres permanently, 132.57 temporarily), 81.68 acres of agricultural row crop cover (10.29 acres
permanently, 71.39 temporarily), 5.63 acres of upland forested cover (0.72 acres permanently,
4.91 acres temporarily), and 4.0 acres of upland scrub-shrub cover (0.63 acres permanently, 3.37
temporarily. In addition, the US Geological Survey National Land Cover Data indicate impacts
to 1.34 acres of forested wetland (0.19 acres permanently, 1.15 acre temporarily), while results
of field delineation of wetlands indicated that 1.46 acres of forested, scrub-shrub, and emergent
wetlands will be affected (0.32 acres permanently, 1.14 acre temporarily). These impacts are
summarized in Table 2-1

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Threatened and Endangered Species


Indiana Bat – The SLW Project will result in the loss of some Indiana bat habitat
(approximately 2.5 acres) but this loss is not expected to lead to harassment or harm of Indiana
bats to an extent that would meet the definition of “take” of the Indiana bat. In addition, Indiana
bat habitat impacts will be minimized and avoided by cutting trees when Indiana bats would not
be present on site. Loss of habitat impacts from the SLW Project will not lead to take of
individual Indiana bats and this potential impact is not likely to adversely affect Indiana bats.

Operation of the project could potentially lead to direct mortality of Indiana bats if they were to
collide with a turbine blade or die from barotrauma. Using the best available information and a
suite of assumptions, SLW estimates that the Project could lead to the death of between 0 and 3
Indiana bats per year. If the threshold of zero is passed, this impact will meet the definition of
“take.” SLW will conduct a rigorous monitoring program to determine mortality and assess its
causes; implement a number of conservation and mitigation measures to offset or compensate for
any take; and adaptively manage the biological outcome to ensure a “net-benefit” impact on the
Indiana bat. Consequently, the Project is not likely to jeopardize the continued existence of the
Indiana bat. The estimated impacts to Indiana bats, proposed mitigation and avoidance
measures, and an assessment of the impacts of the Project on the species are set forth in the BA.
See Appendix C-3.

Grassland Birds – Construction and operation of the Project could potentially affect grassland
species including short eared owl, northern harrier, upland sandpiper and Henslow’s sparrow.
The revised Project layout incorporates a number of NYSDEC recommended changes to avoid
and minimize some of the impacts on these species (specifically Short-eared owl); however, the
measures to avoid and minimize impact are not anticipated to prevent all take of state-listed
endangered/threatened species. Construction of the Project will result in the direct take of 29.87
acres grassland that is permanently converted to roads and turbine pads. In addition, temporary
disturbance to 132.57 acres will result in “disturbance-related" impacts such as fragmentation
and displacement. To address the potential incidental take of these species, SLW has applied for
an incidental take permit under Article 11 of the N.Y. Environmental Conservation Law.

2.2.2.3 Supplemental Mitigation Measures


Vegetation
Vegetation impacts will be mitigated through preservation of forested habitat and grassland
habitat as described in the following section for Threatened and Endangered Species.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Threatened and Endangered Species


Indiana Bat – Conservation measures have been proposed to address the impacts to Indiana
bats. These measures include the following:
x The Project was redesigned to minimize impacts to potential Indiana bat habitat including
deciduous forest and wetlands to the maximum extent possible. The current design would
result in approximately 2.5 acres of deciduous forest impact. No turbines will be located
in forested habitat. Impacts to forests will arise only from access roads and the
transmission line. No known roost trees will be cut for the Project. In addition, impacts
to wetlands will be minor, arising only from crossing of waters with roads and collector
lines. The SLW Project design also will minimize risk to Indiana bat roosting areas
because all turbines will be located approximately ½ mile or more from identified roost
trees.
x SLW proposes to include a conservation easement to protect known Indiana bat habitat as
part of the Project. A block of forest in the Project area will be maintained for the life of
the SLW project through a conservation easement with the land owner to insure that there
are no future impacts to the forest habitat. The conservation easement would include
roughly 56 acres. The conservation easement would insure that the site is excluded from
further development pressure or tree cutting for the life of the wind project.
x To avoid potential take of roosting Indiana bats, all tree clearing will occur between
October 1 and April 15 when Indiana bats are not expected to be within their
spring/summer range or on site.
x To minimize potential harm or harassment impacts, night time construction will be
minimized and lighting will be restricted to safety lighting required around hazardous
equipment or materials as required by law.
x Development of an adaptive management plan to avoid take of Indiana bats. The primary
objectives to meet this goal are to: 1) determine the level of Indiana bat mortality and
identify the circumstances and conditions under which fatalities of Indiana bats occur;
and 2) develop a set of project management actions (alternatives) that when implemented
provide effective means by which the impacts can be reduced, offset, or eliminated, thus
avoiding/minimizing potential impacts.
x SLW will also engage in monitoring as part of the adaptive management program and as
required by the federal and state agencies. Pursuant to the adaptive management program
SLW will engage in a minimum 3-year monitoring program to determine the level of
impact and circumstances under which impacts to Indiana bats occur from the SLW
project. As part of compliance monitoring, SLW will monitor for a designated period
required as a condition of the USACE permit.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

x As part of the overall monitoring study, SLW will implement research projects designed
to provide information related to risk of the wind project to Indiana bats in the Cape
Vincent region. These projects will include banding and radio-tracking study of late
summer/early-fall Indiana bats to determine dispersal patterns and behavior in relation to
known winter hibernacula and to determine if there are any additional hibernacula in the
region, and a banding study of little brown bats to determine impacts to summer resident
bats.
x Acciona Energy, the parent company of SLW, has provided funds to the Emergency
White Nose Syndrome Fund. In addition, SLW will provide continued funding to on-
going research on white nose syndrome geared toward determining causes and corrective
actions to offset the high levels of mortality, with the overall objective of species
conservation.
x Acciona Energy is also a contributing member to the Bat-Wind Energy Cooperative
(BWEC) to fund studies on monitoring impacts from wind turbines and investigate
mitigation strategies such as adjusting turbine cut-in speed and bat deterrent methods.
Acciona will continue to contribute to BWEC on an annual basis for five years, unless the
cooperative is disbanded prior to five years.

Grassland Birds – To address potential impacts to grassland birds, SLW has committed to
compensating for potential Project related direct habitat take associated with the disturbance of
grassland acreage that is permanently converted to roads and turbine pads and additional acreage
impact associated with “disturbance related" factors such as fragmentation and displacement. To
accomplish this SLW proposes to set aside approximately 166 acres of land as a conservation
easement (See Exhibit 2.2.2). This land will be managed to replace habitat affected by direct
and or indirect impacts. Land will be to be dedicated as grassland bird habitat. Key components
of this mitigation include:

x NYSDEC approval of locations and acreage; a plan to enhance grassland quality and or
restore grassland lost to succession; and a plan to perpetuate the restored lands as
grassland.
x SLW funding of a Landowner Incentive Program-like mitigation through a third party
(such as Ducks Unlimited) that would handle the fund and administer the program, while
requiring DEC participation and sign off on the selection of projects.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Exhibit 2.2.2 – Proposed Grassland Bird Conservation Easement

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

2.2.3.2 Revised Impact Analysis


Construction and Operational Impacts
Construction related impacts remained unchanged from those discussed in the SDEIS. SLW
conducted a Final Noise Modeling Assessment for the revised Project

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

layout consisting of 50 1.5 MW Acciona AW-82/1500 wind turbines and 1 1.5 MW AW-
77/1500 wind turbine to assess operational impacts. Sound power data was obtained from the
WTG manufacturer and the critical operational design level was determined for use in the
acoustic noise modeling analysis. The critical operational design level is the worst case in terms
of potential noise impact and perceptibility as it occurs when the differential between the
background level and turbine sound power level is greatest. At higher wind speeds turbine sound
power levels increase, while the masking background sound level also increases significantly.
Table 2-2 shows the comparison of the conservative wintertime L90 background to the wind
turbine sound power levels (SPL) over a range of wind speeds to determine the critical
operational design level. The IEC 61400-11 standard only requires the measurement of SPLs
between 6m/s and 10m/s.

Table 2-2
Comparison of Conservative Wintertime L90 Background and Turbine Sound Levels

Wind Speed
6 m/s 7 m/s 8 m/s 9 m/s 10 m/s
Acciona AW-82/1500 Sound Power Level at 101.7 102.5 102.2 101.8 101.5
Reference Wind Speed
Wintertime L90 Background Sound Level (dBA) 37 39 42 44 47
Differential (dBA) 65 63 60 58 54

The worst case acoustic condition for the proposed Project occurs at a wind speed of 6 m/s, with
the highest differential occurring between the background sound level of 37 dBA and turbine
sound power level (LW) of 101.7 re 1 pW at this wind speed. Table 2-3 shows the estimated
frequency content of the turbine sound power level at 6 m/s.

Table 2-3
Acciona AW 82/1500 Sound Power Level Spectrum at 6 m/s

Octave Band Center


31.5 63 125 250 500 1k 2k 4k 8k dBA
Frequency (Hz)
Estimated Lw
107 104.3 103.8 102.8 100.4 96.8 90.2 82.8 72.7 101.7
(dB re 1 pW)

The Acciona AW-82/1500 WTG sound power level spectrum at the critical design wind speed of
6 m/s speed as well as other wind speeds were inputted into CadnaA (ver. 3.6.115), DataKustik’s
acoustic modeling program. CadnaA conforms to ISO 9613-2 Acoustics – Attenuation of sound
during propagation outdoors and enables the Project and its surroundings, including terrain
features, to be realistically modeled in three-dimensions. Modeling of the current Project layout

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

as of March 2010 assumed the nominally maximum downwind sound level from each turbine in
all directions simultaneously. In other words, although physically impossible, omnidirectional
sound propagation was assumed for all modeled wind speeds. In addition, a conservative ground
absorption coefficient of 0.5 was selected for the acoustic modeling analysis to represent the
rural farming land in the Project area. The ISO standard accounts for ground absorption rates by
assigning a numerical coefficient of 0 for acoustically hard, reflective surfaces and a coefficient
of 1 for absorptive surfaces. If the ground is hard-packed dirt, typically found in industrial
complexes, pavement, or for sound traveling over bodies of water, the absorption coefficient is
defined as G=0. In contrast, ground covered in snow, vegetation, including suburban lawns,
livestock and agricultural fields (both fallow with bare soil and planted with crops), will be
acoustically absorptive and aid in sound attenuation, i.e., G=1.0. It has been found that a middle
value of 0.5 is appropriate for rural farming country in the sense that predicted sound levels
agree very well with measurements of turbine-only sound levels over a variety of wind
conditions.

Modeling results at the critical 6 m/s design wind speed were compared to the NYSDEC
cumulative incremental increase guideline of 6 dBA, which conservatively equates to a Project-
only sound level of 42 dBA, as a basis for Project compliance. This is because a Project-only
level of 42 dBA combined with the wintertime L90 background level of 37 dBA would result in a
total cumulative sound level of 43 dBA, an increase of 6 dBA relative to background. Modeling
results evaluating compliance with the State guideline are shown in Exhibit 2.2.3 and in the form
of a sound contour map. The area inside the 42 dBA sound contour line (in purple) represents the
region where sound from the Project may equal or exceed the NYSDEC’s 6 dBA screening
criterion. These figures indicate that all residences, whether participating or not, lie outside of
the 42 dBA sound contour line and will be short of the 6 dBA NYSDEC threshold.

Acoustic modeling was also completed at a wind speed of 7 m/s, which corresponds to the wind
turbine maximum sound power level output. Modeling results for this wind speed were also
compared to the NYSDEC 6 dBA incremental increase guideline, which equates to a Project-
only sound level of 44 dBA. Exhibit 2.2.4 displays these results and show that no residences
(participating or non-participating) will result in exceedances of the NYSDEC criterion at these
wind speed conditions. The reason for the decrease in potential impacts at wind speeds higher
than 6 m/s is that while the wind turbine sound power level may change slightly as wind speed
increases, the background sound level also increases, resulting in acoustic masking effects. This
trend would continue as wind speeds continue to increase; therefore, at wind speeds higher than
7 m/s the Project would also remain below the NYSDEC impact threshold.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Exhibit 2.2.3 – Noise Modeling Results – Predicted Mean Sound Contours 42 dBA Threshold

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Exhibit 2.2.4 – Noise Modeling Results – Predicted Sound Contours 44 dBA Threshold

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Results of the acoustic modeling analysis indicate that the Project would be in full compliance
with the NYSDEC 6 dBA incremental increase guideline at all non-participating residences
under the 6 m/s critical design wind speed and well short of this threshold at all higher wind
speeds. However, wind and weather conditions (i.e., temperature inversions and low level
jetstreams) may develop from time to time causing Project sound levels to increase, sometimes
substantially, over the nominally predicted level. Field experience indicates that these
unavoidable and inevitable excursions are infrequent and short-lived; for the vast majority of the
time sound levels will be close to the mean predicted value. It should also be noted that Project
audibility does not cease at the 6 dBA threshold but extends further out for some distance
depending on wind, weather and atmospheric conditions. Beyond the threshold, however, the
typical prominence of Project sound emissions above background is significantly lower and
much less likely to be regarded as objectionable.
A modeling analysis of the potential for cumulative sound level impacts from the proposed BP
Cape Vincent Wind Farm Project to the southeast of the Project indicates that, if both the BP
project and the SLW Project are constructed, some residences are likely to experience slightly
higher sound levels than if only the St. Lawrence Project were in operation (See Exhibit 2.2.5).
Increases of 1 or 2 dBA might occur at several homes if the BP project were also operational. It
should be noted that a change of at least 3 dBA is normally required before any real difference in
sound level begins to be perceptible. Therefore, cumulative sound level increases in the Project
area would be fairly minor and would not represent a substantial or particularly tangible change
in the potential impact from the Project when combined with the proposed BP project.

Sound Related Health Impacts


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

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Exhibit 2.2.5 – Noise Modeling Results – Cumulative Impact from Proposed Neighboring Windfarm

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

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


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

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


associations need to be confirmed through controlled studies with case-control or
cohort methodology before they can be accepted as reflective of casual
connections between wind turbine sound and health effects. In the area of wind
turbine health effects, no case-control or cohort studies have been conducted as of
this date. Accordingly, allegations of adverse health effects from wind turbines
are as yet unproven. Panel members agree that the number and uncontrolled
nature of existing case reports of adverse health effects alleged to be associated
with wind turbines are insufficient to advocate for funding further studies.”

The panel concluded that:

x Sound from wind turbines does not pose a risk of hearing loss or any other
adverse health effect in humans.
x Subaudible, low frequency sound and infrasound from wind turbines do not
present a risk to human health.
x Some people may be annoyed at the presence of sound from wind turbines.
Annoyance is not a pathological entity.
x A major cause of concern about wind turbine sound is its fluctuating nature. Some
may find this sound annoying, a reaction that depends primarily on personal
characteristics as opposed to the intensity of the sound level.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

2.2.3.3 Supplemental Mitigation Measures


Mitigation measures proposed for Project construction remain unchanged. To address potential
operational impacts, SLW has redesigned the Project to minimize environmental noise during
Project operations by reducing the number of wind turbines (most recently, eliminating Turbine
11) and siting wind turbines as far away from existing residential receptor locations as
practicable, while keeping the Project an economically viable source of clean renewable energy.

During project operations, SLW has committed to implementing a complaint resolution program
whereby neighboring residents can contact SLW with their concerns. Complaints will be logged
and promptly investigated in order to resolve any verifiable issue or exceedance condition, and
mitigation may be taken on a case-by-case basis. The details of the complaint resolution program
are provided in Appendix C-11.

2.2.4 Shadow Flicker


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

2.2.4.2 Revised Impact Analysis


Of 177 shadow receptors located within 10 rotor diameters:
x 67 (37.8%) will be affected less than 1 hr/yr;
x 84 (47.5%) will be affected 1-10 hrs/yr;
x 19 (10.7%) will be affected 11-20 hrs/yr; and
x 7 (3.9%) will be affected 21-30 hrs/yr

No residences will be affected more than 30 hours per year. All residences that are projected to
be affected more than 20 hours per year are participating in the Project. Based on the limited
number of hours any structure will be affected, shadow flicker is not expected to create an
adverse impact on nearby residential dwellings. For residences where shadow flicker is greatest,
this impact might be considered an annoyance by some, but be unnoticed by others.

2.2.4.3 Supplemental Mitigation Measures


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

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

2.2.5 Transmission Line


2.2.5.1 Supplemental Existing Conditions Information
A 115 kV overhead transmission line will be used to transport power from the collection
substation on Swamp Road in the Town of Cape Vincent to the existing 115kV National Grid
owned substation on Route 179 in the Town of Lyme (See Figure 1). SLW has proposed that the
transmission line will primarily follow the abandoned railroad bed which contains an existing
regional water line owned and operated by the Development Authority of the North Country
(DANC). The total parallel shared ROW of the regional water line and the proposed transmission
line is 7.69 miles. This is the same route proposed and discussed in the SDEIS.

SLW has been working with DANC to identify the construction practices and setback
requirements from the existing water line. On September 30th, 2009 and November 12th, 2009,
representatives from DANC and SLW met to discuss concerns, plans and design standards for
the proposed transmission line. SLW engaged in preliminary engineering with Sargent & Lundy
LLC to determine the design requirements and pole locations for the proposed transmission line.
The focus of the engineering analysis was to design a transmission line that meets all industry
standards and codes, protects the integrity of the water line, allows safe operation and
maintenance of the water line by DANC employees and does not inhibit the operation of the
water line.

DANC has expressed a desire that the proposed transmission line setback the maximum distance
possible from the regional water line, that the vertical clearance between the water line and the
transmission line be maximized, and that the number of times the transmission line crosses the
water line be minimized.

DANC engineers have been involved in reviewing the scope of work for the preliminary
engineering study and the credentials of the engineering firms selected to perform the work.
Three conference calls have taken place where representatives from DANC have reviewed,
discussed and commented on the progress of the preliminary engineering analysis. The
Engineering Concept Report for the proposed transmission line (See Appendix C-7) was
delivered to DANC on April 26, 2010 for their review. DANC has determined that SLW’s
proposed concept design meets their specified minimum requirements (See Appendix A-8).
SLW will continue to work with DANC on the final design, plans and schedule for the proposed
transmission line. Prior to construction of the transmission line, SLW will negotiate a written
agreement with DANC and, at a minimum, will commit to:
x Provide DANC with documentation that appropriate easements have been secured from
property owners;

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Exhibit 2.2.6 – Plan View of Proposed Transmission Owner Interconnection Substation

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003643
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Exhibit 2.2.7 – Profile View of Proposed Transmission Owner Interconnection Substation

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003644
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

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


x Coordinate with DANC during construction to allow for access to the regional water line
for maintenance and emergencies; and
x Ensure DANC’s involvement in progress meetings regarding Project construction in the
regional water line ROW.

The transmission line will terminate at a transmission owner interconnection substation located
on County Route 179 where it will interconnect to an existing 115 kV transmission line at the
operating National Grid substation in the Town of Lyme. Plan and profile views of the proposed
substation are provided in Exhibits 2.2.6 and 2.2.7.

SLW has also been in communication with BP regarding sharing of the transmission line for
BP’s proposed project and will continue to work with BP on an agreement for co-use of the
transmission line (See Appendix A). The poles that are proposed for the SLW Project will be
physically adequate to carry lines that may be needed by BP's proposed project.

2.2.5.2 Revised Impact Analysis


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

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003645
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

The preliminary design provides for a transmission line route that maximizes the horizontal
distance from the regional water line, minimizes the number of crossings and provides the
appropriate vertical clearance taking into consideration the environmental, land, agricultural and
water line maintenance constraints. This distance is more than needed based on the conservative
analysis and design criteria.

2.2.5.3 Supplemental Mitigation Measures


To offset unavoidable visual impacts resulting from the transmission line, the Project has
proposed a visual mitigation plan for the Town of Lyme. SLW proposes to fund renovation of
two community vaults in the Three Mile Bay Cemetery, and to use the remainder of the funds for
vegetative screening of historic resources.

To compensate for potential impacts to wildlife habitat associated with construction of the
transmission line through Ashland Wildlife Management Area (WMA), SLW has committed to
purchasing a 25-acre parcel contiguous to the nearby Point Peninsula WMA in the Town of
Lyme. The WMA provides valuable natural and recreational resources that benefit a wide
variety of wildlife species while being enjoyed by millions of visitors each year. Protection and
enhancement of WMAs in general, thru acquisition, is critical to long term stewardship of these
resources. In particular, the proposed 25-acre Point Peninsula WMA addition will enhance the
area's value as wildlife habitat in general and as a major winter raptor concentration area. The
grassland, wetland and forest complex found on this WMA provides habitat for many common
wildlife species such as white-tailed deer, Canada goose, great blue herons and snapping turtles,
along with less common, endangered and threatened species such as short-eared owl, northern
harrier and Blandings turtle. Adding these lands to the WMA's existing 1000 plus acres will also
improve the potential for popular north country public access activities such as hunting and bird
watching.

SLW is committed to ensuring the communities’ quantity and quality of water is maintained
during construction and operation of the Project, including construction of the transmission line
adjacent to the regional water line. The following steps will be implemented to avoid the
possibility of a breach in the water line during transmission line construction:

x SLW will obtain DANC’s approval of its construction plans near the regional water line
prior to the commencement of construction.
x The main line and all laterals will be marked prior to the initiation of any construction
activities associated with the transmission line.
x A safe buffer distance will be established and maintained during construction of the
transmission line.

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003646
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

x All construction workers will be informed of the location of the water line and safe
working distances.
x The presence of the water line and construction safety will be emphasized during daily
health and safety briefings for all crew members.
x Emergency numbers will be obtained prior to the initiation of construction and made
readily accessible to all crew chiefs.
In the unlikely event of a breach of the water line the following will be implemented:
x The work area will be shut down and secured.
x DANC will be notified immediately.
x The local police will be notified immediately.
x Best reasonable efforts will be made to repair a breach in the water line within 8 to 12
hours of notice to SLW.
x .SLW will develop a plan to provide water in the event of a water line breach prior to
start of construction. This plan will be approved by DANC and the New York State
Department of Health. This plan will also indentify a contractor responsible for
implementing the approved plan.

2.2.6 FAA/NTIA (Communications)


2.2.6.1 Supplemental Existing Conditions Information
FAA
Per SLW request, the Federal Aviation Administration (FAA) conducted an aeronautical study of
the 51 proposed turbines and their locations under the provision of 49 U.S.C., Section 44718 and
Title 14 of the code of Federal Regulations, part 77, as applicable. Correspondence documenting
SLW’s request is provided in Appendix A.

NTIA
SLW notified the United States Department of Commerce, National Telecommunications and
Information Administration (NTIA) of the revised Project layout and requested any concerns the
agencies represented in the Interdepartment Radio Advisory Committee (IRAC) may have
regarding blockage of their radio frequency transmissions. SLW’s request is provided in
Appendix A.

Over-the Air TV
A Final Over-the-Air TV Station Assessment was conducted to determine impacts of the final
Project layout to any over-the-air TV broadcast signals (Appendix C-16). Jefferson County is
located in the Watertown, NY Designated Market Area (DMA). Three of four U.S. full service
digital TV facilities in the Watertown DMA place a predicted FCC

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003647
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

primary service signal over the Project area (Table 2-4). In addition, seven Canadian TV
broadcast stations are predicted to serve the Project area (Table 2-5).

Table 2-4
U.S. Digital TV Stations Predicted to Serve Project Area
Sign City of Power Ant. Height Distance Azimuth
Affiliate Channel
Network License (KW) (m HAAT) (km) (°T)
WWNY-TV CBS 7 Carthage, NY 24.9 219 47.7 116.7
WWTI ABC, CW 21 Watertown, NY 25 331 52.5 124.4
WPBS-DT PBS 41 Watertown, NY 59 369.5 53.1 126.5

Table 2-5
Canadian TV Stations Predicted to Serve Project Area
Sign Analog Digital Distance Azimuth
Affiliate City of License
Network Channel Channel (km) (°T)
CKWS-TV CBC 11 11 Kingston, ON 13.6 279.4
CBLFT-13 Radio-Canada 15 15 Belleville, ON 77.9 284.0
CICO-TV-53 TV Ontario 53 26 Belleville, ON 77.9 284.0
CBC - - 32 Kingston, ON 23.7 312.0
CBLFT-14 Radio-Canada 32 36 Kingston, ON 23.7 312.0
CICO-TV-38 TV Ontario 38 38 Kingston, ON 23.7 312.0
CJOH-TV-6 CTV 6 49 Deseronto, ON 65.3 269.7

2.2.6.2 Revised Impact Analysis


FAA
The FAA determined that the proposed turbines do not exceed obstruction standards and would
not be a hazard to air navigation provided that the turbines are marked and/or lighted in
accordance with FAA Advisory Circular 70/7460-1K Change 2, Obstruction Marking and
Lighting, white paint/synchronized red lights - Chapters 4, 12 and 13 (turbines). Correspondence
documenting its determinations is provided in Appendix A.

NTIA
The agencies represented in the IRAC did not identify any concerns regarding radio frequency
blockage; therefore the Project will have no impact radio frequency transmissions. The response
from the NTIA is provided in Appendix A.

Over-the Air TV
There is some possibility of multipath interference to over-the-air reception of some of the
distant stations in Watertown, NY and Belleville, ON. Residential viewers in the vicinity of the
Project that point their outdoor antennas through the turbines, utilize “rabbit ears” type antennas,
or own TV sets more than approximately five years old are likely to be most affected. Most
modern HDTV sets should successfully handle the described anomalies.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Most of the multipath effect should be dissipated for locations farther than approximately three
miles from a turbine, but some residual problems could be noted for TV receivers that are
located below the grade level at the turbine base. Approximately 10 percent of receiver locations
are affected to some extent within three miles of a wind turbine farm. The usual effect is
intermittent “pixelating” or “freezing” of high definition (HD) TV picture, and “tearing” of an
analog picture.

Approximately 4,000 U.S. households are within an area likely to be affected (roughly within 12
kilometers from the center of the turbine area). Conservatively estimated, at least 50 percent of
the households in the area are likely served by cable or satellite TV and thus would not be
affected by wind turbine disruption. Based on the 10 percent criteria described previously, it is
most likely that up to 200 digital TV receiver households could be affected.

2.2.6.3 Supplemental Mitigation Measures


FAA
A lighting plan has been developed in accordance with FAA Advisory Circular 70/7460-1K
Change 2; Obstruction Marking and Lighting, white paint/synchronized red lights - Chapters 4,
12 and 13 (turbines). This plan is provided in Appendix C-15.

NTIA
The Project will have no impact on radio frequency transmissions of agencies represented in the
IRAC. Therefore, no mitigation measures will be necessary.

Over-the Air TV
Possible mitigation methods (listed from most effective to least effective) to be applied at the TV
receiving household following Project construction are:
x Relocation of the antenna to receive a better signal
x Installation of a higher-quality outside antenna, or one with a higher gain
x Purchase of a new HDTV set or converter box
x Installation of satellite or cable TV.

SLW will utilize the Complaint Resolution process for handling this and other complaints related
to construction of the Project.

2.2.7 Transportation/Traffic
2.2.7.1 Supplemental Existing Conditions Information
The revised primary and secondary equipment delivery routes and private access roads are

2-27

003649
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

provided on Figure 2-5 and Figure 2-6, respectively. SLW also completed a Transportation
Route Evaluation Study (Appendix C-5). The purpose of this study was to determine the
probable local travel routes and potential improvements required for delivery of major wind
turbine components during the construction of the Project. A number of intersection
improvements were been identified. A logistics firm and/or transportation provider experienced
with oversized loads will be engaged in the final route analysis and permit process. The study
also provides a preconstruction photo log that establishes the pre-existing conditions as basis for
the remediation plan.

2.2.7.2 Revised Impact Analysis


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

2.2.7.3 Supplemental Mitigation Measures


SLW is committed to working with the Towns, County, and State agencies to confirm necessary
transportation improvements needed before delivery of equipment to the Project and any
restoration and/or remediation needed after completion of the Project, and that such
improvements will be stipulated in the Project approval. These could include:
x Additional route and condition surveys.
x Temporary removal of obstacles and replacement in kind.
x Completion of improvements before the Project.
x Restoration and/or remediation after the Project.
In addition, road use agreements will be developed with the transportation departments
responsible for public roads during the site plan review process. These agreements will include
adequate detail for evaluating the pre-construction condition of existing roads, standards for
required improvements and restoration, and a mechanism for establishing that restoration has
been satisfactorily completed to the agreed upon standards.

2.2.8 Miscellaneous
Agency Correspondence
Documentation of agency correspondence subsequent to the SDEIS approval is provided in
Appendix A.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 2-6
Potential Impacts Associated with Roadway Improvements

Participating Property
Existing Sign Impacts

ROW Impacts to Non-


Intersection Quadrant

Utility Pole Impacts

Impacts to Existing
Curve/Intersection
Culvert/ Drainage

Trees/Vegetation
Overhead Signal

Road Condition
Overhead Wire
Impacted by Route

Improvement
Clearance

Clearance

Widening
Structure

Owners
Intersections
1) Route 104/Route 104B
2) Route 180/Route 3/County Rd 66 Ɣ
3) Route 180/Route 12F Northeast Ɣ Ɣ Ɣ Ɣ
Southeast Ɣ Ɣ Ɣ Ɣ
4) Route 12F/I-81 Exit 46 NB Ramp Northwest Ɣ Ɣ Ɣ
Northeast Ɣ Ɣ Ɣ
5) Route 342/I-81 Exit 48 NB Ramp Southeast Ɣ Ɣ Ɣ
6) Route 12/Route 342 Northeast Ɣ Ɣ Ɣ Ɣ
7) Route 12/County Rd 9 Southeast Ɣ Ɣ Ɣ
Southwest Ɣ Ɣ Ɣ Ɣ
8) County Rd 9/McKeever Rd Southwest Ɣ Ɣ Ɣ
9a) County Rd 8/McKeever Rd NB Southeast Ɣ Ɣ
9b) County Rd 8/McKeever Rd SB Southeast Ɣ Ɣ
10) County Rd 8/Mason Rd Northeast Ɣ
Southeast Ɣ Ɣ Ɣ
Intersections
11) Mason Rd/Gosier Rd Northwest Ɣ Ɣ Ɣ
12) Favret Rd/Mason Rd Southwest Ɣ Ɣ Ɣ
13a) Favret Rd/Hell St NB Northeast Ɣ Ɣ Ɣ
13b) Favret Rd/Hell St SB Southeast Ɣ Ɣ
14) Hell St/Constance Rd Northwest Ɣ Ɣ Ɣ Ɣ Ɣ
Southwest Ɣ Ɣ Ɣ Ɣ
15) Favret Rd/Wilson Rd Southeast Ɣ Ɣ Ɣ
16) Route 12E/Favret Rd Northeast Ɣ Ɣ
17) Route 12E/Deerlick Rd Southeast Ɣ Ɣ Ɣ
Segments
Constance Road Ɣ
Wilson Road Ɣ
NY Route 12
at NY Route 180 Ɣ
at County Road 179 Ɣ
at County Road 4 Ɣ
Note: Selected quadrant represents the least impacts based on a review of the participating property owners
and existing intersection constraints.

2-29

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Property Values
The concern that property values will be adversely affected by development of the Project has
been expressed by a number of residents. Recent analysis of nearly 7,500 single-family homes
sales between 1996 and 2007 did not uncover conclusive evidence of the existence of any
widespread property value effects that might be present in communities surrounding wind energy
facilities (Hoen, B., R. Wiser, P. Cappers, M. Thayer, and G. Sethi, 2009). For this study homes
were situated within 10 miles of 24 existing wind facilities in nine different states with the
closest pricing models, as well as both repeat sales and sales volume models. A hedonic model
is a statistical analysis method used to estimate the impact of house characteristics on sales
prices.

The study concluded that neither the view of the wind facilities nor the distance of homes to
those facilities was found to have any consistent, measurable, and significant effect on the selling
prices of those homes. Though the analysis cannot dismiss the possibility that individual homes
or small numbers of homes have been negatively affected, it finds that if these impacts do exist,
they are either too small and/or too infrequent to result in any widespread, statistically
observable effect.

Storm Water Pollution Prevention Plan (SWPPP) for the St. Lawrence Windpower Project
This plan (See Appendix C-8) provides the measures SLW will implement to comply with the
State Pollutant Discharge Elimination System (SPDES) requirements for the General Permit for
Stormwater Discharges Associated with Construction Activities (GP-0-08-001). It identifies
potential sources of sediment and other pollutants that affect the quality of stormwater discharge,
and includes plans and measures to:
x Reduce or eliminate erosion and loading of sediment and other pollutants that effect the
quality of stormwater discharges to water bodies during construction;
x Control of the impact of stormwater runoff on the water quality of the receiving waters;
x Control of the increased volume and peak rate of runoff during and after construction;
x Maintain stormwater controls during and after completion of construction;
x Waste and material management for construction activities;
x Implement site inspections, monitoring and personnel training; and
x Identify any post-construction measures that would be required.

Unanticipated Discoveries Plan


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

2-30

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Revised Complaint Resolution Plan


This revised plan (Appendix C-11) outlines protocols for dealing with construction and operation
complaints associated with the St. Lawrence Windpower Project.

Spill Prevention, Control, and Countermeasure Plan (SPCC)


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

Draft Wildlife Protection Plan (WPP)


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

Draft Outline of Construction Environmental Monitoring Plan


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

FAA Final Lighting Plan


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

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

3.0 COMMENT MATRIX


Comments received throughout the SEQR process for the Saint Lawrence Windpower Project
area summarized in Tables 3-1 and 3-2. Summaries of DEIS comments are provided in Table 3-
1 and SDEIS comments are provided Table 3-2. Comments were generally provided in letters to
the Planning Board; however, numerous oral comments were received during the Public
Hearings held for both the DEIS and SDEIS. Transcripts of the DEIS and SDEIS Public
Hearings are provided in Appendix D and copies of all written comments received are provided
in Appendix E in their entirety.

3-1

003654
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Results of the 2006 bat survey and Avian and Bat Study Plan
need to be included in the SDEIS to support conclusions
Tomasik, Steven for stated in the DEIS; SDEIS should also include discussion of
1 1 NYSDEC
Jack Nasca mitigation measures that might be implemented if adverse
impacts are identified in the bat fatality monitoring program
(adaptive management strategy)
DEC does not agree that a more expanded cumulative
analysis is not warranted because "bird collisions with wind
projects represent a very small portion of all bird collisions
Tomasik, Steven for
1 2 NYSDEC with man-made objects," or that the other two proposed wind
Jack Nasca
projects in the region are "speculative". Using existing
available information, the SDEIS should provide a fuller
discussion of cumulative impacts.
SDEIS should include wetland delineation reports for any
areas that would be impacted by project construction; SDEIS
Tomasik, Steven for should discuss wetland avoidance and impact minimization
1 3 NYSDEC
Jack Nasca and proposed techniques to be used to minimize temporary
wetland impacts; feasibility study should be included to make
recommendations in regard to alternatives
If unavoidable wetland impacts result from project
construction, the SDEIS must discuss the overriding
economic and social needs for the project that outweigh the
Tomasik, Steven for
1 4 NYSDEC environmental costs of impacts on wetlands, describe
Jack Nasca
compensatory mitigation being considered, and how the
proposed mitigation will conform to DEC wetland mitigation
guidelines
Tomasik, Steven for The distinction between "temporary" and "permanent"
1 5 NYSDEC
Jack Nasca wetland impact needs to be clarified in the SDEIS
Tomasik, Steven for
1 6 NYSDEC SDEIS should include an Invasive Species Control Plan
Jack Nasca
Section 2.6.4. SDEIS needs to include a description of
Tomasik, Steven for specific processes that will be implemented to ensure that
1 7 NYSDEC
Jack Nasca concrete is handled properly during construction to limit
impacts to surface waters, wetlands and underground waters

3-2

003655
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Section 2.7 and 2.8. Environmental impacts associated with
major turbine repair or replacement, including recurrence of
"temporary" wetland impacts associated with access road re-
widening, not adequately discussed; SDEIS should include a
Tomasik, Steven for
1 9 NYSDEC project-wide long-term environmental management plan, a
Jack Nasca
contingency plan, and assessment and mitigation of
environmental impacts during the decommissioning process;
Environmental management plan should include an adaptive
management plan
Section 3.2.3.3 does not adequately describe the range of
Tomasik, Steven for
1 10 NYSDEC mitigation measures to be considered if project construction
Jack Nasca
results in unavoidable wetland impacts.
DEC recommends that a Blanding's turtle habitat and nest
Tomasik, Steven for site survey be included as part of wetland delineation
1 11 NYSDEC
Jack Nasca activities conducted in the project area. If appropriate habitat
is found, a trapping and tracking survey would be warranted.
DEC recommends that a comprehensive survey of karst
features be conducted in the project development area; DEC
Tomasik, Steven for
1 12 NYSDEC recommends that a plan be prepared that specifies
Jack Nasca
procedures for conducting detailed subsurface investigations
at locations that may interface with limestone/karst features.
Section 3.7.2. Survey to inventory architectural cultural
resources within one mile of the project is not included in the
Tomasik, Steven for
1 14 NYSDEC DEIS; furthermore, the survey's one-mile study area is
Jack Nasca
inadequate; DEC visual policy establishes a recommended
five-mile study area for visual impacts.
DEC recommends that the visual setting of each affected
significant resource in the project area and five-mile visual
impact area, including newly identified significant historic
Tomasik, Steven for resources, be analyzed, and where feasible at specific
1 15 NYSDEC
Jack Nasca impacted resources, direct mitigation options such as
screening or selective turbine re-location should be applied.
Offsets should be employed if these types of mitigation
would be uneconomic or only partially effective. Direct

3-3

003656
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
mitigation and offsets need to be fully discussed in the
SDEIS. Mitigation for visual impacts should be developed in
concert with a mitigation strategy for impacts identified
according to the cultural resources assessment.
SDEIS needs to consider a cumulative assessment of visual
Tomasik, Steven for
1 16 NYSDEC impacts of this project and the two other wind power projects
Jack Nasca
proposed in the general area.
SDEIS should discuss the status and results of any historic
Tomasik, Steven for preservation studies undertaken; correspondence with
1 17 NYSDEC
Jack Nasca OPRHP detailing that agency's rationale for making an
impact/effect determination should be included in the SDEIS
Tomasik, Steven for Archeological studies should be completed prior to, and
1 18 NYSDEC
Jack Nasca incorporated in, the SDEIS
The SDEIS should describe a compliance and monitoring
Tomasik, Steven for
1 19 NYSDEC program to include planning, training, pre-construction
Jack Nasca
coordination, and construction/restoration inspection
DEC may require that the Stormwater Pollution Prevention
Tomasik, Steven for Plan prepared for the project to comply with the SPDES
1 13a NYSDEC
Jack Nasca Stormwater General Permit for Construction Activities be
reviewed by DEC staff prior to implementation
Appendix C. The Visual Impact Assessment (VIA) does not
include consideration of properties identified in the project
Tomasik, Steven for Cultural Resources Survey for this project which are not
1 13b NYSDEC
Jack Nasca currently inventoried, but which may be determined to be
National Register Eligible (Doesn't include results from 5-mile
study).
Section 2.3. No data provided to support statement that the
Stilwell, David and Tim
2 1 USFWS project will improve air quality by offsetting emissions
Sullivan
produced at fossil fuel burning power plants
Section 2.3. The DEIS indicates that the project will reduce
sulfur dioxide, nitrogen oxide, and other pollutants; however,
Stilwell, David and Tim
2 2 USFWS wind energy projects do not deliver the environmental
Sullivan
benefits typically described by project sponsors. Almost no
sulfur dioxide or nitrogen oxide would be eliminated from the

3-4

003657
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
operation of wind energy projects.
It is not specified whether will be one or two meteorological
towers, nor is it mentioned what type of structure will be
Stilwell, David and Tim constructed; USFWS recommends that no guy wires be used
2 3 USFWS
Sullivan on the towers as they have been known to be flight hazards
for wildlife; monopole or self-supporting towers should be
installed
USFWS recommends that the siting of wind turbines avoid
Stilwell, David and Tim forested areas and structures instead by placed along the
2 4 USFWS
Sullivan edges of forests or be eliminated to limit habitat
fragmentation
Stilwell, David and Tim Section 2.5. USFWS found little data to support the need for
2 5 USFWS
Sullivan the project size
Section 2.5. DEIS does not indicate the locations of the best
Stilwell, David and Tim
2 6 USFWS wind resource; therefore they cannot determine what options
Sullivan
the project sponsor has to move turbine locations
Section 2.5. Data should identify areas where birds and bats
Stilwell, David and Tim
2 7 USFWS are concentrated, and thus, provide data to support alternate
Sullivan
turbine locations
Section 2.6. Since birds are likely to occur throughout the
Stilwell, David and Tim project site during the construction period, the USFWS
2 8 USFWS
Sullivan questions how impacts to breeding birds will be avoided
(stated in Table 1-1, Sheet 3 of 8).
Section 2.6. USFWS suggests that applicant reduce the final
Stilwell, David and Tim
2 9 USFWS proposed width of access roads to 16 feet, consistent with
Sullivan
access road width for other wind projects in the State.
Section 2.6. USFWS recommends that the project sponsor
Stilwell, David and Tim design the project so that more project facilities are
2 10 USFWS
Sullivan collocated. Currently only 3.4 miles of the 44 miles of buried
interconnect cable would be collocated along access roads.
Section 2.6. The project sponsor should reduce impacts to
Stilwell, David and Tim habitat as much as possible. Vegetation is proposed to be
2 11 USFWS
Sullivan cleared to a width of 25 feet where underground cable will be
buried but the actual cable trench would only be 1 to 3 feet

3-5

003658
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
wide.
Section 2.6. Directional drilling should be used to cross all
Stilwell, David and Tim
2 12 USFWS perennial streams and wetlands to reduce the potential for
Sullivan
water quality impacts.
Section 2.6. The proposed route of the overhead
transmission line has not been determined, information vital
Stilwell, David and Tim to determine the potential impacts to wildlife. The
2 13 USFWS
Sullivan transmission line should be routed around forests to protect
existing habitat value, reduce fragmentation, and maintain
interior core areas.
Section 3.0. USFWS recommends that no turbines are sited
Stilwell, David and Tim
2 14 USFWS within peat muck areas as these soils may support rare and
Sullivan
irreplaceable habitat.
Stilwell, David and Tim Section 3.0. Karst features may provide unknown
2 15 USFWS
Sullivan hibernacula for bats and should be avoided.
Section 3.0. DEIS should specifically state that alvar
Stilwell, David and Tim
2 16 USFWS landscapes, located at Chaumont Barrens and Three Mile
Sullivan
Creek Barrens, will not be impacted by the project.
Section 3.2. The report should include biotic and water
Stilwell, David and Tim
2 17 USFWS quality data along with a discussion of potential impacts from
Sullivan
project construction.
Section 3.2. Project sponsor should identify which water
bodies will be crossed; the current condition of each; whether
they are perennial, intermittent, or ephemeral; and the exact
amount of temporary, permanent, direct, and indirect impact
Stilwell, David and Tim to each. This should include an analysis of impacts to water
2 18 USFWS
Sullivan quality, habitat conditions, and aquatic life. Mitigation
measures to compensate for lost or degraded habitat should
be discussed. Permanent stream crossings should consist of
bridges or bottomless culverts. In disturbed areas, stream
banks should be seeded and planted to prevent erosion.
A field delineation of wetlands should be completed and then
Stilwell, David and Tim
2 19 USFWS project design adjusted so that impacts are avoided and
Sullivan
minimized to the greatest extent practicable. The DEIS

3-6

003659
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
should be revised with information on wetland extent; size;
physical characteristics; community type, function, and value;
and potential direct and indirect impacts to each.
Turbines should be located away from wetlands and water
Stilwell, David and Tim
2 20 USFWS bodies to avoid changing the character and function of these
Sullivan
features for wildlife.
DEIS does not identify if the wind project will impact the
efforts to establish St. Lawrence Wetland and Grassland
Management District (SLWGMD) nor does it mention if the
proposed project is compatible with the purpose of the
Stilwell, David and Tim
2 21 USFWS SLWGMD. This information should be provided to the
Sullivan
USFWS for review. Since waterfowl and grassland birds
may collide with turbines, and because the purpose of the
SLWGMD is to increase production of avian populations in
these areas, the two projects may not be compatible.
DEIS should provide the methodologies used to determine
Stilwell, David and Tim natural resource impacts. Habitat types in the project area
2 22 USFWS
Sullivan should be field checked so that impact assessments are
accurate.
No discussion of reptiles and amphibians potentially found in
the project area is included in the document. Nor is there
Stilwell, David and Tim
2 23 USFWS any discussion of potential impacts to these species. The
Sullivan
New York State Amphibian and Reptile Atlas (NYSDEC)
should be consulted.
The discussion of affected mammals is inadequate, as no
survey data or existing information sources were provided.
The Lead Agency should require the project sponsor to
Stilwell, David and Tim include this information in a revised report. The statement
2 24 USFWS
Sullivan that "no threatened or endangered mammals, or their critical
habitat, are located within the project area" should be
removed as insufficient studies have been conducted to
determine the presence of listed bats.
Stilwell, David and Tim Section 3.3.3. The fact that the Indiana bat is a State- and
2 25 USFWS
Sullivan Federally-listed endangered species should be clarified.

3-7

003660
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
The statement that Indiana bats have not been recorded in
Stilwell, David and Tim the project area is misleading. Results from the acoustic
2 26 USFWS
Sullivan monitoring have not been presented and no mist-netting has
occurred within the proposed project area.
The distances to Indiana bat locations are incorrect. Multiple
Indiana bat spring/summer roosts have been documented
Stilwell, David and Tim
2 27 USFWS within 10 miles of the project area. The Glen Park
Sullivan
hibernaculum is approximately documented 17 miles
southeast of the project area.
Further analyses regarding potential impacts to bats from the
proposed project are needed. There is nothing to support
the claim that "Predicting bat fatality impact is difficult based
Stilwell, David and Tim
2 28 USFWS on available knowledge of bat interactions with wind facilities
Sullivan
but is expected that impacts to bats at the Saint Lawrence
Wind Energy Project would be similar to other regional wind
projects"
The USFWS does not agree that Section 3.3.7 provides an
adequate assessment of potential impacts to the Indiana bat.
Stilwell, David and Tim Large numbers of bats have been killed by wind turbines in
2 29 USFWS
Sullivan the East and the potential cumulative impact on populations
could be significant. Should the proposed project be
constructed, a bat fatality monitoring program is necessary.
Section 3.3.4 DEIS does not disclose that Derby Hill has
among the highest number of raptors observed during spring
migration in the Northeast. Also, the text does not
Stilwell, David and Tim adequately address the fact that large numbers of raptor
2 30 USFWS
Sullivan species, such as bald eagles, golden eagles, northern
harriers, and peregrine falcons move along the Lake Ontario
shoreline toward the project area. An adequate assessment
of risk to these species should be provided.
Section 3.3.4. It is unclear how the project sponsor can
Stilwell, David and Tim
2 31 USFWS claim that the project design minimizes impacts to migrating
Sullivan
birds when avian migration data is not yet available.
2 32 USFWS Stilwell, David and Tim Section 3.3.5. Project-specific breeding bird data should be

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003661
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Sullivan included in a revised report. This should include information
on the potential impacts to grassland nesting birds endemic
to the region. Sponsor should evaluate project compatibility
with Service' efforts to increase productivity of grassland and
waterbirds in the area.
Section 3.3.6. There are a large number of wintering raptors
Stilwell, David and Tim other than bald eagles in the region. This information should
2 33 USFWS
Sullivan be considered by the project sponsor in siting the project
features.
Section 3.3.6. The project sponsor should review the
Stilwell, David and Tim Service's "Interim Guidelines to Avoid and Minimize Wildlife
2 34 USFWS
Sullivan Impacts from Wind Turbines" (Guidelines) (USFWS 2003)
during design of the project.
Section 3.3.6. A risk assessment that includes information
on bird abundance and distribution over multiple seasons
and years, avian avoidance behavior of turbines, weather
data, and information on migration, breeding, wintering, and
Stilwell, David and Tim
2 35 USFWS stopover habitat should be included in the environmental
Sullivan
documents. Insufficient data were collected at the project
site to determine use of the project airspace by flying animals
to conduct a risk assessment and predict wildlife mortality for
this project.
A post-construction monitoring protocol should be provided
to the NYSDEC and USFWS for review. If turbines are
Stilwell, David and Tim located within blocks of grassland habitat, turbines should
2 36 USFWS
Sullivan not have a cut-in speed of less than 6 meters per second
and operation should be curtailed between July 15 and
September 15 for 5 hours after sunset.
A construction environmental monitoring program should be
Stilwell, David and Tim implemented, which includes a training component for
2 37 USFWS
Sullivan workers on how to identify and handle injured or dead
wildlife.
Stilwell, David and Tim Section 3.3.7. Copy of the current draft protocols from the
2 38 USFWS
Sullivan recently issued Draft Revised Indiana Bat Recovery Plan for

3-9

003662
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
information on this species and mist-netting procedures
enclosed.
The FEIS should address the potential effects of the action
on the Indiana bat and bald eagle in far greater detail than
Stilwell, David and Tim
2 39 USFWS the DEIS. Additionally, the Corps or applicant should
Sullivan
prepare a Biological Assessment (BA) for the proposed
project.
Section 3.3.7. Adverse impacts to Blanding’s turtle are
unclear. The turtles use upland areas for many activities
Stilwell, David and Tim
2 40 USFWS including basking and nesting. Further discussion with the
Sullivan
NYSDEC is necessary to determine the potential for impacts
to Blanding's turtles.
Section 3.3.7. The statement "Based on the wintering bald
eagle's use of the St. Lawrence River, the Project is not
expected to have an adverse affect on eagle foraging or
substantially increase the risk of eagle foraging or
substantially increase the risk of eagle collisions with
Stilwell, David and Tim
2 41 USFWS turbines" is confusing and unsubstantiated. Section should
Sullivan
address eagle nesting, wintering, and migration occurrences
and behaviors, and link those to potential effects to the eagle
from turbine construction and operation. Increased potential
for collision during adverse weather conditions should also
be discussed.
Section 3.3.7. The statement "Although dispersal of the
Indiana bat is in the range of the proposed Project, impacts
are considered unlikely as Indiana bats typically fly low to the
Stilwell, David and Tim
2 42 USFWS ground, below the rotor sweep are" is unsubstantiated at this
Sullivan
time. Mist-netting should be done performed. Potential
impacts due to construction and operation of the proposed
project will need to be analyzed in much greater detail.
Section 4.0. The DEIS should provide a general description
Stilwell, David and Tim of where the other 2 proposed wind energy projects are
2 43 USFWS
Sullivan located in the region; the assumption should be made that
these projects will be constructed; more discussion should be

3-10

003663
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
provided on the potential effects on wildlife, particularly avian
and bat species.
Section 7.0. Wind data were not provided for the project
Stilwell, David and Tim area; therefore, alternative turbine locations could not be
2 44 USFWS
Sullivan determined. The project design, including project size,
should reflect efforts to avoid and minimize impacts.
State of New York
Section 2.6.5. The minimum burial depth in agricultural
Department of
3 1 Brower, Matthew areas should be 48 inches for all methods, unless bedrock is
Agriculture and
encountered at less than 48 inches.
Markets
The Department recommends that the 34.5 kV lines be
buried in agricultural fields. If lines must be installed
State of New York
overhead, they should be located outside field boundaries
Department of
3 2 Brower, Matthew wherever possible. When these lines cross farmland,
Agriculture and
spanning distances should be no less than 400 feet. Line
Markets
location and pole placements should be reviewed with the
Dept. prior to final design.
State of New York
Department of Recently revised "Guidelines for Agricultural Mitigation for
3 3 Brower, Matthew
Agriculture and Windpower Projects" is enclosed
Markets
The DEIS does not include in sufficient detail the specific
State of New York
project components necessary for project operation; specific
4 1 Department of Public Davis, Andrew
knowledge of the proposed turbine sizes, make and model is
Service
appropriate for consideration in a DEIS.
Project components not described in the DEIS include:
communications equipment associated with turbine field
operations, typically including SCADA communication cables
State of New York from each turbine to substations and the O&M facilities;
4 2 Department of Public Davis, Andrew substation communication equipment to downstream electric
Service transmission substations; the 9-mile long overhead line,
substation equipment for low-voltage step-up to transmission
voltage and transmission interconnection facilities at the
NMPC Lyme Substation; and any downstream improvements

3-11

003664
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
to the NMPC transmission system to accommodate the
electrical output of the project. All subsequent analyses of
project impacts should specifically address the size, location,
and nature of impacts associated with those project
components.
Added information to the project website subsequent to
State of New York issuance of the DEIS has not been adequately noticed or
4 3 Department of Public Davis, Andrew formally issued to involved agencies or to the public.
Service Documents should be circulated with notice of the
appropriate comment period.
Section 2.5.2. The town should consider the size and scale
of the proposed turbines in establishing appropriate setback
State of New York
distances from adjacent properties; a buffer of 75 feet from
4 4 Department of Public Davis, Andrew
adjacent property lines would likely represent the smallest
Service
setback yet specified for any major wind turbine siting project
in NY.
Section 2.5.2. Increased setback distances from the St.
Lawrence River and Lake Ontario, the Seaway Trail Scenic
Byway, historic properties listed or eligible for the State and
State of New York National Register of Historic Places, designated Coastal
4 5 Department of Public Davis, Andrew Zone areas including Significant Coastal Fish and Wildlife
Service Habitats and Local Waterfront Revitalization areas, and
designated Wildlife Management Areas should be seriously
considered and addressed in detail as project planning and
environmental review proceeds.
Section 2.6.3. The Guidelines for Agricultural Mitigation
included in the DEIS are outdated; and the application of
State of New York
agricultural protection and mitigation measures will be
4 6 Department of Public Davis, Andrew
required for implementation in Agricultural Districts by any
Service
Certificate of Public Convenience and Necessity issued by
the PSC.
State of New York Section 2.6.5. Disturbance specifications and impact
4 7 Department of Public Davis, Andrew characterizations would probably significantly under
Service represent impacts and installation methodologies where soil

3-12

003665
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
is limited. Burial depth for cables is likely to encounter
bedrock at many areas; bedrock cutting and additional steps
would be necessary for installation at the recommended
depths in agricultural lands. SDEIS should include a careful
analysis of soils characteristics and limitations, based on field
surveys of soils cover depth for proposed facilities sites.
Where soils depth or wetness limitations influence
consideration of overhead, rather than underground
gathering line placement, those locations should be identified
and analyzed for related effects on land use, visibility , and
co-location with other utility equipment such as overhead
electric lines and telephone cables.
Section 2.6.7. The location of the Project substation is within
or directly adjacent to the Warren Wilson House Historic
District, which warrants consideration of alternative locations
to avoid any adverse effect on the Historic District.
State of New York
Additional information should be provided including a site
4 8 Department of Public Davis, Andrew
plan and profile drawings of the arrangement and types of
Service
equipment proposed for the substation, depiction of its
appearance and the relation to the defining characteristics of
the Historic District. Alternative locations should be and
results reported in a Supplemental DEIS.
Section 2.6.8. The DEIS provides limited information
regarding the proposed overhead transmission line. The
location of facilities should be specified, and alternatives,
including consideration of the costs and benefits of
State of New York
underground location for all or part of the line should be
4 9 Department of Public Davis, Andrew
addressed. Consideration of underground placement should
Service
address the crossing of the Chaumont River, any regulated
wetlands or Wildlife Management Areas, Important Bird
Areas, locations visible from the Seaway Trail Scenic Byway,
Historic Districts, and other locations as appropriate.
State of New York If the abandoned railroad grade from Cape Vincent through
4 10 Davis, Andrew
Department of Public Lyme to near the Chaumont River, analysis of the line and of

3-13

003666
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Service ROW location should address: clearing of forest and shrub
cover; relation of the line location to existing water main
within the RR grade; access limitations where bridge
crossings are insufficient or no longer exist.
Transmission facility information which should be provided
into the SDEIS includes: facility design, including structure
types, height and width; expected electromagnetic and
electric field levels at facility centerline, ROW edge and
State of New York
nearest residence; assessment of clearing needs and
4 11 Department of Public Davis, Andrew
vegetation management specifications; relation of facility
Service
location to other overhead and underground utilities and
other existing infrastructure; ROW access improvement
needs and limitations, such as for stream or wetland crossing
locations.
Section 3.1. SDEIS should include an overlay of the project
facilities on a map of floodplain locations; and analysis of
State of New York floodplain limitations on facility location, design and
4 12 Department of Public Davis, Andrew mitigation needs should be provided. Appropriate design
Service criteria should be specified to assure conformance with
floodplain regulations and any requirements of local or
federal floodplain insurance programs.
Discussion of streams, rivers and lakes, wetlands and
State of New York ecological resources does not include any consideration of
4 13 Department of Public Davis, Andrew several Coastal Zone Significant Fish and Wildlife Habitats
Service within the general project area, and downstream from much
of the proposed project area.
SDEIS should include detailed consideration of: the French
Creek Marsh, St. Lawrence River Shoreline Bays, Wilson
Bay and Marsh, and the avian and waterfowl habitats
State of New York
supported by other Coastal Zone Significant Habitats
4 14 Department of Public Davis, Andrew
including Fox Island - Grenadier Island Shoals, Carlton
Service
island, Point Peninsula, and Point Peninsula Marsh. Habitat
impairment tests should be completed for each of the
Significant areas in the project vicinity.

3-14

003667
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
State of New York
A Coastal Zone Consistency Analysis should be included in
4 15 Department of Public Davis, Andrew
the SDEIS
Service
State of New York The Avian and Bat Studies Interim Report (May 2007) should
4 16 Department of Public Davis, Andrew be included in the SDEIS and circulated to involved agencies
Service with appropriate notice to involved agencies and the public.
A single fall season of field observation is not a sufficient
State of New York basis for drawing conclusions regarding impacts, average
4 17 Department of Public Davis, Andrew population characteristics or usage of the project area from
Service birds and bats. Additional seasons of data should be
collected, analyzed, and reported in the SDEIS.
State of New York Characterizations of avian and bat impact should also note
4 18 Department of Public Davis, Andrew recent information reported from other NYS locations,
Service including the Maple Ridge project in Lewis County.
Consideration of the use of the area by migratory species
should include the broader area including Wildlife
State of New York Management Areas and the Coastal Zone Significant
4 19 Department of Public Davis, Andrew Habitats. Study locations were focused on the northerly -
Service westerly portions of the project area, while there are large
areas of wetlands and grassland habitats along the easterly
side of the project area.
Mitigation measures should be replaced with responsible
consideration of mitigation based on results of on-going field
State of New York studies. A commitment to adopting adaptive management
4 20 Department of Public Davis, Andrew principles and detailed plans for facility operation and
Service management, including measures to avoid significant
adverse impacts on bird and bat populations and habitats
should be specified.
The statements that "131 birds known to breed in the Project
area" and "total number of birds varies between 104 and
State of New York
117" should be clarified to reflect the numbers of bird species
4 21 Department of Public Davis, Andrew
encountered. If only 131 individual birds were counted in
Service
surveys of the Project area, then the studies should be
started over during periods when there are actually breeding

3-15

003668
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
or migratory populations present.
Survey results reported to date do not address over-
wintering species presence or use patterns even though the
State of New York
DEIS states that "survey results will identify specific species
4 22 Department of Public Davis, Andrew
that winter at the site and their use patterns of the site" and
Service
the project will "minimize impacts to wintering roosting and
foraging birds."
State of New York
The May 2007 Interim Report does not provide page 29 for
4 23 Department of Public Davis, Andrew
review.
Service
The discussion of threatened and endangered species and
Areas of Critical Concern dismisses any potential adverse
impacts, despite the surveys for the listed species not having
State of New York been completed, and despite the preliminary description of
4 24 Department of Public Davis, Andrew the project components and facility locations. More detailed
Service consideration of the endangered Indiana Bat, the
endangered short-eared owls, and other rare, threatened
and endangered species is warranted than in the cursory
discussion in the DEIS.
Recent management activities at the Ashland Flats Wildlife
State of New York
Management Area, including habitat manipulation and
4 25 Department of Public Davis, Andrew
clearing of forest cover for grassland species management,
Service
should be reported and considered in detail.
Section 3.4. Discussion of transportation and traffic impacts
State of New York should be expanded to specifically address the potential to
4 26 Department of Public Davis, Andrew adversely affect traffic on Route 12E, the Seaway Trail
Service designated Scenic Byway and tourism route. Safety
concerns warrant additional consideration.
Section 3.4. Effects of the appearance of the project
State of New York facilities from the Route 12E Seaway Trail Scenic Byway
4 27 Department of Public Davis, Andrew should be considered as a potential effect of facility
Service operations on traffic. Turbines will have the potential to
distract drivers' attention from safe vehicle operation.
4 28 State of New York Davis, Andrew Section 3.4. Consultation with NYSDOT regarding facility

3-16

003669
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Department of Public construction routing and equipment delivery, and facility
Service operational considerations is recommended, and specific
traffic controls and mitigation planning options should be
reported in the SDEIS
Section 3.4. Discussion of potential impacts to local roads
State of New York
should also include potential grading to reduce high spots to
4 29 Department of Public Davis, Andrew
accommodate the extremely long delivery trailers (e.g.,
Service
approach to the proposed substation along Swamp Road)
Section 3.5. The discussion of project area land use does
not acknowledge the significant areas with the project area
towns which are wetland or habitat reserves. These areas
State of New York
should be addressed as natural areas with significance at
4 30 Department of Public Davis, Andrew
local, regional and statewide scales, as acknowledged in the
Service
designations as Wildlife Management Areas, NYS-regulated
wetlands, and Coastal Zone Significant Fish and Wildlife
Habitats.
Section 3.5. The discussion of the Coastal Management
Program is not a complete consideration of the
responsibilities on New York State agencies in consideration
of actions affecting the designated State Coastal Zone.
Responsibilities of the State Agency include consideration of
State of New York
direct effects on coastal resources and potential indirect
4 31 Department of Public Davis, Andrew
effects on resources such as visual effects on coastal areas
Service
and impacts on historic resources located within the coastal
zone; or effects of construction on coastal resources, such as
sedimentation and erosion from a project site on vulnerable
significant habitat locations downstream from the
construction site.
Section 3.5. The DEIS does not include a Coastal Zone
Consistency evaluation. Within this, discussion of the Scenic
State of New York
Quality Policies should address visual effect of the project on
4 32 Department of Public Davis, Andrew
viewpoints within the Coastal Zone; Recreation policies
Service
discussion should address effects of the project on coastal
zone recreational areas and parks, cultural, historic and

3-17

003670
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
architectural resources; potential project effects on
Significant Coastal Zone Fish and Wildlife Habitats should be
addressed.
The SDEIS should include a complete Coastal Zone
State of New York
Consistency Review, and should document address the full
4 33 Department of Public Davis, Andrew
range of Coastal Policies as listed in 19 NYCRR Section
Service
600.5
Section 3.7. The discussion of Cultural Resources does not
indicate that the project proposes to site turbines, gathering
lines and the gathering and step-up substation within and
State of New York
within close proximity of Historic Properties listed on the
4 34 Department of Public Davis, Andrew
National Register of Historic Places (i.e., Warren Wilson
Service
House and N. Cocaigne House). Potential direct project
impacts on Historic Properties and District locations should
be conveyed explicitly in the DEIS
The project area of potential effect (APE) should be
State of New York expanded to address the proposed substation
4 35 Department of Public Davis, Andrew interconnection in the town of Lyme, and the route of the
Service proposed 115 kV transmission line from the Cape Vincent
substation to the Lyme substation.
The analysis of project visibility from historic resources
State of New York
should be coordinated with the project visual assessment,
4 36 Department of Public Davis, Andrew
since the tall wind turbines, substations, and overhead will be
Service
prominent visual intrusions into the project area.
Supplemental surveys should include all component
State of New York resources and landscapes within listed, eligible or potentially
4 37 Department of Public Davis, Andrew eligible historic properties or districts, as appropriate, to
Service demonstrate the extent of impacts of the project on those
resources.
Phase 1A and 1B reports should be provided to involved
State of New York
agencies when available, for review and comment. Posting
4 38 Department of Public Davis, Andrew
reports on the project website should not be relied on for
Service
purposes of service on involved agencies.
4 39 State of New York Davis, Andrew The APE should include the viewshed of the proposed

3-18

003671
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Department of Public overhead transmission line and substation facilities.
Service
Section 3.8 and Appendix C. The discussion of Visual
Resources and Community Character does not adequately
address the scale and scope of potential project impacts on
State of New York
the project area, the affected local community, or several
4 40 Department of Public Davis, Andrew
resources of regional or statewide significance. Additional
Service
studies are appropriate to more fully address the potential
project visibility and visual impact on important resource
locations
Section 3.8 and Appendix C. Cumulative assessment of the
project on the Seaway Trail Scenic Byway should be
developed, by a sequential representation of several
viewpoints with direct views toward the project area, as
would be experienced by touring visitors traveling along the
Route 12E corridor. The VIA does include representations
from 3 or 4 locations along the Scenic Byway, but the
State of New York presentation does not provide an orientation to the various
4 41 Department of Public Davis, Andrew points, and does not provide consideration of the various
Service cultural, historic, recreational, and scenic resources which
cumulatively comprise the setting and experience of traveling
along the Seaway Trail. The analysis of impacts should
consider corridor management principles and guidelines for
the Seaway Trail, and provide additional consideration to
minimizing the project impacts due to the close proximity of
many of the proposed turbines to this scenic resource of
statewide significance.
Section 3.8 and Appendix C. The DEIS does not address in
State of New York
a comprehensive manner the relation of the Seaway Trail
4 42 Department of Public Davis, Andrew
Scenic Byway to the landscape and the various resources
Service
which contribute to the corridor adjacent to the Trail.
State of New York Section 3.8 and Appendix C. The VIA does not address in a
4 43 Department of Public Davis, Andrew meaningful way the potential project visibility from the
Service designated Coastal Zone areas, such as from within the St.

3-19

003672
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Lawrence River, or from Lake Ontario. Additional
simulations should be presented which represent project
view simulations from both middle-ground and fore-ground
distances from the Coastal Zone water surface, representing
views across locations with both developed and undeveloped
shorelines, to represent the nature of views experienced by
recreational boaters. Demonstration of the consistency of
the proposed project with relevant Coastal Zone Policies for
scenic and visual resources should be provided in a SDEIS.
Section 3.8 and Appendix C. Wider field of view simulations
should be used; viewpoints represented in the VIA are
limited to less than what is experienced at many locations in
State of New York the project landscape. Additional viewpoint and simulation
4 44 Department of Public Davis, Andrew views should be created from locations such as the vicinity of
Service the Thousand Islands High School oriented southerly from
County Route 9. The current photograph is taken from a
topographically inferior position, which limits views of
background distance zone turbine positions.
The discussion of project impact mitigation should consider
project alternative layout and project arrangement, which
State of New York would remove turbines from the most prominent locations
4 45 Department of Public Davis, Andrew near the Coastal Zone areas, the Seaway Trail Scenic
Service Byway, Historic Properties listed or eligible for listing on the
State or National Register of Historic Places, and other
resources of scenic and aesthetic importance to the State.
Section 3.13. The document should include discussion and
details of security measures including limitations on access
State of New York to electrical equipment and substations, including
4 46 Department of Public Davis, Andrew specifications for station fencing and access gates; any
Service proposed security lighting at substation locations measures
to mark underground facility locations and participate in the
Dig Safely New York facilities protection system.
State of New York Section 4.0. The discussion of Cumulative and Growth
4 47 Davis, Andrew
Department of Public Inducing Impacts should address the proposed Wolfe Island

3-20

003673
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Service Wind Project. Additional information, including the
Environmental Overview Report and additional details should
be reviewed and assessed in a cumulative impact
assessment, especially addressing visual resources and
potential for "visual saturation" of the regional coastal
landscape, and cumulative effects on significant habitats,
migratory wildlife and rare, threatened or endangered
species populations.
Cumulative assessment of the combined impacts of the St.
State of New York Lawrence Windpower and the BP Alternatives project should
4 48 Department of Public Davis, Andrew be addressed. Visual impacts, wildlife habitat effects,
Service construction impacts, traffic impacts, and historic resource
impacts should be addressed in a meaningful way.
The range of Coastal Zone resources should be carefully
considered in identifying cumulative project impacts.
State of New York
Coordinated planning for electrical output and
4 49 Department of Public Davis, Andrew
interconnecting facilities should be required to avoid multiple
Service
or duplicative facilities, and repeated construction impacts of
multiple transmission and substation facilities.
Section 7.0. The Alternatives analysis should be significantly
expanded to address project alternatives, including
State of New York
alternative electrical interconnection facilities, alternative
4 50 Department of Public Davis, Andrew
project arrangement and increased separation and setback
Service
from the broad range of significant resources within the study
area.
Section 7.0 The alternatives analysis should address routing
alternatives for the 115 kV transmission line, including facility
State of New York routes within or adjacent to the abandoned railroad ROW;
4 51 Department of Public Davis, Andrew and alternative designs including underground placement of
Service the 115 kV line especially near sensitive resources such as
Wildlife Management Areas, the Chaumont River, and
locations within view of the Seaway Trail Scenic Byway.
State of New York The Alternatives Analysis and the DEIS in general should
4 52 Davis, Andrew
Department of Public convey the essential nature of the project area as containing

3-21

003674
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Service a concentration of inter-related natural and cultural resources
which should be considered cumulatively, rather than
singularly by topic heading.
The Alternatives Analysis should be expanded to present
State of New York detailed assessments and mitigation opportunities resulting
4 53 Department of Public Davis, Andrew from a project design and layout, which increases setback
Service distances from the multiple sensitive resources in and
surrounding the project layout.
The developer should be required to give serious
consideration to a range of alternative facility arrangements
to enable the advancing of a project design that is
State of New York responsive to the many significant resources of State interest
4 54 Department of Public Davis, Andrew in the project area. This should address a reduced project
Service footprint; increased setbacks from shoreline areas, the
Seaway Trail, visual and cultural resources, Significant
Coastal Fish and Wildlife Habitats, WMA and Important Bird
Areas; and remove facilities from NRHP listed properties.
DEC recommends that mitigation measures be discussed,
including plans to provide for adequate control of stormwater
runoff near any identified karst features. The SDEIS should
describe procedures for conducting detailed subsurface
5 1 NYSDEC Nasca, Jack investigations at turbine site locations. The range of actions
to be taken if karst features are identified should be
specified, including further investigation, turbine re-location,
determination of the effects of blasting, or engineering
construction controls.
DEC recommends that a detailed construction plan be
developed to incorporate stringent containment of
5 2 NYSDEC Nasca, Jack construction-related runoff (e.g., installation of silt/stormwater
fencing to prevent surface runoff from entering uncontrolled
into karst inlets, etc...)
DEC recommends that the SDEIS discuss the role of an
5 3 NYSDEC Nasca, Jack environmental monitor, qualified to work in a karst
environment, related to pre-construction surveys and

3-22

003675
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
construction activities that involve excavation to bedrock or
are located in proximity to an identified karst feature.
Figure 3 should be updated to include both the spring and
6 1 NYSDEC Gary, Brianna
fall radar sampling points
The dates on which no sampling occurred should be
6 2 NYSDEC Gary, Brianna
included in the text, along with the reason.
Flight direction, movements, as well as distance of each bird
from the observer should be provided on a map and
6 3 NYSDEC Gary, Brianna
table/graph for all birds, including those seen outside of an
800 meter radius from the observation point.
6 4 NYSDEC Gary, Brianna Headings for Table 1 seem to be missing or misaligned.
Information in Table 2 should be broken down by season
(spring 2006, 2007, and fall 2006). Combining the
6 5 NYSDEC Gary, Brianna percentages of birds flying within and below the rotor swept
area among all seasons could mask times of the year when
birds may be at greater risk.
The overall raptor passage rate at the St. Lawrence site is
generally lower than established hawk watches in New York,
particularly in the spring. However, when comparing this
proposed wind development site to others in the state, the
6 6 NYSDEC Gary, Brianna number of birds per observer hours reported is the highest of
15 spring reports and the second highest of 18 fall reports. It
should also be noted that despite these greater passage
rates, the raptor migration surveys at this project were
conducted with fewer hours of effort than at many other sites.
Based on a comparison of multiple reports from across the
state, the potential for raptor-turbine collisions at the
proposed St. Lawrence wind project may be higher than at
6 7 NYSDEC Gary, Brianna other proposed wind projects in New York. A post-
construction mortality monitoring plan will help determine
impacts to raptors and mitigation measures appropriate to
the level of impact.
No BBS points were located in the southern portion of the
6 8 NYSDEC Gary, Brianna
project area where approximately 20 of the 96 turbines are

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003676
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
proposed.
Survey points also appear to be lacking in the northern
portion of the project area near some larger patches of
forest, and 13 proposed turbines. Conducting surveys in
these areas would provide a baseline estimate of what
6 9 NYSDEC Gary, Brianna
forest-dependant species may be using the project area prior
to construction. A post-construction BBS would then provide
information on whether fragmentation has a negative effect
on breeding forest birds.
Surveys were conducted slightly later in the year than is
typical for BBS, and may have missed or had lower numbers
6 10 NYSDEC Gary, Brianna of some species that would have been more readily detected
during the peak of breeding season (e.g., Henslowe’s
sparrows, upland sandpipers, and short-eared owls)
The sponsor should keep in mind that the proposed project
area lies entirely within the FWS St. Lawrence Wetland
Management District Focus Area of the St. Lawrence Valley
Wetland and Grassland Management District. The NYS
6 11 NYSDEC Gary, Brianna Grassland Bird Landowner Incentive Program has also
received a number of applications from western Jefferson
County. The presence of these programs in the same area
as the project emphasizes the importance of grassland and
wetland habitat in the region.
The dates that each driving and static survey took place, the
times surveys were actually conducted, the weather
conditions during the surveys, and the number and species
of birds seen at each observation point and along driving
6 12 NYSDEC Gary, Brianna routes should be included in the report. Two state-
threatened bald eagles, 36 state-threatened northern
harriers, and 120 rough-legged hawks are reported, but it
cannot be determined from the tables provided when, where
or under what conditions these birds were seen.
Although no state-endangered short-eared owls were
6 13 NYSDEC Gary, Brianna
observed by West, Inc. during the nine days of survey

3-24

003677
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
between November 5, 2006 and March 1, 2007, this species
is known to winter in the area of the proposed project in fairly
large numbers. Surveys conducted on 57 days between July
13, 2006 and March 31, 2007 found 69 owls at 5 roost sites
on 9 survey days between November and March within and
around the project area. DEC staff has also captured and
radio tagged 2 individual owls during winter 2006-2007 and
tracked their movements around the Cape Vincent area.
For the Indiana bat habitat surveys, raptor migration surveys
focusing on golden eagles, and wintering raptor surveys
targeting short-eared owls, rough-legged hawks, northern
harriers, and eagles: a scope of each work plan should be
6 14 NYSDEC Gary, Brianna submitted for review, and consultation should be made with
DEC and USFWS prior to the start of these surveys, or as
soon as possible if fall studies have already commenced, to
determine appropriate methods, duration, and intensity of
survey effort for fall and winter 2007-2008.
A revised report containing the requested information that is
lacking in the current report should be submitted to the DEC
and USFWS as soon as possible. A work plan for monitoring
6 15 NYSDEC Gary, Brianna
post-construction mortality and displacement should be
developed prior to the construction of any turbines, and will
be a condition of any permit issued by DEC.
Township of Cape Comments regarding the importance of setbacks and safety
7 1 Carr, Paul, Ph.D., P.E.
Vincent Engineer as it relates to ice throw
Concern over placement of the overhead transmission line.
What is the immediate vulnerability to the waterline and the
Township of Cape
7 2 Carr, Paul, Ph.D., P.E. impact on long-term maintenance if the OH was to be put in
Vincent Engineer
proximity to the Development Authority of the North Country
Right-of-Way for the waterline, the old RR bed?
If the transmission line is to follow the RR bed, what
Township of Cape
7 3 Carr, Paul, Ph.D., P.E. environmental issues arise as it passes through the Ashland
Vincent Engineer
Game Management area?
7 4 Township of Cape Carr, Paul, Ph.D., P.E. Have the Villages of Chaumont, Dexter, Brownville, and Glen

3-25

003678
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Vincent Engineer Park agreed to have a 115 KV or possibly a 345 KV
overhead power line straddling their single source for a vital
community service?
As the line approaches the Village of Chaumont, has there
Township of Cape been a proper notification of those effected residents?
7 5 Carr, Paul, Ph.D., P.E.
Vincent Engineer Comment expresses concern about the opportunity for
residents to comment on OH route.
Photos in the Visual Impact Study are misleading and
Township of Cape
7 6 Carr, Paul, Ph.D., P.E. visually inaccurate representations of post-project conditions
Vincent Engineer
because of perspective.
Sound level analysis is inadequate and potentially
misleading. The ambient sound level in the community is not
45 dBA as used in the analysis, but closer to 30 as
Township of Cape measured by the commenter. If one were to use 45 dBA as
7 7 Carr, Paul, Ph.D., P.E.
Vincent Engineer the ambient noise and allow a "non-interfering" increase of
5dBA from the Project, the noise increase would actually be
"objectionable" bordering on "intolerable" according to DEC
policy.
Concern for high visibility of the OH lines; disruption of the
Ashland Flats Wildlife Management Area; and devaluation of
8 1 Harris, Michael
land values for properties which will be visually impacted by
the project.
The Stone Building Appreciation Society supports the intent
in the Cape Vincent Zoning Law to protect historic properties
Stone Building
9 1 Uhlig, Robert and locations while allowing development and agrees with
Appreciation Society
the letter by D. Timothy J. Abel of the Jefferson County
Historical Society on this subject matter.
The nocturnal radar study was only available for public
10 1 Old Bird, Inc. Evans, William R. review 2 weeks before the public comment period on the
DEIS was over. The comment period should be extended.
The project turbines are proposed to be up to 425 feet high
but bird migration information is only provided for heights
10 2 Old Bird, Inc. Evans, William R.
under 410 ft above ground level. Bird/bat migration altitude
information should be provided at 25-m resolution up to 200

3-26

003679
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
m above ground level.
Nightly data on passage rate below turbine height is not
presented. Providing a seasonal average for targets below
125 m is not helpful for assessing flying animal impact. Were
observations concentrated in certain months when the main
10 3 Old Bird, Inc. Evans, William R.
bat migration was occurring? Data should be presented in
tabular format with actual figures. West Inc. should follow
the format of Woodlot Alternatives in presenting their radar
data.
The Project would be located 800 m from the St. Lawrence
River and the radar study site was apparently only about 500
m from the shoreline, outside the wind project area. The
radar site would ideally be located 1500 m from the
shoreline, as previously stated by the consultant. Placement
10 4 Old Bird, Inc. Evans, William R.
of the radar unit 1 km closer leads to the fact that about one
third of the radar detection area was located over the St.
Lawrence River and less than half of their radar coverage
was over the proposed wind project site (based on West's
method of determining passage rate in the horizontal mode)
Comparing horizontal radar data from the West radar study
to those of other New York radar studies is problematic b/c
no radar studies in inland NYS includes such a large over-
water proportion in their sampling region. Based on his own
10 5 Old Bird, Inc. Evans, William R. research, there is a strong likelihood that more small
songbird migration in the fall occurs inland along the St.
Lawrence River than over the water. This would especially
be true on evenings when winds are below 10 mph or if
winds were from the east.
West's data suggests that the St. Lawrence plays a role in
channeling nocturnal migration but their analysis does not
10 6 Old Bird, Inc. Evans, William R. provide information on the details of this channeling. Is it
occurring across the whole St. Lawrence Valley? Only at low
altitudes?
10 7 Old Bird, Inc. Evans, William R. Radar data from over the St. Lawrence River, its shoreline,

3-27

003680
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
and inland areas of coverage are summed together to
produce a single passage rate for the whole radar survey
area. Thus, the question of migration corridor along the
south shore of the St. Lawrence is not addressed as was
suggested it would be in the Study Plan.
It would be useful to a 500 m representation of flying target
density as one moves away from the St. Lawrence River up
10 8 Old Bird, Inc. Evans, William R.
to 2.0 km from the River. Also, how do these migration
density dynamics vary with weather?
Concurrent use of image intensifier methodology can be
10 9 Old Bird, Inc. Evans, William R. used to help understand the proportion of bats and birds in
the flying animal mix revealed by the radar.
11 1 LeTendre, Gerard Multiple concerns regarding birds
11 2 LeTendre, Gerard Multiple concerns regarding bats
11 3 LeTendre, Gerard Concern regarding the exact numbers and sizes of turbines
Threatened and endangered species such as Blanding's
11 4 LeTendre, Gerard
turtle should be identified, quantified, and protected.
Wetland studies have not been presented; wetlands should
11 5 LeTendre, Gerard
be avoided during and after construction.
Towers and blades should be painted to not attract birds and
11 6 LeTendre, Gerard
bats
Sellers should be compensated for declining property values
11 7 LeTendre, Gerard
associated with the St. Lawrence Wind Farm
Multiple concerns regarding placement of turbines in
11 8 LeTendre, Gerard proximity to Cape Vincent and in proximity to non-
participating landowners
11 9 LeTendre, Gerard All transmission lines should be underground
11 9 LeTendre, Gerard Concern for sound levels
Request for mitigation measures in the event that
12 1 Falcon, Mary construction problems are encountered when blasting and
agricultural runoff enters local wells and streams.
Bird and bat studies are incomplete and should be extended
12 2 Falcon, Mary
for at least the same number of years as the wind studies.

3-28

003681
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Clarification needed on what a bat fatality monitoring
12 3 Falcon, Mary
program will involve
Multiple concerns regarding comment periods for
12 4 Falcon, Mary
supplemental reports
It is believed that the old railway outside the Village of Cape
Vincent traverses an Indian burial ground. Has approval
12 5 Falcon, Mary
been sought from the Native American Tribes to dig in this
area?
12 6 Falcon, Mary All transmission lines should be underground
12 7 Falcon, Mary Will the Project augment local electricity supply?
Visual Impact photos should include photo simulations from
12 8 Falcon, Mary
the St. Lawrence River.
The Project will be visible from Wolfe Island as well as from
12 9 Falcon, Mary the Lake and River. Have residents of Wolfe Island been
contacted?
The alternatives analysis is misleading. All alternatives have
12 10 Falcon, Mary
not been explored.
12 11 Falcon, Mary Flicker supplemental is based on erroneous data
Concerns about the effects of noise on health. Further
13 1 Falcon, Spencer, MD studies on noise should be performed and short and long-
term health effect studies should be conducted
14 1 Chase, Hester Will forests be protected from being clear-cut?
USDA soil maps show Cape Vincent as very low construction
14 2 Chase, Hester
possibility. Why will turbine towers be different?
Question about compatibility of Project and Town's
14 3 Chase, Hester
Comprehensive Plan.
Does the DEC intend to change laws or guidelines to make it
14 4 Chase, Hester
possible for the towers to be built?
Question about impacts to bridges, buildings, roads, Indian
14 5 Chase, Hester
sites, rock walls, and historic places.
14 6 Chase, Hester Question about ice throw, setbacks, and Highway Dept. input
Questions regarding noise, noise studies and mitigation for
14 7 Chase, Hester
noise

3-29

003682
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
14 8 Chase, Hester Concern regarding profits to participating wind companies
14 9 Chase, Hester Question regarding efficiency of turbines and alternatives
14 10 Chase, Hester Concerns about diligence of bird / bat studies
14 11 Chase, Hester Concern about the identification of Indiana Bats
14 12 Chase, Hester Source of concrete and gravel for roads
14 13 Chase, Hester Question regarding worker crew lodging
Concern about effect of Project on Important Bird Habitat on
14 14 Chase, Hester
Pleasant Valley Road.
Concern about landowner rights (Refers to BP Cape Vincent
14 15 Chase, Hester
Wind Power Project)
14 16 Chase, Hester Concern about shadow flicker on health
14 17 Chase, Hester Questions regarding decommissioning
Gaudette, Richard and Letter opposed to wind farm citing safety, visual impacts, and
15 1
Jan environmental impacts
Petras, Leigh and Request to move transmission lines through Chaumont
16 1
James several miles to the north to avoid visual impact
Concerns regarding shortcomings of DEIS and proposed
17 1 Dziekan, Andrew
mitigation measures
Copy of letter submitted to the NYS Historic Preservation
Office regarding potential effects of Project on historic
18 1 Bragdon, Brooks
preservation properties and the Historic District; copy of
response from the NYS Historic Preservation Office.
Save the River and
Caddick, Jennifer and A thorough review of the collective impacts of wind
19 1 1000 Islands Land
Aaron Vogel development projects in the region should be performed
Trust
Save the River and
Caddick, Jennifer and
19 2 1000 Islands Land Comment on importance of pre-construction studies
Aaron Vogel
Trust
Concern that the SEQR process has not been followed to its
Save the River and fullest extent. DEIS fails to show what the significant
Caddick, Jennifer and
19 3 1000 Islands Land adverse environmental impacts might be and does not
Aaron Vogel
Trust contain information necessary to evaluate project
alternatives

3-30

003683
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Save the River and
Caddick, Jennifer and Comment on importance of agency involvement in decision
19 4 1000 Islands Land
Aaron Vogel making processes.
Trust
Save the River and
Caddick, Jennifer and
19 5 1000 Islands Land The DEIS must include studies of at least 3 years in duration
Aaron Vogel
Trust
Save the River and
Caddick, Jennifer and
19 6 1000 Islands Land The DEIS does not address wetland impacts
Aaron Vogel
Trust
Save the River and Post-construction impacts of storm water run off from new
Caddick, Jennifer and
19 7 1000 Islands Land roads and other turbine maintenance facilities must be
Aaron Vogel
Trust examined.
Save the River and
Caddick, Jennifer and
19 8 1000 Islands Land A cost-benefit analysis of the project must be considered
Aaron Vogel
Trust
20 1 Merchant, Jerry Letter opposing wind farm
Avian and Bat Study Plan is only a protocol for undertaking a
Menter, Rudin and one year avian and bat impact study in the future; a 3-year
21 1 Fucillo, Thomas J.
Trivelpiece, P.C. preconstruction study should be conducted; other
comments/concerns
Menter, Rudin and Wetlands have not been delineated; impacts to wetlands
21 2 Fucillo, Thomas J.
Trivelpiece, P.C. have not been assessed
Menter, Rudin and A geotechnical investigation and SWPPP should be part of
21 3 Fucillo, Thomas J.
Trivelpiece, P.C. the DEIS
A transportation and traffic plan should be created as an
appendix of the DEIS to address the traffic-related impacts to
Menter, Rudin and
21 4 Fucillo, Thomas J. the Town of Cape Vincent resulting from the array of heavy
Trivelpiece, P.C.
vehicles that will deliver turbine components to the Project
site.
A sediment and erosion control plan and a Project
Menter, Rudin and Stormwater Pollution Prevention Plan should be developed
21 5 Fucillo, Thomas J.
Trivelpiece, P.C. to ensure that impacts associated with construction area
properly mitigated.

3-31

003684
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
SLW should be directed by the Planning Board to utilize the
Menter, Rudin and Ranking Protocol (USFWS guidelines - enclosed) to
21 6 Fucillo, Thomas J.
Trivelpiece, P.C. determine whether the proposed site is appropriate for
development of a wind energy facility.
Cumulative impacts of SLW and proposed wind projects in
Menter, Rudin and
21 7 Fucillo, Thomas J. close proximity should be addressed: community character,
Trivelpiece, P.C.
wildlife, connection to the existing power grid.
Menter, Rudin and
21 8 Fucillo, Thomas J. Comments/concerns about the Sound Level Report
Trivelpiece, P.C.
Menter, Rudin and
21 9 Fucillo, Thomas J. Comments/concerns about the Visual Resource Survey
Trivelpiece, P.C.
Menter, Rudin and The DEIS does not identify any mechanism to avoid or
21 10 Fucillo, Thomas J.
Trivelpiece, P.C. mitigate for shadow flicker.
Menter, Rudin and The DEIS fails to properly assess the environmental impacts
21 11 Fucillo, Thomas J.
Trivelpiece, P.C. of constructing the substation and power lines.
The DEIS should be modified to determine what portions of
Menter, Rudin and the electrical interconnection line will be aboveground, what
21 12 Fucillo, Thomas J.
Trivelpiece, P.C. portions will be belowground, and assess the impacts of
such aboveground installation.
Financial assurances should be secured to fund the
Menter, Rudin and decommissioning of the Project in the event that the
21 13 Fucillo, Thomas J.
Trivelpiece, P.C. Applicant is no longer financially viable or refuses to properly
remove the facilities.
Menter, Rudin and Enclosure: USFWS Service Interim Guidance on Avoiding
21 14 Fucillo, Thomas J.
Trivelpiece, P.C. and Minimizing Wildlife Impacts from Wind Turbines
The DEIS does not adequately reference the Town's
Menter, Rudin and
22 1 Fucillo, Thomas J. Comprehensive Plan, or the fact that this Project appears to
Trivelpiece, P.C.
directly conflict it.
The DEIS should contain a meaningful discussion of
Menter, Rudin and
22 2 Fucillo, Thomas J. alternatives, not just the conclusory assertions that it
Trivelpiece, P.C.
presently contains.
23 1 Faulknham, R. Dennis The DEIS did not include a Shadow Impact Assessment
23 2 Faulknham, R. Dennis Large segment of the Project will be highly visible from many

3-32

003685
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
parts of Cape Vincent. Request for one mile setbacks to
reduce visual impacts.
Given the scale of the Project, it is likely that visual impacts
23 3 Faulknham, R. Dennis
may extend far beyond the 5-mile APE
The DEIS does not discuss how long following completion of
site restoration the contractor will stay to evaluate areas
24 1 Faulknham, R. Dennis disturbed during construction and assure that agricultural
and wetland functions and values are restored and
maintained over the long term.
Public road improvement wetland study must be included in
24 2 Faulknham, R. Dennis
the EIS
Wetlands analysis in DEIS should be refined to apply full
range of potential impact criteria to proposed construction
24 3 Faulknham, R. Dennis activity in determination of total area of permanent impact;
not just those areas proposed for permanent placement of
fill.
Ambient decibel levels used in the DEIS are higher than
25 1 Jury, Charles
observed
26 1 Vail, Alan Question about the "no action" alternative
Question about impact of Project on town and village
26 2 Vail, Alan
budgets
Comment on financial assurances for payment, performance
and maintenance bonding. If the project is not bonded,
26 3 Vail, Alan neither the towns nor the leaseholders have a guarantee that
promise will be kept, construction, completed, payments
made, maintenance done, and dismantling completed.
Most DEISs include results of a Job and Economic
Development Impact Model. None was referenced in DEIS
26 4 Vail, Alan
so it appears that the Socioeconomic Section was based on
Assumptions
Comment on direct financial benefit for town/village power
26 5 Vail, Alan
users
26 6 Vail, Alan The Decommissioning Plan needs to be completed

3-33

003686
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
26 7 Vail, Alan Comment on the alternative of downsizing the Project
Concern for residents' needs and wants conflicting with
27 1 Gormel, Thomas
Project
Multiple concerns regarding existing and new roads and road
28 1 Gormel, Thomas
maintenance
29 1 Gormel, Thomas Multiple questions regarding bird and bat studies
30 1 Gormel, Thomas Concern regarding setbacks
Concerns regarding mitigation of views from historic
31 1 Gormel, Thomas
properties
Concerns about the overall cost of the Project and how that
32 1 Gormel, Thomas
will affect town and village budgets
Multiple questions regarding archeological studies and Indian
33 1 Gormel, Joyce
burial grounds.
Questions regarding impact of Project on herons and other
34 1 Gormel, Joyce
recreationally viewed avian species
Multiple concerns regarding effect of Project on community
35 1 Gormel, Joyce
tax base and income
Multiple questions regarding effect of Project on fishing and
revenues from fishing: recreational fishing important part of
the allure of the town and fisherman support local
businesses. Who compensates local businesses if wind farm
36 1 Gormel, Joyce development results in a loss of revenue? Construction
would occur during fishing season and could represent an
access conflict. How will change in revue be measured if
fisherman and recreation boaters go elsewhere after the
towers are constructed?
Questions regarding road maintenance and cost of road
37 1 Gormel, Joyce
maintenance
Multiple concerns regarding existing and new roads and road
38 1 Zovistoski, Mary
maintenance
38 2 Zovistoski, Mary Concern for safety of children
Question regarding MOA developed if the Project design
38 3 Zovistoski, Mary
affects NRHP-eligible sites

3-34

003687
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
38 4 Zovistoski, Mary The assumptions used to complete the DEIS are not listed
Comments requesting more detail on layout of substation,
38 5 Zovistoski, Mary
O&M facility, and construction staging area.
Comment regarding representation of the Project's area of
38 6 Zovistoski, Mary impact as an alternative to GIS maps, line of sight cross
sections, and photo simulations.
38 7 Zovistoski, Mary Multiple comments regarding alternatives
38 8 Zovistoski, Mary Comment regarding decommissioning
38 9 Zovistoski, Mary Mitigation strategies pertaining to visual impacts are limited
Concerns that the maximum power generation of the wind
farm will come close to the transmission line capacity, and
39 1 Hirschey, Urban C.
about the impact that this will have on future power
requirements for the area.
When will the estimate of the cost of decommissioning be
39 2 Hirschey, Urban C.
presented to the Town Board for approval?
The DEIS states that in agricultural areas, electrical cables
39 3 Hirschey, Urban C. will be buried at a possible depth of 48 inches; however, the
NYSDAM states a minimum burial depth of 48 inches.
What are the "other" subcomponents of the wind farm not
40 1 Hirschey, Urban C.
listed in the Executive Summary?
Concern for effect of Project on Fort Drum soldiers and
families. Projected increase in rental costs, based on a
40 2 Hirschey, Urban C.
surge in construction workers and the Fort Drum buildup will
place soldiers and their families at a financial disadvantage.
Question regarding MOA developed if the Project design
40 3 Hirschey, Urban C.
affects NRHP-eligible sites
40 4 Hirschey, Urban C. Concern for safety of children
Comments regarding layout of substation, O&M facility, and
40 5 Hirschey, Urban C.
construction staging area
A real-time, 3-D computerized simulation of the project's area
of impact should be prepared to assess visual impacts
40 6 Hirschey, Urban C.
instead of GIS maps, line of sight cross sections, and photo
simulations.

3-35

003688
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
40 7 Hirschey, Urban C. Multiple comments regarding alternatives
40 8 Hirschey, Urban C. Comment regarding decommissioning
40 9 Hirschey, Urban C. Mitigation strategies pertaining to visual impacts are limited
Comment regarding necessity of environmental monitor in
40 10 Hirschey, Urban C.
areas where karst features may occur
The DEIS needs to state that the maximum megawatt
capacity of this project is 136 megawatts, and that if turbines
41 1 Hirschey, Urban C.
larger than 1.5 megawatts are used, the number of turbines
will be reduced accordingly.
Photos in the Visual Impact Study are misleading because of
41 2 Hirschey, Urban C. turbine positioning and inaccurate representations of turbine
size
The viewshed analysis range should be enlarged to 10 miles
42 1 Hirschey, Urban C.
since land is relatively flat and there are many clear days
No field surveys regarding migratory birds, bats, and other
species were included in the DEIS. No information regarding
43 1 Hirschey, Urban C.
the location of flight corridors was depicted on the study
maps.
Section 3.4.3 should include an appropriate strategy for road
43 2 Hirschey, Urban C.
restoration
Section 3.5.1.2 and 3.5.1.5 should discuss the
43 3 Hirschey, Urban C. Comprehensive Plan adopted by the town and how the
project will fit into the goals set forth in the plan.
In evaluating if turbines prevent future development, Section
3.5.2.3 should discuss examples of future residential
43 4 Hirschey, Urban C.
development within 5 miles of turbines in comparison to
similar areas where they were not constructed.
Page 3-50 should include turbine accidents statistics along
43 5 Hirschey, Urban C. with the required emergency services used to respond.
Towns should be reimbursed for these services.
Page 3-62 should include performance of a balloon study on
43 6 Hirschey, Urban C.
a calm day
43 7 Hirschey, Urban C. Multiple comments regarding ambient noise and noise

3-36

003689
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
increases due to turbines
Section 3.11.1.1 should discuss the effect of the project on
43 8 Hirschey, Urban C. property values in this area of high scenic value and tourism
potential.
Receptors of shadow flicker should be notified and
43 9 Hirschey, Urban C.
compensated
Section 6.0 should discuss the predicted effective capacity of
43 10 Hirschey, Urban C.
the project compared to the nameplate capacity.
Comments regarding declining property values as a result of
44 1 Hirschey, Urban C.
wind projects. Enclosure not attached.
Questions regarding medical issues, safety issues, and a fire
45 1 Boss, Mark
prevention and control plan
45 2 Boss, Mark Questions regarding road modifications and layout
Concerns that the maximum power generation of the wind
farm will come close to the transmission line capacity, and
45 3 Boss, Mark
about the impact that this will have on future power
requirements for the area.
When will the estimate of the cost of decommissioning be
45 4 Boss, Mark
presented to the Town Board for approval?
Bracket, Mr. and Mrs. Letter expressing concern that EIS and other studies may be
46 1
Montgomery biased
Audubon New York requests that the DEIS perform
47 1 Audubon New York Liner, Jillian M. adequate pre-construction surveys to determine bird usage
and assess potential risk.
Comments regarding importance of historic properties and
48 1 Bragdon, Brooks
suggestions for setbacks
48 2 Bragdon, Brooks Enclosure: Correspondence from NYS OPRHP
Enclosure: Letter to Editor from Brooks Bragdon regarding
49 1 Bragdon, Brooks turbine setbacks. Enclosure of SLW visual simulation not
attached.
Gregory, Maureen
50 1 Multiple comments regarding historic properties
Wiley
50 2 Gregory, Maureen Multiple questions regarding planting trees as mitigation for

3-37

003690
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Wiley visual impact
Gregory, Maureen
51 1 Multiple questions about archeological studies.
Wiley
Multiple questions about financial benefits and effect of
Project on Town and Village budgets (What is overall
estimated cost of project? What is estimated cost per
Gregory, Maureen
52 1 kilowatt/hour for first year, first five years, first ten years?
Wiley
How will residents other than lease-holders benefit? How will
the town’s budget be affected in one year, five years, ten
years?)
Gregory, Maureen Questions regarding impact of Project on herons and other
53 1
Wiley recreationally viewed avian species
Gregory, Maureen Multiple concerns regarding existing and new roads and road
54 1
Wiley maintenance
Gregory, Maureen Questions regarding road maintenance and cost of road
55 1
Wiley maintenance
Gregory, Maureen
56 1 Multiple questions regarding bird and bat studies
Wiley
Gregory, Maureen Multiple questions regarding effect of Project on fishing and
57 1
Wiley revenues from fishing
Gregory, Maureen Concern for residents' needs and wants conflicting with
58 1
Wiley Project
Gregory, Maureen Multiple concerns regarding effect of Project on community
59 1
Wiley tax base and income
Multiple comments and recommendations regarding
60 1 Doull, Melodee
representation and mitigation of viewshed
Comments and concerns about underlying geologic material
61 1 Macura, Daniel
and resulting impacts
Comments and concerns about effect of Project on
61 2 Macura, Daniel
groundwater
Moehs, Charles, MD, Concerns about "wind power syndrome" and
62 1
MPH recommendations on how to avoid this
63 1 Duehkind, Winnie Is it possible to set up some sort of screen to project birds

3-38

003691
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
and bats?
64 1 Walker, Tom and Mabel Concern about adequacy of studies for wildlife
Comment on assessment of land as industrial as opposed to
64 2 Walker, Tom and Mabel
agricultural
The DEIS fails to evaluate impacts on Federal and State
65 1 Brown, Thomas listed threatened and endangered species, including the
Indiana Bat, the Short Eared Owl, and the Black Tern.
The DEIS should include an assessment to determine if
65 2 Brown, Thomas ozone levels would increase due to the collective effect of
the multiple proposed wind farms in this general area
Concern about declining property values and suggestion of
66 1 Hludzenski, Kathryn A.
property stabilization program
Section 3.13.1.2 on possibility of ice shed is misleading
67 1 Hludzenski, Kathryn A.
because of selective quoting
Crossby, William and
68 1 Comment on the importance of performing thorough studies
Barbara
Jefferson County Comments on the importance of reviewing all historical
69 1 Historical Society, Abel, Timothy J., PhD resource inventory and assessment research prior to making
Watertown, NY a final decision on the Project.
70 1 LaPlante, J.O Urging of pre-construction bird and wildlife studies
Article: Watertown Enclosure: Article: "Study says wind power fatal to birds and
70 2
Daily Times bats" from the Watertown Daily Times 5/31/2007
Article: Los Angeles Enclosure: Article: "Wind power planning called for" from the
70 3
Times Los Angeles Times
Article: Watertown Daily Enclosure: Article: "Blades a draw for bats, birds" from the
70 4
Times Times Washington
Article: Source Enclosure: Article: "Wind farms, Study sees need for more
70 5
Unknown guidance"
Concern regarding public input and the addressing of
71 1 Hanson, Rollin V
comments
Multiple comments regarding historic sites, viewshed
71 2 Hanson, Rollin V
analysis, and mitigation for visual impacts
72 1 Hludzenski, Kathryn A. Question regarding turbine stability in underlying geologic

3-39

003692
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
substrate
73 1 Freislich, Michele L. Concerns about health effects from Project
Letter expressing concern about town relationships and
74 1 Simpson, Carol
asking Town Planning Board to slow down decision-making
Section 2.2 What is the third alternative procedural pathway
75 1 Gormel, Joyce
available to the Lead Agency?
Number of miles of gravel access roads is inconsistent
75 2 Gormel, Joyce
(Section 2.6.3 states 44 miles)
Section 3.12.1.1 and 3.13.1.1 are both titled "Microwave
75 3 Gormel, Joyce Analysis". Which section needs to address this topic and
what is missing from the other section?
75 4 Gormel, Joyce Section 3.13.2.4 Multiple questions regarding fire hazards
Section 1.6 and 2-9 contain the same table titled "Permits
75 5 Gormel, Joyce and Approvals for the St. Lawrence Wind Energy Project"
with different verbiage. Which is correct?
Request for more detailed information on PILOT payment
75 6 Gormel, Joyce
intentions
75 7 Gormel, Joyce Request for more detailed information on decommissioning
Request for more detailed information on bird and bat
75 8 Gormel, Joyce
studies
Multiple comments and recommendations regarding safety
76 1 Pundt, Art plans, emergency services training, and additional potential
hazards
The DEIS lacks detail on decommissioning and should be
77 1 Gormel, Thomas
modified to reflect a more formal plan
Concerns with DEIS claim that only a portion of the study
78 1 Levy, Ann E. area will have visibility of wind turbines within the five mile
radius
78 2 Levy, Ann E. Concerns with effectiveness of mitigation for visual impact
There is no mention of the Dodge Bay Cemetery in the
79 1 Boss, Sarah F. Historical Architecture Resource Investigation section of the
DEIS
79 2 Boss, Sarah F. As the zoning law does not permit structures more than 35

3-40

003693
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
feet high, the wind towers do not qualify in the Township
79 3 Boss, Sarah F. The deadline for public input should be extended
Concern that wind power does not eliminate pollutants and
79 4 Boss, Sarah F.
greenhouse gases during the production of electricity
79 5 Boss, Sarah F. Transmission line locations have not been specified
79 6 Boss, Sarah F. Potential impacts to wetlands have not been provided
Potential impacts to karst topography have not been
79 7 Boss, Sarah F.
provided
Potential impacts to avian and bat species have not been
79 8 Boss, Sarah F.
provided
The model and megawatt of the windmills still need to be
79 9 Boss, Sarah F.
determined
Number of miles of gravel access roads is inconsistent
79 10 Boss, Sarah F.
(Section 2.6.3 states 44 miles)
The DEIS needs to specify who will be responsible for road
79 11 Boss, Sarah F. improvements and reconstruction necessitated by
construction vehicles
79 12 Boss, Sarah F. Concern for turbine blades crossing property lines
Urging of an analysis of impacts to property values and the
79 13 Boss, Sarah F.
region's economy
Concern that turbines are located too close to the Thousand
79 14 Boss, Sarah F.
Islands Junior/Senior High School; concern for ice throw
Questions regarding how the Project will affect ducks and
80 1 Brown, Thomas
geese and how these impacts will be assessed
Inquiry as to when supplemental bird and bat studies will be
80 2 Brown, Thomas
available
Pressly & Associates,
81 1 Pressly, Nicholas Wetland impacts were not avoided to the extent practicable
Inc., Cherry Valley, NY
Pressly & Associates, Construction sites should be placed far enough away from
81 2 Pressly, Nicholas
Inc., Cherry Valley, NY potential receptors to reduce effects of storm water runoff
Pressly & Associates, A field survey of existing wetlands and associated biota
81 3 Pressly, Nicholas
Inc., Cherry Valley, NY should be included in the DEIS
81 4 Pressly & Associates, Pressly, Nicholas Potential long-term impacts resulting from increased surface

3-41

003694
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Inc., Cherry Valley, NY flow due to road construction should be evaluated. This
should include impacts to wildlife resulting from increased
volume, turbidity, and chemicals used for road deicing or
dust suppression.
It is likely that groundwater will be impacted by direct
Pressly & Associates, infiltration of turbid water and dissolved concrete into the
81 5 Pressly, Nicholas
Inc., Cherry Valley, NY bedrock aquifer. Potential impacts to groundwater should be
evaluated in the DEIS.
81 6 Curriculum Vitae Enclosure: CV of Nicholas Pressly
82 1 Cuda, Kenneth Request for removal of Turbine #22
Concerns expressed over proximity of Project to the Cape
83 1 Bragdon, Brooks
Vincent Historic District
The Project does not accommodate the stated purposes of
83 2 Bragdon, Brooks
the Cape Vincent Zoning Law
Cape Vincent Zoning
83 3 Enclosure: Page 1 of the Cape Vincent Zoning Law
Law
Bouchard, Gerry and Will the wind companies be held responsible for correcting
84 1
Michelle any interference with TV and radio reception?
85 1 Cuda, Kenneth Request for greater setbacks from the St. Lawrence River
Letter from Brooks Bragdon to the NY State Dept of Parks
addressing impacts to the St Lawrence River, Historic
86 1 Bragdon, Brooks
District, and NR Listed properties; and requesting increased
setbacks and smaller turbines
Proposal for the formation of a review board to evaluate
87 1 Dziekan, Andrew
Project
Article: Pylon cancer fears put £7bn blight on house prices
88 1 Article: Telegraph (UK)
(5/1/2006)(1st page only)
Article: Leukemia risk 70pc higher for children close to power
89 1 Article: Telegraph (UK)
lines 6/8/2005)
Internet Article: Daily-
90 1 Article: An ill wind…wind farms as a blight on the landscape
John.com
91 1 Gormel, Joyce Multiple concerns about PILOT payments
92 1 Moehs, Charles, MD, Discussion of Wind Turbine Syndrome and request for

3-42

003695
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
MPH increased setbacks from the Thousand Island Junior/Senior
High School
Concern that the number and placement of turbines will
93 1 Brown, Thomas transform the landscape into an industrial complex. Request
for fewer turbines and greater setbacks from the shore.
Letter to Editor: Letter to Editor: Noisy turbines disrupt sleep, devalue
94 1
Watertown Daily Times property
Multiple questions and comments regarding cumulative
95 1 Gormel, Thomas impacts of wind projects on wildlife, resources, migratory
birds, and transmission of electricity to the national grid.
A website has been created whereby all comments can be
96 1 Levy, Ann E.
aired objectively (www.stlawrencewind.org)
Comment on the term "appropriate" in the Executive
Summary when referring to buffers from property lines
97 1 Gormel, Thomas
nearby residences, roads, and other nearby visually sensitive
areas.
97 2 Gormel, Thomas Mitigation for visual impacts needs to be more specific
The DEIS is incomplete; the public hearing and comment
Wind Power Ethics period should be stayed until sufficient information has been
98 1 Drabicki, Judy, Esq.
Group developed to provide for a legitimate public review and
comment. Enclosure: not attached
99 1 Wiley, Karen Concerns about suffering summer tourism
Concern regarding the potential density of turbines in the
99 2 Wiley, Karen
region
99 3 Wiley, Karen Concern for declining property values
Concern that East End Park will not be as attractive with
99 4 Wiley, Karen
visible wind towers; effect on hunters and snowmobilers
99 5 Wiley, Karen Concern regarding objectivity of studies performed
Does St. Lawrence Wind Power have a good safety record
99 6 Wiley, Karen
regarding the construction and operation of towers.
Urging of town officials to do research regarding the impact
99 7 Wiley, Karen
of noise and light from the towers on residents and wildlife.
100 1 Graf, David General comments.

3-43

003696
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
General questions about the size of the Project, visual
101 1 Callery, Judith Anne impacts, tax implications, impacts to avian species, ice
throws, TV reception interference, property values, and noise
Concern for tourism, visual impacts; call for zoning laws
102 1 Kemmis, Richard J. specific to wind turbines and increased setback from the St.
Lawrence River
103 1 Brown, Thomas Objection to the St. Lawrence Wind Farm DEIS
Brown, Thomas; R. Letter to the NYSDEC and USFWS expressing concerns
Dennis Faulknham, regarding the lack of bird and bat studies in the DEIS,
104 1
Gerard LeTendre, and impacts to migrating birds, and calling for 3-year long studies
Clifford Schneider for assessing impacts on bird and bat resources.
Haskins, Janet and
105 1 Concern for ill health effects from Project
James
The NYSDEC's Assessing and Mitigation Noise Impacts
(AMNI, 2001) should not be quoted as a standard; there is
106 1 Schneider, Clifford P.
no current statewide standard to govern and guide wind farm
development in New York State.
Article: Utica Observer Enclosure: Article: Wind Turbines could force family to leave
106 2
Dispatch Fairfield home (Utica Observer Dispatch - March 8, 2007)
Pre- and post-construction photographic simulations are
107 1 Brooks, Colin
deceptive due to perspective.
The only people who stand to benefit from the construction of
107 2 Brooks, Colin wind turbines are those who are leasing their land to the
company
There is a conflict of interest between members of the board
107 3 Brooks, Colin and St. Lawrence Windpower LLC; some individuals have a
financial/personal interest in the development of the Project
Objection to the size, shadow effect, flicker effect and noise
108 1 Bragdon, Brooks of the turbines; call for setbacks to protect the character of
the community. Listed enclosures not attached.
Multiple comments on inadequacy of specific avian studies.
109 1 Smith, Gerald
Please refer to comment letter.
110 1 Docteur, David H. Multiple questions on effect of Project on short and long term

3-44

003697
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
human health
110 2 Docteur, David H. How do sweeping shadows affect fish?
Enclosure: e-mail concerning a press release about Vibro-
110 3 E-mail
Acoustic Disease,
To comply with Cape Vincent's wind turbine noise guideline,
a greater setback distance is needed. A setback of 3,457
feet would recognize the importance of night-time
background levels, include the 5 dBA above background
111 1 Schneider, Clifford P.
guideline, and use the same method as AES-Acciona uses
to calculate wind turbine noise spread loss. It would also
give non-participating landowners leverage in negotiating
with AES-Acciona.
Post-operational background noise surveys should be
performed to ensure that AES-Acciona conforms to their own
111 2 Schneider, Clifford P.
predictions and that their wind turbines comply with the
Planning Board's noise guideline.
AES-Acciona should be required to shut down wind turbines
111 3 Schneider, Clifford P. when winds at ground level diminish to turbine cut-in speeds
(e.g., 5 m/s)
The Planning and Town Boards should be more concerned
with individual property loss of non-participants than tower
111 4 Schneider, Clifford P.
removal costs. Bonding should provide these residents with
protection from property loss.
111 5 Schneider, Clifford P. Forty-one questions regarding sound level report
111 6 Schneider, Clifford P. Eleven questions regarding the flicker assessment
111 7 Schneider, Clifford P. Twenty-four questions regarding avian studies
111 8 Schneider, Clifford P. Twelve questions regarding the Visual Assessment Report
Enclosure: Response letter from Jack Nasca to Clifford
111 9 Letter: NYSDEC.
Schneider regarding comments dated 3/12/2007
The project definition should include an evaluation of the
Bernier, Carr, and
Cape Vincent Planning bedrock geology, as well as in the EIS. The level of detail
112 1 Associates (Dimmick,
Board needs to be commensurate with the stage of environmental
Kris)
review. This analysis should also identify potential impacts

3-45

003698
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
and mitigating measures that will be implemented during the
site and foundation design. Remote sensing might also be
helpful.
The planning board requires that SLW redo the map showing
tower locations to conform to the following criteria: A. No
tower is to be closer than 1,000 feet to a non-participating
property line; B. No tower is to be closer than 1,250 feet to a
Cape Vincent Planning Planning Board
112 2 non-participating residence; C. No tower is to be closer than
Board Members
750 feet to a participating residence; D. No tower is to be
closer than 1,500 feet to the Village of Cape Vincent line.
The new map is to be submitted to the Planning Board and
to all of the locations where the DEIS is located.
SLW will respond to all comments submitted by the N.Y.
State DEC, USFWS, NY Public Service Commission, NY Ag
Cape Vincent Planning Planning Board and Markets, and NW State Historic Preservation Office that
112 3
Board Members have been submitted during the public comment period
ending 6/15/2007. SLW will submit a copy of this
correspondence to the Planning Board.
SLW is to indicate on their new map that location of the
transmission lines inside and outside of the project area.
The map will need to show whether the lines are above
ground or below ground. If below ground, the depths of the
lines will need to be indicated. The map will need to show
line capacity, size of lines, height of lines, material of lines,
and any other pertinent specifics. The map will also have to
Cape Vincent Planning Planning Board show the specifics of any towers and the tower placement.
112 4
Board Members This new map will also have to be submitted to the Planning
Board and to all of the locations where the DEIS is located.
There is to be only one transmission line leaving the wind
turbine project from the Town of Cape Vincent. Therefore,
SLW is to communicate with BP to the effect that both
companies must work together on the transmission line.
SLW is to send this correspondence to BP via certified return
receipt mail. A copy of the SLW letter, certified receipt, and

3-46

003699
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
any response by BP are to be submitted to the Planning
Board.
A revised visual impact study will need to be done based on
the new project map. This revised visual impact study is to
include at least 2 locations from the waters of Lake Ontario
inland and 3 locations from the waters of the St. Lawrence
Cape Vincent Planning Planning Board
112 5 river inland. There is to be an additional location taken from
Board Members
the water in the vicinity of the Tibbets Point Lighthouse
focusing downriver. Another such location is to be taken
from the Cedar Point State Park area while on the water
looking back toward the Tibbets Point Lighthouse.
Cape Vincent Planning Planning Board Further explanation of the visual study methodology will need
112 6
Board Members to be submitted to substantiate the study.
Background ambient sound levels will need to be done to
accurately measure the entire project and the Village of
Cape Vincent. The background ambient sound
measurements submitted need to be located so as to include
Cape Vincent Planning Planning Board
112 7 commercial and pleasure watercraft on the river as well.
Board Members
These background ambient sound levels are to include
measurements taken both during daytime and nighttime
hours. Study methodology will need to be submitted to
substantiate the study.
Cape Vincent Planning Planning Board A revised shadow flicker study map is toe be prepared using
112 8
Board Members the new project map and submitted accordingly.
Cape Vincent Planning Planning Board Wetland delineation studies need to be done and wetland
112 9
Board Members locations shown on the project map.
SLW will need to meet with the Cape Vincent Fire Dept. and
Cape Vincent Planning Planning Board
112 10 work out an emergency fire and ambulance response plan.
Board Members
This will need to be submitted accordingly.
Cape Vincent Planning Planning Board A traffic/transportation plan will need to be created and
112 11
Board Members submitted accordingly.
A stormwater pollution prevention plan and soil erosion
Cape Vincent Planning Planning Board
112 12 control plan will need to be prepared for the appropriate
Board Members
agency approval as part of the site plan review approval

3-47

003700
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
process. All necessary permits will need to be in place prior
to any construction.
Enough distance to avoid shadow flicker affecting people
113 1 Boss, Sally
with migraines.
113 2a Byrne, John Requesting that the night-time lighting be mitigated
Requesting the avoidance of excessive trees and shrubbery
113 2b Byrne, John
removal.
113 3 Docteur, David Minimize shadow flicker, 3,000 setback for noise.
Wind Power Ethics Public comment period after environmental studies are
113 4 Drabicki, Judy, Esq.
Group complete?
113 5 Falcon, Mary Contingency plans for water run-off problems from project.
What are the cumulative impacts of all of these projects on
the residents of our community? How will all proposed wind
projects in the area impact migratory birds? How SLW does
113 6 Gormel, Thomas
proposes to mitigate the cumulative impact of all of these
projects on the transmission of electricity to the National
Grid.
113 7 Hambrose, Harold Inaccurate visual analysis of the area.
Questions: is the removal of turbines only to be paid at the
end of their useful life, clear definition of "useful life", who
113 8 Hambrose, Johanna
determines “useful life", removal of underground collection
system, damage to visual beauty of area.
113 9 Hanson, Rollin V Setbacks needed to protect character, history of area.
113 10 Henchy, Harold Do not overlook quality of life.
Concerns about changing recreational area to industrial
113 11 Hirschey, Sally
zone.
Concerns about changing recreational area to industrial
113 12a Hirschey, Urban C.
zone, outdated, suggests 5 mile setback from lake and river.
113 12b Hirschey, Urban C. Accuracy of the project efficiency needed.
Who provides compensation for loss of property value,
113 13 Hludzenski, Ed damage to water table? Who is liable for property, personal
damage from ice throw, study on infrasound needed.
113 14 Hludzenski, Ed Leukemia possible near power lines.

3-48

003701
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-1
Saint Lawrence Windpower Project DEIS Comment Summary
Source ID1 Comment ID Agency/Organization Commenter Comment/Summary
Decommissioning of turbines at no cost to town, absolutely
113 15a Metzger, Don
no advertising.
113 15b Metzger, Don Requesting that the night-time lighting be minimized.
Restoring damage from installation process, and repairs at
113 16a Reinhart, Marianna
no cost to town
Where will the O&M building be placed in relation to town
113 16b Reinhart, Marianna
and turbines?
Three year Avian / Bat study, unknown credentials of visual
113 17a Schneider, Clifford P. analyst, use accurate noise instruments for measuring
sound.
Night-time noise studies needed, more description of
113 17b Schneider, Clifford P.
character of noise needed
113 18 Simpson, Carol Relocate turbines to accommodate the wildlife in the area.
Siting of turbines must be done in an environmentally
113 19 Nasca, Jack
sensitive fashion.
1
Source 113 represents oral comments received during March 24, 2007 Public Hearing.

3-49

003702
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
The USFWS has reviewed the SDEIS and may provide further comments
1 1 USFWS Stilwell, David pursuant to the MBTA, BGEPA, CWA, or the Fish and Wildlife Coordination
Act, as applicable. Further consultation pursuant to the ESA is warranted
and is ongoing.
The additional data gathered by the project sponsor has answered some of
1 2 USFWS Stilwell, David our questions and concerns. However, we believe that insufficient
information still exists to predict potential impacts to wildlife.
Our previous comments on the project's ability to reduce greenhouse gases
1 3 USFWS Stilwell, David were not adequately addressed. We requested data which shows that the
project will offset emissions produced at fossil fuel burning plants, but none
was provided.
According to the SDEIS, there will be five meteorological towers eventually
located in the project area and all will by guyed for support. As stated
1 4 USFWS Stilwell, David before, we recommend that no guy wires should be used on the towers as
they have been known to be flight hazards for wildlife. Instead, monopole or
self-supporting towers should be installed.
Transmission line overhead crossing of the Chaumont River should be
accomplished using directional drilling under the river to limit impacts to
wildlife using the river corridor. Also, we commend the project sponsor for
1 5 USFWS Stilwell, David minimizing habitat impacts by choosing a route that primarily follows an
abandoned railroad and water line right-of-way. We recommend that tree
clearing along the ROW to reduce risk of damage to OH lines be kept to a
minimum amount necessary.
Based on wetland delineation report, it appears Turbine 3 is in wetland W-
1 6 USFWS Stilwell, David 22; however, the permanent impact associated with this area is listed as a
road impact on Table 3-6. Determine if this is an error. We recommend that
no turbines be placed in wetlands.
We recommend project design should be reviewed to eliminate clearing of
1 7 USFWS Stilwell, David 0.34 acres of forested wetland, if feasible. While compensatory mitigation
plans have not been finalized, project sponsor is not proposing mitigation

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003703
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
for clearing of forested wetlands. We consider that this impact is
permanent, and accordingly, mitigation should be provided.
The SDEIS, p3-47, indicates that breeding bats are not highly susceptible
to mortality from wind turbines. We caution that insufficient data has been
collected at wind energy projects in the eastern US to draw conclusions
1 8 USFWS Stilwell, David about the effects of turbines on local populations. However, it is true that
most bat fatalities have been found during the fall migratory period,
primarily because that is when turbine areas have been searched for
carcasses.
The SDEIS mentions White Nose Syndrome (WNS) as an affliction killing
bats but does not include a discussion of the cumulative effects of WNS
and other sources of mortality on bats, such as wind turbines. While the text
acknowledges that little brown bats have been most affected by WNS, it
1 9 USFWS Stilwell, David does not mention that this species was also among the most killed at
nearby Maple Ridge wind project last year. Since little brown bats are the
most numerous species of bat found in the project area, the text should
provide an analysis of what the long term implications of the project are for
this species.
Adaptive management should be listed as a method for monitoring and
mitigating impacts to bats (and birds). Specifically, the project sponsor
should commit to adjusting project operations, such as adjusting turbine
1 10 USFWS Stilwell, David cut-in speeds during low wind periods to reduce bat fatalities. This is the
period when most bats are killed as documented by recent research (Arnett
2005). A study at the Meyersdale wind project in PA recently determined
that bat mortality can be reduced by more than half if the cut-in speeds are
adjusted (Arnett 2009).
The project area, as noted in the DEIS on p3-22, is within a concentrated
migratory pathway, has attractive stopover habitat, and has unusually high
1 11 USFWS Stilwell, David concentrations of birds and, therefore risk for collision may be higher than
at other projects. The proximity to wetlands, Lake Ontario, and St.
Lawrence River attract waterfowl, waterbirds, and shorebirds to the area
during the breeding and migratory periods (Northern Ecological Associates,

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003704
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
1994). We find that insufficient data were collected at the project site to
determine the spatial and temporal use of the project airspace by flying
animals and to adequately conduct a risk assessment and predict wildlife
mortality for this project. One year of surveys is not enough and we
recommend another year of study data to adequately determine avian use
in project area and the associated risk from project operation.
The SDEIS has documented the presence of bald eagles and golden
eagles in the project area. The bald eagle was removed from the Federal
endangered list and is no longer protected under the ESA; bald eagles
1 12 USFWS Stilwell, David remain on the NYS list as a threatened species and are also protected by
the federal MBTA and BGEPA. The USFWS is currently finalizing
regulations related to eagle take. We suggest the project sponsors review
that information when available. We may make additional recommendations
regarding these species.
The USFWS is currently coordinating with project team and USACE
regarding effects of the project on the federally-listed Indiana bat. The
project sponsor is preparing a Biological Assessment and we reserve the
1 13 USFWS Stilwell, David right to provide additional comments on the Federally-listed species until
the receipt of a complete BA. We will follow the consultation process (CFR
Part 402) for next steps (Biological Opinion, determination of effects,
recommendations and necessary conservation measures, etc).
In summary, we find that the SDEIS provides some of the information we
requested previously, but other data are missing. We maintain our view that
the report does not contain adequate information regarding potential
impacts of the project on wildlife, and additional environmental review is
necessary. Significant data is lacking for migrating, breeding, and wintering
1 14 USFWS Stilwell, David birds, as well as bats. Importantly, more information is needed on State-
and Federally-listed species use of the project area and how the
construction and operation of the project will affect these species. The
USFWS typically recommends that these studies be conducted over 3
years of project operation and be conducted at all times of the year and
under varied weather conditions.

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003705
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Our previous recommendation to mitigate potential impacts to bats was not
included in the SDEIS. Again, we recommend turbines should not have a
cut-in speed of less than 6 meters per second, and operation should be
curtailed between July 15 and September 15 for 5 hours after sunset. Also,
1 15 USFWS Stilwell, David the project approval should be conditioned upon an adaptive management
plan to address wildlife mortality as a result of turbine operations. A
construction environmental monitoring program should be implemented for
this project. We suggest that the program include a training component for
workers on how to identify and handle injured or dead wildlife.
The SDEIS Section 2.4, page 2-4, states that the project is seeking an
easement from DEC to cross approximately 1.6 miles of the Ashland WMA
with the 115 kV transmission line. Use of the WMA for this purpose requires
authorization by the New York State Legislature and requires DEC
approval. The DEC is not aware of any pending legislative proposals to
2 1 NYSDEC Tomasik, Stephen provide this authorization. Because the timeframe for receipt of
authorization by the state legislature is not able to be determined, an
alternate route may be necessary for the project to move forward in a timely
manner, which may necessitate revision of SDEIS Section 7, Alternatives
Analysis. If the transmission line exceeds 10 miles, DPS approval would be
required.
Define the procedures proposed to cross the Chaumont River with the
overhead transmission line. The Chaumont River is a Navigable Body of
Water, as defined by 6 NYCRR Part 608. Workers/contractors in the river
2 2 NYSDEC Tomasik, Stephen could create a health and safety issue for the workers and the recreational
public. Appropriate measures to ensure the health and safety of the
workers/contractors and recreational public while crossing a navigable body
need to be addressed.
SDEIS Section 4 does not include discussion of the potential for use of the
proposed transmission line by the BP Cape Vincent Wind Power Project,
2 3 NYSDEC Tomasik, Stephen which would be located adjacent to the SLWF and would need to deliver
power to the same substation in the Town of Lyme. This analysis should be
provided.

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003706
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
SDEIS Section 2.6.5, page 2-16, states that although not currently
anticipated, portions of the interconnect could be installed above-ground
when burial would not be economically feasible or could result in significant
2 4 NYSDEC Tomasik, Stephen environmental impacts. More clearly define what situations would meet
these criteria to provide rationale for change. This section includes typical
specifications for installation of underground collection lines. Provide specs
for OH lines also in order that potential impacts, particularly visual, can be
analyzed.
Section 3.1.3.3 includes an outline of proposed karst and geotechnical
investigations, and the role of the environmental monitor is included in
2 5 NYSDEC Tomasik, Stephen Section 3.1.3.4. While this largely conforms to the DEC's previous
recommendations in the June 15, 2007 letter, it is important that results be
made available to assess the adequacy of proposed mitigation measures
identified in Section 3.2.1.3.
A draft SWPPP should have been included in the SDEIS that provides
specifications for best management practices to control contaminants
based on results of the karst and geotechnical investigations. Specifically
lacking is any mention of controlled concrete washout areas at turbine
2 6 NYSDEC Tomasik, Stephen foundation sites, which is imported for preventing concrete slurry from
contaminating groundwater through karst features or surface waters and
wetlands. DEC may require that the SWPPP prepared for the SPDES
permit be reviewed by DEC staff prior to implementation to ensure that
plans for site characterization, project construction, and construction
monitoring have been included and adequately address these concerns.
DEC is concerned that the short-eared owl was not sampled in any of the
bird surveys conducted. In contrast to SDEIS Section 3.3.6.2, DEC has
documented a wild, although cyclic, distribution of the species within the
2 7 NYSDEC Tomasik, Stephen general project area during winter months (see attached maps). Additional
surveys of short-eared owl are recommended both pre-construction and
post-construction to be sure this species' distribution and abundance is
accurately documented. SDEIS should also include 1) short-eared own in
its list of bird species know to inhabit the area 2) short-eared owl in its

3-54

003707
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
wintering bird discussion and 3) short-eared owl listed in Table 1-1.
In reference to Appendix E, page 3, the site visit with the DEC staff
2 8 NYSDEC Tomasik, Stephen mentioned is not valid part of survey/study effort and was not only to
identify roosting locations. DEC requests that this characterization in the
report be corrected.
Based on the information in the SDEIS, it is difficult to predict that raptors
would not have a high risk for collision due to either low recorded numbers
or flight height outside of the rotor swept zone because 1) the numbers
recorded at the Project Area were higher than most other proposed wind
energy projects and 2) there is not enough information collected at the
2 9 NYSDEC Tomasik, Stephen Project Site regarding use by wintering or migrating raptors, especially
during fall migration to make such a conclusion. It is known that the Project
Area lies within one of the most important raptor wintering grounds in New
York State. A more thorough analysis of raptor migration within the Project
Area is needed to support the conclusions made in the SDEIS.

Mortality rates at other wind farms, such as Maple Ridge, should not be
2 10 NYSDEC Tomasik, Stephen used to predict SLWF numbers because avian use of the SLWF Project
Area is higher than all other sites.
SDEIS Section 2.4 states that the total of built project facilities will occupy a
land area of approximately 60 acres. The SDEIS also quantifies impact to
habitat loss by providing the acreage of grassland (41 acres) and second
growth forest (17 acres) that will be affected. However, calculating the total
of temporary and permanent impacts, 14.4 miles of access road
development at 39 feet mean width, 53 tower work spaces at 1.6 acres
2 11 NYSDEC Tomasik, Stephen each, the result is approximately 150 acres of disturbed land area, much of
which may represent existing wildlife habitat. Further discussion is needed
regarding plans for restoration of temporarily affect areas, including the
length of time for restoration (e.g. replaced forest canopy will require much
longer to replace than grassland). Also, any areas that will need to remain
as buffers (e.g., mowed areas along permanent roads) should be calculated
as permanent impacts if these activities represent restoration of viable

3-55

003708
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
wildlife habitat.
2 12 NYSDEC Tomasik, Stephen Revise Table 1-1 of the SDEIS to include consultation with the DEC
regarding T&E species, in addition to consultation with USFWS.
While it is recognized that project development and operation will result in
the perpetuation of some grassland habitat (that might otherwise be lost to
succession if farm were to cease) the direct loss of 150 acres of habitat, at
least on a temporary basis, combined with associated habitat loss due to
avoidance or displacement, at least relative to listed species, will need to be
2 13 NYSDEC Tomasik, Stephen minimized and perhaps mitigated. Pending further clarification and
consultation with DEC with regard to direct and indirect habitat loss due to
construction of this project, the presence of both state endangered and
threatened species utilizing the Project Area may require the issuance of an
Article 11 permit from DEC. The principal condition of this permit would be
to ensure that habitat take impacts, if not avoided, will be mitigated in such
a way as to achieve a "net conservation benefit."
The breeding bird survey conducted for the project according to USGS BBS
protocol are not sufficient; the BBS protocol is designed to estimate trend
data over the long-term, not to fully characterize bird species' occupancy of
2 14 NYSDEC Tomasik, Stephen an area. Due to the presence of significant grassland, endangered, and
threatened species know to be in the area, an additional breeding bird
survey should be conducted according to DEC's Guidelines for Conducting
Bird and Bat Studies at Commercial Wind Energy Facilities.
More complete data need to be obtained in order to support the conclusion
that construction and operation of the proposed Project will likely result in
2 15 NYSDEC Tomasik, Stephen minor, temporary impacts to breeding birds. The Project could contribute to
an increase in the fragmentation of habitat that may result in birds being
displaced from their nesting areas.
Conclusion: The SDEIS and its related additional information with regards
to pre-construction bird and bat studies substantially adds to what was
2 16 NYSDEC Tomasik, Stephen offered in the DEIS. However, several of the related studies, including the
Raptor Migration and Breeding Bird Surveys are still lacking in scope in
comparison to the most recent DEC guidelines for bird and bat pre-

3-56

003709
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
construction studies.
Conclusion: Another concern is that the SDEIS continually cites other
studies of wind projects or data from surveys that are not ecologically
2 17 NYSDEC Tomasik, Stephen similar or even related to the Project Area. The SLWF is located in a region
that has significant grassland bird, raptor, and waterfowl concentration
areas and should not be compared to other potential wind energy projects
that do not support the same natural resources.
DEC agrees that post-construction studies are very important and should
be included as part of the project's required mitigation measures. The
2 18 NYSDEC Tomasik, Stephen SDEIS should further state that based on the results of these studies,
adjustments to the Project's operational configuration and or time-table may
be necessary to affect avoidance or minimization of the take of birds or
bats, with listed species receiving the highest consideration.
In order to adequately assess the potential impacts to the Project Area's
threatened and endangered species, the Project needs to fully characterize
2 19 NYSDEC Tomasik, Stephen seasonal use of the area by these species. As submitted, the SDEIS is
inadequate to allow a thorough evaluation of the potential impacts to these
species.
Subsection 3.1.1.4, p3-13, states that a majority of the area is level and the
drainage pattern is generally in the direction of small streams and creeks
(e.g. Kent's Creek, Fox Creek, Shower Creek, Super Creek, Three Mile
Creek), which discharge directly into the St. Lawrence River. There are a
number of inaccuracies in this description: (1) Kent's Creek (aka Mud
Creek) flows directly into Mud Bay, which is an embayment of Lake Ontario
2 20 NYSDEC Tomasik, Stephen that is approximately 4 miles from the beginning of the St. Lawrence River;
(2) Fox Creek flows directly into Lake Ontario approximately 5.5 miles away
from the beginning of the St. Lawrence River; (3) Shower Creek and Super
Creek do not exist within the Project Area. Shaver Creek, Soper Creek, and
Three Mile Creek flow into Three Mile Bay which flows into Chaumont Bay
and then directly into Lake Ontario approximately 12.2 miles from the
beginning of the St. Lawrence River.

3-57

003710
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Subsection 3.2.2, p3-23, stats that 36 mapped surface water bodies occur
within the Project layout. These include Scotch Brook, Chaumont River,
Kent's Creek, Shaver Creek, Three Mile Creek, Soper Creek and 30
unnamed tributaries. These surface waters are perennial and located within
the Saint Lawrence River Basin. There are a number of inaccuracies in this
description: (1) Scotch Brook is the only one from the listed streams on
page 3-23 that actually flows directly into the St. Lawrence River; (2) Kent's
Creek (aka Mud Creek) flows directly into Mud Bay, which is an embayment
of Lake Ontario that is approximately 4 miles from the beginning of the St.
Lawrence River; (3) Shaver Creek, Soper Creek, and Three Mile Creek flow
into Three Mile Bay which flows into Chaumont Bay and then directly into
Lake Ontario approximately 12.2 miles away from the beginning of the St.
Lawrence River.

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


surface water geography as it relates to the Project Area.
Subsection 3.1.2 states that the proposed project, once built, could
potentially cause a minor alteration to existing drainage patterns (pages 3-
13 to 3-14). A detailed investigation designed to evaluation the potential for
2 21 NYSDEC Tomasik, Stephen long-term alterations to existing drainage patterns should be prepared,
noting that any alterations to the existing drainage patterns, even perceived
minor ones, could have serious effects on current land use patterns,
homes, and the environment.
The methods noted in the SDEIS to avoid impacts to Blanding's turtles
(Subsection 3.3.7) are insufficient to adequately protect Blanding's turtles,
particularly from loss of nesting habitat by turbines and mortality caused by
2 22 NYSDEC Tomasik, Stephen vehicles on roads constructed in nesting areas. Nesting areas are typically
found outside of wetlands. In addition, minimization of impacts to nesting
Blanding's turtles may need to include the restriction of construction
activities to outside of the nesting season.
2 23 NYSDEC Tomasik, Stephen SDEIS Section 2.6.10. DEC recommends that the environmental monitor
be empowered to order correction of acts that violate environmental

3-58

003711
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
regulations and permit requirements, and order the cessation of
construction activities until such corrective action has occurred. The monitor
should also provide regular reports to appropriate involved and interested
agencies, including DEC staff responsible for permitting and technical
review of agency permits. A staff of monitors should be available to provide
coverage at all times the construction activities occur; one monitor may not
be enough to cover extended hours. These provisions will be requirements
on any DEC permits that may be necessary for project construction.
As currently proposed, the project is not substantially located within the
boundaries of the New York State coastal zone. However, its proximate
location and the nature of the proposed activity suggest that coastal effects
3 1 NYSDOS Zappieri, Jeff may be likely. Should further authorization from other federal regulatory
agencies be required or should the USACE decide that the proposed
project would not meet the criteria for a permit issued under the NWP
program, DOS should be notified to determine if a consistency review is
necessary.
The proposed project incorporates transmission lines that traverse portions
of New York's Coastal Zone. Transmission line right-of-way maintenance
activities should not adversely affect any coastal resources. In part, this
3 2 NYSDOS Zappieri, Jeff may be accomplished through a reduced reliance on herbicides, the
establishment of buffer areas adjacent to the Chaumont River, and careful
use of best management practices designed to lessen stormwater impacts
both pre- and post-construction.
Section 2.8.1.4 states that at decommissioning, the transmission line poles
will be sawn flush with the ground unless the "appropriate governing
3 3 NYSDOS Zappieri, Jeff authority" determines that the environmental damage will outweigh the
benefits of removal. This "appropriate governing agency" should be
identified along with suspected environmental damage that would negate
the benefits of removal.
In the Section 2.8.3 discussion of decommissioning, it may be useful to
3 4 NYSDOS Zappieri, Jeff require a performance bond or dedicated fund to be established to ensure
the complete decommissioning of the project.

3-59

003712
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Section 3.2.3.3 should include that all wetland mitigation should be located
within the same sub-watershed as the original disturbed wetland.
Additionally, specific parameters should be established that define what
3 5 NYSDOS Zappieri, Jeff would constitute a successfully established wetland and at what point
guaranteed remedial action would occur, should success parameters not be
met. It may be advantageous to guarantee proper wetland establishment
through bonding or other financial security mechanisms.
Curtailment between July and September should be considered to reduce
impacts to birds and bats. A recent study at the Casselman Wind Power
Project in Pennsylvania indicated that these impacts may be reduced by
3 6 NYSDOS Zappieri, Jeff raising the minimum "cut-in" wind speed necessary to begin turning the
wind turbine. An investigation into the viability of such a procedural shift
may indicate that the benefits derived warrant its implementation. Similarly,
this procedure may be useful to curtail potential effects on the proximate
Significant Coastal Fish and Wildlife Habitats.
Avian use may be affected at the seven Significant Coastal Fish and
Wildlife Habitats (SCFWH) located within 10 miles of the SLWF. Specific
pre-construction characterization of avian uses of the SCFWHs should be
3 7 NYSDOS Zappieri, Jeff required along with sufficient post construction monitoring to quantify any
potential effects. Appropriate provisions for operating procedure adaptation
should be included in the SDEIS if impacts at the SCFWHs become
evident. These and all other wildlife monitoring data should be presented to
all regulatory agencies and made available for public inspection.
Statements within the last paragraph of Section 3.3.7.2 appear to contradict
each other by stating that the project may cause abandonment of an
3 8 NYSDOS Zappieri, Jeff Indiana Bat maternal colony, effects will not be large enough to affect the
maternal colony, and that direct impacts may lead to the loss of the
maternal colony. This language should be clarified to indicate the
paragraph's true intent.
Section 3.4 states that several road closures may be necessary to enable
3 9 NYSDOS Zappieri, Jeff delivery of construction equipment and materials to the project site and that
some routes may necessitate road improvements. These routes should be

3-60

003713
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
planned to ensure that the public's access to the coast is not hindered.
Additionally, the potential may exist to improve the public's access to the
coast by ensuring that necessary road upgrades are constructed in a way
that would relieve traffic congestion or otherwise improve the public's travel
to and from the coast.
Section 3.4.3 discusses mitigation measures to repair highway
infrastructure that may be damaged during construction of the proposed
3 10 NYSDOS Zappieri, Jeff project. It may be advantageous to ensure that proper financial assurance
measures are in place to provide for adequate repair. Roads likely
susceptible to damage also likely provide the public access to the coast and
as such should be maintained in an appropriate fashion.
Section 3.5.1.3 discusses potentially applicable New York State coastal
policies. However, the analysis appears to consider only a small part of the
project's transmission line. Given the project's proximity to the coastal zone,
3 11 NYSDOS Zappieri, Jeff a full analysis of coastal policy should be included in the SDEIS that
considers the potential effects of the entire project on New York Coastal
Resources. Such an analysis should consider all applicable New York State
coastal policies and any applicable policies of the Village of Cape Vincent
Local Water Revitalization Plan.
3 12 NYSDOS Zappieri, Jeff Include the DOS on the distribution list for all future monitoring reports
regarding this proposed project.
The facilities proposed for the SLWF do not trigger Public Service
4 1 NYSDPS Davis, Andrew Commission jurisdiction (nameplate capacity above 80MW, 115 kV line
over 10 miles, or 125 kV over 1 mile).
The PSC encourages wind energy developers to adopt procedures and
practices to minimize conflicts and interruptions of utility services during
wind project construction and operations. The developer should coordinate
4 2 NYSDPS Davis, Andrew with local utility service providers to avoid construction interference of
electric, gas, cable, water, and telecommunications services providers. The
developer is encouraged to join Dig Safely New York UFPO program during
project development to identify proposed locations of underground facilities
in relation to other underground infrastructure and avoid inadvertent

3-61

003714
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
interruptions during excavation. Section 3.6.2.1 does not address
underground utility structures and equipment which may be affected by
road widening or access road construction. Widening roads at intersections
for temporary construction access by oversize vehicles has the potential to
affect buried infrastructure. Project planning and coordination with utilities
should address any underground facilities which may be encountered for
these improvements. Alternative design or access layout adjustments may
be necessary to avoid conflicts with infrastructure.
Discussion of transmission line construction at Section 3.6.2.1 is cursory.
Construction will involve repeated access for clearing, grading, and access
4 3 NYSDPS Davis, Andrew improvement, excavation, pole placement, installation of hardware and
conductors and conductor tensioning. Maintenance of transmission facilities
and vegetation along the right-of-way will require permanent and ongoing
periodic access to the length of the line.
Above-ground poles should be marked with owner identification information
and numbering of poles, pursuant to PSC regulations. DEIS Section 3.6.3
does not address pole marking requirements. Pole marking is important for
4 4 NYSDPS Davis, Andrew notification of the facility operators in event of damages to or emergency
responses involving downed or damaged service lines. Without appropriate
facility marking information, the likely perception in the community will be to
contact the local electric company if a pole is damaged in events such as
automobile accidents, or construction accidents or line encounters.
DPS staff notes that the use of the former railroad corridor for siting a 115
kV transmission line will require access for construction and facility O&M.
The old rail right-of-way includes washed out bridge and culvert crossings
at waterways, which preclude through-access, and which may make
4 5 NYSDPS Davis, Andrew construction access problematic. Access routes should be identified, and
constraints accounted for in project planning and permitting. In addition, the
co-location of electric transmission lines along the corridor of the existing
water lines may have the potential to result in induced voltages on the
water pipeline. Step and touch voltage levels should be estimated, and any
grounding necessary to avoid induced voltages which could induce an

3-62

003715
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
electric shock in someone touching an above-ground water line facility
(such as a hydrant) should be implemented.
Discussion of facility security at Section 3.13.3.2.7 should indicate that clear
4 6 NYSDPS Davis, Andrew zone around the project substation may need to be enlarged beyond the 10
feet cited, to preclude danger tree contact with station infrastructure and
perimeter fencing.
Attached are standard questions and information requests which DPS
poses to major wind project developers. Some of these items are
4 7 NYSDPS Davis, Andrew addressed in the discussion of impacts and mitigation as described in the
SDEIS; however there are additional details which may be relevant for
consideration of the SLWF.
Visual impacts discussion does not address the Seaway Trail-Cape Vincent
Bicycle Look trail (map attached), much of which is open land through
portions of the Project Area. An analysis of visual impacts to the trail,
including photo simulations, should be provided. Some consideration of
4 8 NYSDPS Davis, Andrew cumulative effects of wind energy on state parks and recreation facilities in
the Jefferson County area is warranted. The number of wind turbines which
will be visible from park locations should be noted for the Wolfe Island, St.
Lawrence, Cape Vincent, and Hounsfield Wind projects is like to be
significant. DPS notes that the Wolfe Island wind turbines are visible across
the low-relief areas of the region at distances exceeding 12 miles.
1. Provide a list of engineering codes, standards, guidelines, and practices
that the company intends to conform with when planning, designing,
4 9 NYSDPS Davis, Andrew constructing, operating and maintaining the wind turbines, electrical
collection system, substation, transmission line, interconnection, and
associated buildings and structures.
2. a) Provide a list of the permits, approvals, and permissions the company
will have to obtain to construct, operate, maintain, and retire the wind
4 10 NYSDPS Davis, Andrew turbines, electric collection system, substation, transmission line,
interconnection, and associated buildings and structures. b) Provide an
estimated schedule for the application and receipt of items in item "a"
4 11 NYSDPS Davis, Andrew 3. Provide a Quality Assurance and Control plan, including staffing

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003716
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
positions and qualifications necessary, demonstrating how applicant will
monitor and assure conformance of facility installation with all applicable
design, engineering and installation standards and criteria as indicated in
question 1 above [Comment 4-9].
4. Provide a statement from a responsible company official that: a)
company and its contractors will conform to the requirements for protection
4 12 NYSDPS Davis, Andrew of underground facilities contained in Public Service Law §119-b, as
implemented by 16 NYCRR Part 753; b) company will comply with pole
numbering and marking requirements, as implemented by 16 NYCRR Part
217.
5. Provide plans and descriptions indicating design, location, and
construction controls to avoid interference with existing utility transmission
4 13 NYSDPS Davis, Andrew and distribution systems. Indicate detailed locations and specify design
separations of proposed facilities from existing electric, gas, and
communications infrastructure. Indicate measures to minimize interferences
where avoidances cannot be reasonably achieved.
6. Provide description and indicate details of plans to limit public access
4 14 NYSDPS Davis, Andrew and assure security at substations, collection points, wind energy facilities,
and aboveground components of electrical collection system.
7. Explain how the design and operation of the facility will avoid interference
4 15 NYSDPS Davis, Andrew with radio communications, including cell phones, AM/FM/SW radio,
television, radar, GPS and LORAN, and microwave transmissions.
8. Provide transmission facility design and construction plans, indicating
vegetation clearing and disposal specifications, structure locations, access
4 16 NYSDPS Davis, Andrew requirements, grading and access improvements, and environmental
control measures including storm water and erosion and control practices
and facilities.
9. Provide facility maintenance and management plans, procedures, and
criteria. Specifically, address the following topic:
4 17 NYSDPS Davis, Andrew a) turbine maintenance, safety inspections, and tower integrity;

b) electric transmission, gathering and interconnect line inspections,

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003717
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
maintenance and repairs;
(i) vegetation clearance requirements;
(ii) vegetation management plans and procedures;
(iii) inspection and maintenance schedules;
(iv) notification and public relations for work in public right-of-way;
(v) minimization of interference with electric and communications
distribution plans.
c) vegetation management practices for switchyard and substation yards,
and for danger trees around stations; specifications for clearances;
inspection and treatment schedules; and environmental controls to avoid
off-site effects.
10. If the company will entertain proposals for sharing above ground
4 18 NYSDPS Davis, Andrew facilities with other utilities (communications, cable, phone, cell phone
relays, etc) provide criteria and procedures for review of proposals.
11. Provide emergency response plans, notification and coordination
procedures. Specify plans and procedures for addressing electric line
4 19 NYSDPS Davis, Andrew outages, specification of 24-hours per day storm and emergency response
situations. Include measures for communication and coordination with
operators of existing utility facilities, and residents of adjoining or affected
locations.
4 20 NYSDPS Davis, Andrew 12. Specify commitments for addressing public complaints, and procedures
for dispute resolution during facility construction and operation.
13. Specify commitments for end-of-life facility retirement and
4 21 NYSDPS Davis, Andrew decommissioning, with specific references to electrical gathering and
transmission system, interconnection and substation facilities.
14. Provide switchyard and substation design drawings and site plans,
indicating:
a) property lines and setbacks; access road location, width, and gradient;
4 22 NYSDPS Davis, Andrew site grading, cut and fill, drainage and environment controls; all proposed
improvements and equipment; fencing and gates; permanent erosion
control measures;
b) indicate any station lighting needs, and appropriate design criteria

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003718
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
c) provide a statement indicating that any future lighting will be designed to
avoid off-site lighting effects (i.e., avoid up-light direction except for as-
necessary maintenance task-lighting; avoid drop-down optics to minimize
light trespass);
d) listing of all electrical equipment and specifications for substation and
switchyard facilities;
e) interconnection facility design plan and profile information.
4 23 NYSDPS Davis, Andrew 15. Provide a status report on equipment availability and expected delivery
dates for towers, turbines, transformers, and related major equipment.
16. a) Specify turbine design setback requirements for the following
structures: occupied structures (residences, businesses, and schools);
barns and unoccupied structures; electric transmission lines.
4 24 NYSDPS Davis, Andrew b) Explain the rationale for the setback distances for each type of structure
or facility.
c) Provide a detailed explanation as to why local setback provision from
transmission lines cannot be accommodated in facility layout.
17. Provide an analysis of the electrostatic and electromagnetic fields for
the proposed 115 kV electric transmission line. Include a cross-section
diagram and chart showing the results of the field strength analysis at
4 25 NYSDPS Davis, Andrew average annual and annual maximum conductor current flow (maximum
conductor rating). The cross-section diagram should demonstrate the
electrostatic and electromagnetic field strengths extending horizontally from
facility centerline to a distance of 300 feet.
We have received a request to evaluate properties for potential
historic/cultural significance. The initial request for resource evaluation was
received on October 9, 2007 and consisted of a single-volume report titled
Historic Architectural Survey (1-2 Mile APE) for the St. Lawrence Wind
5 1 NYSOPRHP Bonafide, John Project (October 2007, TRC). This document was supplemented by a
revised and expanded survey document that was received on January 23,
2008 titled Historic Architectural Survey for the St. Lawrence Wind Project
(January 2008 TRC). Our full assessment is attached to this letter as
Appendix A.

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003719
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Within the survey area, this agency has identified several key loci where
visual impacts should be carefully assessed. There areas encompass the
Cape Vincent village area, especially the National Register Listed individual
properties and historic district. Many of these resources may have a direct
visual connection to more than two-thirds of the proposed towers. In
addition, several of the individual rural agrarian properties will be in the view
5 2 NYSOPRHP Bonafide, John shed of a significant number of the proposed towers. Given the
unremarkable topography of this area the potential view shed/setting
impacts associated with these resources should be carefully assessed. All
resources where this office believes additional visual assessments should
be undertaken have been identified in Appendix A with an asterisk (*). We
would recommend that your agency seek to have appropriate visual
simulations generated to better understand the full extent of the potential
visual impacts associated with this project.
Although the full extent of potential impacts from the proposed undertaking
cannot be assessed absent simulations as part of a comprehensive visual
analysis, OPRHP believes that sufficient information does exist to
determine that under Section 14.09 1(c) of New York State Parks and
Recreation Law, the undertaking will have an Adverse Impact on cultural
5 3 NYSOPRHP Bonafide, John resources. The introduction of the sleek, ultra modern, approximately 425-
foot tall kinetic wind turbines (up to 96 proposed) throughout this scenic
landscape forever alters and changes the rural setting, which itself is a
significant element in much of the survey area and serves as the backdrop
for the architectural, cultural, and scenic tourism heritage of these
communities.
We would recommend that the applicant utilize the visual analysis as a tool
to aid in the exploration of feasible and prudent alternatives that avoid the
adverse impact(s). The assessment of potential impact avoidance options
5 4 NYSOPRHP Bonafide, John may include a reduction in turbine numbers and/or height, relocation of
turbine units, and various screening options. We would recommend that
only after an assessment of avoidance options has been established should
potential migration options be discussed. All consultation regarding

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003720
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
avoidance options and potential later mitigation options should involve
those state/federal agencies directly associated with the permitting/approval
process for this project.
At this point in time we have concluded our evaluation of eligible resources
5 5 NYSOPRHP Bonafide, John and the potential impacts to those resources associated with this project.
Please be aware that we will be asking the project sponsor for GPS data
gathered as part of the survey.
Project design has been changed from 97 turbines to 53 and, consequently,
from 136 MW to 79.5 MW. As a result of the redesign, the project may no
longer require the Section 14.09 review of the NYS Public Service
6 1 NYSOPRHP Bonafide, John Commission. However, at this time, we do not know if other state and/or
federal agencies may be involved in this undertaking. Also, please note, our
comments related only to historic/cultural resources. Comments regarding
New York State parkland were submitted separately.
It is our understanding that the remaining 53 turbines are located on sites
previously identified in the original project information. As such, no
6 2 NYSOPRHP Bonafide, John additional topographic assessment or architectural survey was requested
by this office. The Alternatives Analysis and Visual Analysis provided in the
SDEIS would indicate that a number of the previously identified resources
would remain affected even with the turbine field selection.
As noted in the SDEIS, the reduction in the total number of turbines from 97
to 53 is a significant component in minimizing the impacts to historic
properties and is discussed in the sponsor's Alternatives Analysis. While
recognizing the significance of this redesign on the overall impact to the
6 3 NYSOPRHP Bonafide, John region's historic resources that surviving turbine field, nevertheless will
continue to have an adverse effect on historic properties. At this point in
time we encourage the Lead Agency, the project sponsor, and involved
state and/or federal lead agencies to continue to seek opportunities to
explore feasible and prudent alternatives that avoid, minimize, or to mitigate
the adverse impacts.
7 1 NYSOPRHP Lyons, Thomas I am writing on behalf of the State Parks office of the NYSOPRHP.
Comments on the cultural/historic impacts are provided separately by John

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003721
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Bonafide.
The visual impact analysis indicates the project will be visible from three
state parks: Cedar Point, Burnham Point, and Long Point. These three
facilities constitute an important component of the public recreational
amenities in the region and it is quite apparent that this project will have an
7 2 NYSOPRHP Lyons, Thomas adverse impact on these facilities. It is not possible to tell the location where
the line-of-sight confirmations were conducted. We request information on
the specific location, preferable GPS coordinates, for further review. Once
we receive this information, we may request additional photo simulations to
assist in determining potential impacts.
There seems to be an inconsistency in the SDEIS between the photo
simulation in Figure A14b and Table 3-27 which indicates that the "Actual
7 3 NYSOPRHP Lyons, Thomas View" from Cedar Point State Park will be "substantially screened by local
structures or vegetation." It would seem that this should be listed as
"Visibility indicated." Please clarify or provide further information.
7 4 NYSOPRHP Lyons, Thomas We also request further information on the impacts to park patrons of the
required FAA lighting to the nighttime horizon.
Based on the fall raptor migration rates exceeding those of Franklin
Mountain Hawk Watch and given the location of the project along the
northeastern edge of Lake Ontario, large numbers of birds may funnel
7 5 NYSOPRHP Lyons, Thomas through the Project Area during fall migration. State Parks recommends
that post-construction mortality surveys focus particularly on mortality
during migration. If significant mortality is observed, consideration should
be given to reducing operations during peak periods of migration.
State Parks endorses the SDEIS proposal to implement "the minimum FAA
safety lighting requirements." Also with regard to lighting, this agency
requests that the findings within the following two scientific documents be
7 6 NYSOPRHP Lyons, Thomas considered during the preparation of the FEIS: 1) USFWS 2003 Interim
Guidelines to Avoid and Minimize Wildlife Impacts from Wind Turbines.
Wind Turbine Siting Group, and 2) Longcore, Travis, Catherine Rich and
Sidney A. Gauthreaux Jr., 2008.
7 7 NYSOPRHP Lyons, Thomas The DEIS states that there will be shadow flicker less than 10 hrs/year at

3-69

003722
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Burnham Point State Park. Please provide additional information on
impacts associated with shadow flicker including the basis for this estimate
as well as a focus on impacts to recreationists at the State Park.
Table 1-1 of the DEIS states, "The proposed project would generate noise
7 8 NYSOPRHP Lyons, Thomas during construction." State Parks seeks assurances that the project
applicant will confer with us on ways to minimize disruptions to park patrons
during construction.
In closing, State Parks acknowledges the importance of alternative and
7 9 NYSOPRHP Lyons, Thomas renewable energy sources for sustainability but we also recognize the
importance of this agency's mission to protect public resources that are so
important to the quality of the experience for our patrons.
WWNY's experience is that windmill farms can disrupt television signals
and municipalities should have a solid plan to make sure that free over-the-
air TV remains a valuable resource to all citizens now and in the future for
local news, weather, emergency broadcasts, as well as entertaining
programming.
WWNY has reviewed the sections which covered television reception within
the DEIS and SDEIS. We know St. Lawrence Wind Farm contracted
Comsearch for an analysis of the impact on off-air television reception, but
Corbin, James, could not find a date when this study was conducted. Some data is
FOX Program Director incorrect or dated (stations in operation, channel numbers, stations
10 1
Broadcasting and Director of FOX operating digitally, etc) and there are a few statements which we would
Broadcasting challenge based on our engineering knowledge and experience.
As of February 17, 2009 WWNY no longer broadcasts an analog signal. On
that date we also switched our digital broadcasts from UHF channel 35 to
VHF channel 7. It has been our experience that VHF frequencies are more
affected by turbines than UHF frequencies, and contrary to the conclusion
Comsearch makes, digital signals can be affected by intervening structures.
We suspect it relates the physical size of the radio wave-length of a
structure reflects or signal. Reflected signals produce a phenomenon called
multi-path which with may DTV sets or converter boxes makes the signal
appear weak or missing.

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003723
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
We were pleased to read that if project operations impact existing television
coverage SLWF would address and resolve each individual problem. This
is encouraged since all viewers are important to us. It notes further that
mitigation actions could include adjusting existing antennae, upgrading
Corbin, James antenna, or providing cable or satellite systems to affected households. It
FOX Program Director needs to be noted that cable is not a viable action for many residents in our
10 2
Broadcasting and Director of FOX rural area and the Direct Broadcast Satellite services do not carry local
Broadcasting stations. Signal interference from windmills would not make a viewer
eligible for a distant-market Network feed from satellite and distant-market
feeds do not serve the viewer with local news or emergency broadcasts.
Distant Network feeds negatively affect WWNY's ability to serve and
contribute to the North Country.
Menter, Rudin, The SDEIS is not adequate and still fails to address the deficiencies
11 1 & Trivelpiece, Fucillo, Thomas discussed in my letters of June 13, 2007, June 14, 2007 and February 20,
P.C. 2008.
The SLWF is incompatible with the Village and Town of Cape Vincent Joint
Comprehensive Plan of 2004. The plan provides that "Area 8" where the
majority of the Project and much of the unrelated BP wind project will be
Menter, Rudin, sited, consists "mainly of rural residential and agriculture, with scattered
11 2 & Trivelpiece, Fucillo, Thomas commercial and a public school." The plan provides that "development that
P.C. has minimum impact on important resources such as scenic natural vistas,
working landscapes, and tourism assets" should be encouraged, and the
"location of towers...or utility facilities...[which] would have a negative
impact on scenic vistas and tourism assets" should be discouraged. Page
32.
Menter, Rudin, The visual impact analysis is not adequate. The 140 towers from the
11 3 & Trivelpiece, Fucillo, Thomas pending Cape Vincent are not included. The density of wind turbines in the
P.C. town will have a large impact that is not adequately addressed.
Menter, Rudin, The Applicant states that design alternatives for the portion of the
11 4 & Trivelpiece, Fucillo, Thomas transmission substation in the resort district will be evaluated to avoid or
P.C. minimize placement of this facility within this district. The evaluation of
design alternatives must take place as part of the impact statement

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003724
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
process.
Menter, Rudin, The bird and bat studies in the SDEIS are not adequate. Further study is
11 5 & Trivelpiece, Fucillo, Thomas necessary in accordance with NYSDEC Guidelines (expanded study) and
P.C. USFWS 2003 Interim Guidelines.
Menter, Rudin, The raptor surveys are inadequate. The SDEIS downplays the presence of
11 6 & Trivelpiece, Fucillo, Thomas these species. At a minimum, additional seasons of data regarding the
P.C. presence and height of these species is needed before such presence can
be dismissed as "minimal" or outside the "zone of danger."
Menter, Rudin, The presence of the protected species of breeding birds (northern harrier,
11 7 & Trivelpiece, Fucillo, Thomas horned lark, grasshopper sparrow, and vesper sparrow) merits additional
P.C. seasons of study during the SEQR review of this Project.
The Indiana bat analysis in the SDEIS is inadequate. Further study is
required to determine the extent in which this site is used by the Indiana
Bats (as opposed to the two brief sampling events conducted by the
Menter, Rudin, Applicant) and to corroborate the Applicant's theory that the Glen Park
11 8 & Trivelpiece, Fucillo, Thomas cave-based ecology is dying off. Such analysis should not be part of a
P.C. vague future "collaborate process" but must be assessed in an
environmental impact statement. Such consultation and the development of
effective mitigation must occur during the SEQR process to render SEQR
meaningful.
Based upon the presence of multiple threatened and endangered species
of birds and bats and in the immediate vicinity of the site, much more study
is required to adequately assess the impact of the proposed facility on
those species. Such study must be performed prior to construction, as part
Menter, Rudin, of the environmental impact statement for this Project.
11 9 & Trivelpiece, Fucillo, Thomas
P.C. Such impacts must be assessed and mitigated during the SEQR process,
not after it has concluded. These are potential impacts that will likely require
a "taking" permit under both state and federal law, and therefore this is not
some theoretical or fanciful concern. There are many different species of
birds and bats which are lawfully protected and significantly more study is
required in an environmental impact statement to determine whether or not

3-72

003725
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
this site is feasible for this large industrial wind facility.
Menter, Rudin, SDEIS should adequately justify the need for overhead rather than buried
11 10 & Trivelpiece, Fucillo, Thomas power lines and discuss whether overhead lines will actually create more
P.C. impacts to birds than will be avoided in the wetlands.
Menter, Rudin, Coastal consistency - nowhere in the DEIS or SDEIS is there any
11 11 & Trivelpiece, Fucillo, Thomas demonstration that this facility (or any part of it) must be constructed in a
P.C. shorefront location.
Menter, Rudin, The SDEIS states that the Applicant will develop a wetland mitigation plan.
11 12 & Trivelpiece, Fucillo, Thomas Mitigation of impacts to resources such as wetlands is an important part of
P.C. the SEQR process and should be discussed within the SDEIS, not
developed after SEQR is completed.
Group of local citizens hired a noise consultant to evaluate Hessler's noise
analysis of the BP facility (attached to comment letter). Because the same
consultant conducted the analysis for SLWP, we assume the same flaws in
methodology.
(1) Test sites at the noisiest locations resulting in higher ambient noise
level. And the typical residence in Hessler's report is not a typical residence
but a construction trailer on a main road with a storage yard for trucks and
other heavy equipment
(2) Hessler significantly overstated background noise conditions during the
Menter, Rudin, summer by conducting a noise survey during a narrow time period when
11 13 & Trivelpiece, Fucillo, Thomas insect noise would have been at its peak
P.C. (3) Insect noise does not "mask" noise from wind turbines as contended by
Hessler because it is of a substantially higher frequency than wind turbine
sounds.
Schomer showed how a much more accurate ambient level for comparison
is 30 dB, which is much more typical of a rural community like Cape
Vincent.
Based upon the critical ramifications of establishing an erroneous ambient
sound level, it is incumbent upon the Town to more accurately determine
the background sound levels in this community. SLWF's elevated ambient
level of 37 db(A) is neither reasonable nor adequate to protect the citizens

3-73

003726
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
of Cape Vincent from objectionable noise. At a minimum, the Town should
have its own consultant assess background noise levels in Cape Vincent,
the results of which will be important to both pending projects.
Anticipated noise level of the operating facility is also suspect. The
Applicant's study relied upon modeling results obtained utilizing the
manufacturer's (the Applicant's) own sound data rather than actual sound
Menter, Rudin, level data obtained from operating wind farms. The Applicant should
11 14 & Trivelpiece, Fucillo, Thomas compare actual operational noise data from operating facilities with
P.C. manufacturer's data to determine if model results compare with actual
conditions at such facilities, and determine if whether the Applicant's
modeling assesses the frequency and duration of weather-generated
variation from "normal" expected sound levels at such facilities.
Menter, Rudin, The visual impact analysis of impacts to cultural/historic resources is
11 15 & Trivelpiece, Fucillo, Thomas inadequate because it does not consider the total impact of the additional
P.C. 140 proposed turbines for the adjacent Cape Vincent Wind Energy Project.
The SEQR process is meant to be an important tool for analyzing impacts
and mitigation, not a mere procedural impediment or bother. As with the
Menter, Rudin, DEIS, the Applicant relies too much on post-construction studies or future
11 16 & Trivelpiece, Fucillo, Thomas collaborative efforts with state and federal agencies to determine impacts or
P.C. develop necessary mitigation. As Lead Agency, the Planning Board must
ensure that such efforts are part of the SEQR process or that process has
no value whatsoever.
Since my comment letter dated May 22, 2007, I have received copies of the
following documents which are part of the Planning Board's record of this
action:
Menter, Rudin, 1. Memo to "File" from Kris Dimmick, the Town of Cape Vincent's consulting
12 1 & Trivelpiece, Fucillo, Thomas engineer dated 2/11/09 re Comments on January 2009 SDEIS (copy
P.C. attached).
2. 2/12/09 Letter from Todd Mathes, Town of Cape Vincent attorney, to
Richard Cogen, attorney for SLWF regarding the SDEIS completeness
review.
3. Email from Todd Mathes to various representatives of the Applicant

3-74

003727
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
dated 3/20/09 subject "Comments on St. Lawrence SDEIS" and
4. Letter of 3/23/09 from Todd Mathes to Richard Edsall regarding
completeness review of the SDEIS.

These documents support the conclusion that the SDEIS is inadequate, in


particularly regarding the sound analysis. It confirms that the Town's sound
consultant takes issue with portions of the sound analysis. Our FOIL
request to obtain a copy of these comments was denied and we reserve the
right to challenge that denial as a violation of New York's Freedom of
Information Law.

We request that you make the Tocci materials part of the SEQR record in
this action, require the Applicant to modify the SDEIS to make substantive
changes required by Mr. Dimmick (and apparently Mr. Tocci) and require
further analysis of noise impacts after appropriate background levels are
determined. There is no need to rush this important review to accommodate
the Applicant's construction schedule.
The WEST Inc study is likely flawed and did not adhere to the study work
plan. The SLWF is located proximal to one of the largest rivers in North
America and at the base of a large peninsula yet the studies provide little
evidence documenting the large concentrations of birds that would be
expected in this area. Flaws include:
- The study does not characterize avian/bat passage rates proximal to the
shoreline nor over inland areas, as planned in the study plan. Only a
13 1 Old Bird Inc. Evans, William passage rate summing up the whole radar-swept area is provided, most of
which is outside the wind project and another determination of passage rate
from a thin slice of atmosphere from the vertical mode of radar operation,
which was also collected outside the wind project area.
- West located radar equipment 0.5 km (instead of the prescribed 1.5 km
from the river edge. As such, the study provides horizontal passage rate
data where a third of the radar sweep area is over the St. Lawrence River.
The bird activity in this airspace is totally impertinent [sic] for avian impacts
of this wind project and it likely severely biases the results. For example,

3-75

003728
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
lower density (low-altitude) migration over water wouldn't have been
included in the overall passage rate figure whereas higher density overland
migration would have. Why doesn't the SDEIS come out and say that the
radar was only located 0.5 km from the St Lawrence River instead of the
prescribed 1.5 km? Why does this SDEIS incorrectly state that the USFWS
and NYSDEC recommended that the radar be less than 1.5 km away from
the shore when, in fact, these agencies requested that it be "approximately
1.5 km away?
- The passage rate determined from the vertical radar analysis is just a
single small slice of atmosphere adjacent to the project area and doesn't tell
us anything about channeling dynamics or the migration density across the
larger project area.
The West study does provide directional data of targets, which has the
potential to indicate channeling dynamics if carried out properly. But the
directional data they use in their analysis is from targets detected across all
altitudes surveyed. West's inclusion of high-altitude targets in this analysis
13 2 Old Bird Inc. Evans, William will tend to mask any channeling along the shoreline region because such
channeling activity would be primarily at low-altitudes.
The West study does not provide quantification of the relative rates of
passage below turbine height over the water, over the coastal zone, or over
the inland regions -- data that would help substantiate whether channeling
along the lakeshore was occurring.
For various reasons, the preconstruction radar study for this wind project
was not as productive as it could have been. What this means is there is a
lot less certainty in any forecast for impact to night migrating songbirds,
13 3 Old Bird Inc. Evans, William which so far appear to compose more than 80% of fatalities in eastern
North American wind projects. I think the SDEIS and the West radar study's
predictions of inconsequential collision impacts to birds are without solid
basis. The avian collision impact is potentially much higher than is
suggested by the SDEIS and West.
13 4 Old Bird Inc. Evans, William I have conducted nocturnal migration research in the region of the St.
Lawrence wind project using acoustic monitoring of avian flight calls. While

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
my data suggest channeling dynamics in the region and unusual avian
concentration dynamics due to the peninsular location of this wind project, it
is clear that more research needs to and could be conducted to understand
these complex nocturnal migration dynamics with regard to reducing the
avian impact of wind projects in the region. What is needed is a study with
multiple nocturnal monitoring methodologies that can monitor the
atmospheric stratum below turbine height of multiple sites. Such a study
would help site turbines in areas that would have less nocturnal migration
traffic below turbine height, and theoretically less collision risk. Such a
study is worth consideration by all parties as wind turbine development in
this region is a long-term prospect.
While the West radar study has serious flaws and could have been carried
out more productively, the NYSDEC bears some responsibility for making
sure than the preconstruction studies are on track to be productive. The
preconstruction studies for the SLWF wind project were designed and
13 5 Old Bird Inc. Evans, William carried out before the NYSDEC guidance on wind power development were
finalized and fully thought out. It should be noted that avian impact at wind
projects is a learning process for all involved. The wind industry is the
primary proponent (and receiver of significant public $ stimuli). As such, it
has to bear a major burden for compliance with the full spectrum of public
service surrounding wind projects, including environmental impact.
I have conducted an acoustic monitoring avian night migration study
approximately 1 km west of the intersection of Rosiere Rd and Millens Bay
Road, approximately 1 km south of the SLWF, rough the same distance as
the West radar equipment was from the wind project area. The breeding
bird survey should also consider the following five species based on my
13 6 Old Bird Inc. Evans, William study, which recorded multiple flight calls of these species in the first week
of June 2007: Black-crowned night heron, least bittern (NYS Threatened),
Virginia rail, whip-poor-will (NYS Special Concern), and grasshopper
sparrow (NYS Special Concern). The site where these species were
recorded was simply an open field area. For most of these species, this
suggests they were flying about at night in regions outside of their preferred
feeding and nesting habitat. The fact that three of these species are

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
associated with wetlands suggests that they are breeding within (or in the
near vicinity) of the SLWF. I am happy to provide this data to SLWF and the
agencies.
The SDEIS does not contain enough data to support the conclusions made
in the SDEIS. For example, the Second Atlas of Breeding Birds in New
York State identifies Cape Vincent as having significant concentrations of
Onondaga bird species that are Threatened and Special Concern in New York State.
14 1 Riley, Thomas
Audubon The atlas is a culmination of five years of fieldwork by thousands of
volunteers across the state. The SDEIS does not report the same avian
concentrations. We believe this is because the fieldwork for the SDEIS was
not adequate in duration and expertise.
We are very concerned that the project will adversely impact breeding,
migrating, and wintering patterns and behavior on the project site and
Onondaga surrounding area for the following Threatened and Species of Special
14 2 Riley, Thomas Concern that occur in the project area: northern harrier, short-eared owl,
Audubon
rough-legged hawk, whip-poor-will, and grasshopper sparrow (contrary to
the SDEIS conclusion, there is no evidence that this species would benefit
from the project).
The environmental impact statement attempts to discount those concerns
with the citing of minimal studies. Considering the variety of weather and
Onondaga other natural cycles there was not enough study of the bird populations to
14 3 Riley, Thomas
Audubon be confident of the recommendations. We would request that at least two
additional years of avian studies be conducted before another
environmental impact statement is considered for review.
For all the assurances in the SDEIS, the operator does not know what
damage will be done to the bird species on this site. The impact of this
Onondaga project on the welfare of birds in the region and the state is so critical that
14 4 Riley, Thomas we should insist that all comments in the study be based on scientifically
Audubon
acquired data. Referencing other studies and the proposed wind projects
that do not have a historical basis for their data should be discounted and
removed from the report.
14 5 Onondaga Riley, Thomas Any wind power project that gets approved and built should include post-

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Audubon construction studies. For this unique site it is critical that the science be
done now, not after the facilities are built and the damage to the avian
resources is done.
Onondaga In conclusion we ask you to recommend that this site not be approved for
14 6 Riley, Thomas
Audubon wind power projects.
We have talked with DEC employees watching for short-eared owls by our
Bell, Dolores and house over the past few years. They've seen as many as seven owls at one
15 1 time. If those doing the SDEIS failed to find any of these owls they must be
Michael
either incomplete or negligent and it should call into question their credibility
on other aspects of the SDEIS.
Two years ago, Clif Schneider did a sound level study at our home. Sound
levels he recorded were much lower than background levels assumed in
the SDEIS. The ambient sound test for the SDEIS is not a correct
representation of typical non-participating residents because the testing
Bell, Dolores and positions were located in noisy areas (near a construction site, near the
15 2
Michael largest dairy in town, near working farms, near busy highway, one near a
farm and a road). We are a farming and a resident community. To achieve
a limit of no more than 5 dBA above ambient sound at our home we think
setbacks need to be at least 3500 feet. Assurances that non-participating
residents will be protected need to be made before development proceeds.
In reference to low frequency noise, independent studies show it adversely
affects young children and the elderly. There needs to be further studies
into that. We did not find reference to this problem in the SDEIS. Please
reference World Health Organization (WHO) Lares final report Noise effect
Bell, Dolores and Morbidity by Dr. Niemann and Dr. Maschke
15 3
Michael (http://www.who.int.docstore/peh/noise/guidelines2.html) on page 8 refers
to the nervous and cognitive systems and on page 14 it refers to noise and
sleep disturbances, let alone other health problems. Science suggests that
Fiber acoustic disease may be attributed to windmills, so further research
needs to be done here too.
Bell, Dolores and The SDEIS report claims shadow flicker will affect up to 2,700 feet. There
15 4
Michael are 10 proposed turbine sites within this distance of our house. We have

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
bedroom windows facing east without shades, frequently watch the sunset
out the western windows, and spend a lot of time outdoors. We will be
subjected to shadow flicker thought the day.
Bell, Dolores and Under the complaint resolution it is very vague and no true resolutions are
15 5 listed. Fill out the paperwork and wait. It doesn't give any time constraints
Michael
for true resolution.
A concern to be included in the complaint resolution in the complaint
resolution would be for the wind farm, it's developer and participating
Bell, Dolores and landowners to put up a bond to purchase properties from non-participating
15 6
Michael owners of adjacent windmill property owners if adjacent windmill property to
remediate any problems, if adversely affected by the "effects" of the
windmills and unable to sell on the open market.
There are no mitigation measures for shadow flicker or sound levels in the
Bell, Dolores and report. In fact, the use of buffer zones is the primary protection for ice shed
15 7
Michael and blade failure. We think buffer zones should be at least 3,500 feet to
avoid problems with shadow flicker and sound levels.
Also, under the mediation measure it needs to state that if within 18 months
Bell, Dolores and a non-participating resident deems that the developer denies them health,
15 8
Michael safety, or well-being, the wind farm, its developers, and participating
landowners would purchase property at pre-development market value.
It's not the responsibility of this board to assess the wind power industry's
Bell, Dolores and affect on global warming based on questionable science or the financial
15 9 viability of the industry without government subsidies. It is this board's
Michael
responsibility to regulate development based on its effect on the health,
safety, and general welfare of the public of this community.
Bell, Dolores and We think the SDEIS should be rejected due to its obvious lack of credibility
15 10 and apparent attempt to deceive and a moratorium be placed on
Michael
development until these concerns can be more adequately addressed.
Bell, Dolores and We started building our home over 5 years ago. If we know then what we
15 11 knew now we wouldn't have built our home here. The public officials did us
Michael
a disservice by not letting us know of the proposed windmills.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
The poles used for the overhead 34.5 kV and 115 kV transmission lines can
cause interference with agriculture operations when located on farmland.
16 1 Boss, Mark As a result, the Department [NYS Ag & Mkts] recommends that the 34.5 kV
lines be buried in agricultural fields. Why are you not burying the lines in
farmland?
In paragraph 2.6.2 St. Lawrence Wind states that in active agricultural
areas, agricultural protection measures in accordance with the guidelines of
16 2 Boss, Mark the NYS Ag & Mkts will be followed and the cable will be placed at a
minimum depth of 48 inches or 6 inches beyond the depth of bedrock. NYS
Ag & Mkts says that at now time [sic] will the depth be less than 24 inches
below the soil surface. Is it 24 inches or 6 inches?
Concerns regarding impacts of bedrock excavation on water resources.
There is no indication that any fieldwork has been done to establish major
springs and their use or flow prior to construction, thus no baseline to
16 3 Boss, Mark measure the impact of construction. Nor is there any information on wells
and springs within 500 feet of where blasting will occur. Will this information
be included in the FEIS? Also, what is St. Lawrence Wind's plan to provide
citizens with potable water if well problems occur?
St. Lawrence Wind does not say if the concrete will be mixed on site or
hauled in from off site. In either case will the FEIS include a description of
16 4 Boss, Mark specific processes that will be implemented to ensure the concrete is
handled properly during construction to limit the impacts to surface waters,
wetlands, and underground waters, given the existence of karst topography
in the project area?
St. Lawrence Wind states that the final overhead transmission line right-of-
16 5 Boss, Mark way will be identified post-construction on as-built drawings which will be
filed with the Towns of Cape Vincent and Lyme. Why not be identified pre-
construction?
Why doesn't the decommissioning plan include the long distance
16 6 Boss, Mark transmission lines? What is the plan to ensure that there are sufficient
funds available to execute the plan? If it includes bonding, which I favor,
how will that bonding follow to successive owners?

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
What are the migratory patterns of the herons and how do they fly when
17 1 Boss, Sarah they are migrating? How long do they stay in Cape Vincent? When do they
arrive and when do they depart? Why isn't this addressed in the DEIS?
17 2 Boss, Sarah Impacts of shadow effect on wildlife should be part of the DEIS.
17 3 Boss, Sarah Individuals, guides, and town must be compensated if towers result in loss
of fishing revenues.
17 4 Boss, Sarah SLWF needs to establish who the environmental monitor works for and how
he/she sends reports to.
The development of a long-term environmental management plan should
be considered to incorporate plans for restoration of environmental impacts
17 5 Boss, Sarah during the following construction [sic], environmental considerations to be
included in the ongoing maintenance facility, a contingency plan to assess
and minimize environmental impacts during major repairs, and assessment
and mitigation of environmental impacts during decommissioning process.
17 6 Boss, Sarah It is important to know the impacts of shadow effect on the fish in the water.
How can the impact on wells and springs be evaluated if there is now
baseline for the springs or wells? Fieldwork should be done to establish
17 7 Boss, Sarah major springs and their use or flow prior to construction. I would like to see
identification of all wells and springs within 500 feet of where blasting will
occur. Also address the steps to be made to provide citizens with potable
water if problems occur.
17 8 Boss, Sarah The project may require an Article 24 Freshwater Wetland Permit and
Section 401 Water Quality Certification.
Since issues regarding potential medical problems related to wind turbines
17 9 Boss, Sarah come up with proposals around the state, it would seem appropriate to
include a section on medical issues in the DEIS.
Critical information is needed to evaluate potential impacts resulting from
17 10 Boss, Sarah the project not performed as part of the DEIS. The DEIS should be updated
to include: geotechnical field data, groundwater studies, wetland field
survey, and hydrogeological balance study based upon long-term runoff. By

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
omission of this information during the design and review stage with a
disclaimer that it will be obtained "prior to construction" the developer
avoids all accountability from the Lead Agency, involved agency, and public
comment.
At best the studies to date may be considered pilot efforts requiring 3-5
17 11 Boss, Sarah years of intense further studies of many groups before any consultation of
value may be drawn.
Are you and the Audubon Society aware of the IBA (Important Bird Habitat)
17 12 Boss, Sarah on Pleasant Valley Road? How will it be affected? What does Audubon
say?
17 13 Boss, Sarah The lease with SLWF takes away landowners' constitutional rights to sue
for punitive damages and the right to jury trial. Why is this acceptable?
Section 2.6.4 of the SDEIS needs to include a description of specific
processes that will be implemented to ensure the concrete is handled
17 14 Boss, Sarah properly during construction to limit the impacts to surface waters,
wetlands, and underground waters, given the existence of karst topography
in the project area.
The report should specifically state that the habitat type located at
17 15 Boss, Sarah Chaumont Barrens and Three Mile Creek will not be impacted by the
project.
Section 3.2 shows that no biotic or water quality data is provided but this
17 16 Boss, Sarah information should be included in the report along with a discussion of
potential impacts from project construction.
Section 3.3 of the DEIS does not identify if the wind project will impact to
17 17 Boss, Sarah establish [sic] the St. Lawrence Wetland and Grassland Management
District (SLWGMD). Nor does it mention if it is compatible with the
SLWGMD.
Section 3.3.6 NYS Fish and Wildlife strongly recommend that the Smith
17 18 Boss, Sarah (2007) be considered by the project sponsor in siting the project features
[sic].
17 19 Boss, Sarah Section 3.3.6 NYS Fish and Wildlife found insufficient data exists to

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
adequately conduct a risk assessment and predict wildlife mortality for this
project.
The DEIS falls short of providing the necessary information in a
17 20 Boss, Sarah comprehensive manner. The DEIS states that additional data on wildlife
use and potential impacts is forthcoming. NYS Fish and Wildlife will review
this information prior to making a final determination.
The SDEIS states that SLWF will meet the setbacks required by the
Planning Board of Cape Vincent. These setbacks are 1,500 feet from the
18 1 Boss, Sarah Village of Cape Vincent boundary line, 1,000 feet to a non-participating
property line, 1,250 feet to a non-participating residence, and 750 feet to a
participating residence. These are inadequate for the safety of our
residents. I request that you require changes to these setbacks.
Commentary regarding the impact on health and safety from the wind
18 2 Boss, Sarah turbines. It is bordering on a crime to even consider that some residents will
be forced out of their homes due to inability to live with conditions caused
by the location of their turbines to their homes.
The monies the town acquires from the PILOT will be eaten up by the loss
18 3 Boss, Sarah of revenue from property taxes. Properties will decrease in value due to the
turbine industry. Commentary regarding negative impacts to the community
from the wind project.
The SDEIS is incomplete and not adequate for public comment and should
not have been accepted by the Town of Cape Vincent Planning Board.
Dramatic adverse impacts are proposed in the SDEIS without adequately
19 1 Bragdon, Brooks describing these impacts. There is no discussion to avoid adverse impacts;
there is no mention of alternate sites for the turbines, and no opportunity for
interested parties such as myself to communication concerns and
suggestions about the adverse impacts.
A letter dated May 28, 2008 from John A Bonafide of the NYS Historic
Preservation Office to Andrew C Davis of the NYSDPS advises that the
19 2 Bragdon, Brooks project shall result in adverse impacts, that "visual analysis be used to
explore alternatives to avoid the adverse impacts, suggests discussion of
relocation of the turbine units as well as a reduction in height and the

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
number of turbines. Only after potential avoidance options have been
established should mitigation measures be discussed and this
communication should involve supervision state and federal agencies.
There is no such communication in the SDEIS.
Objections to the location of turbines near the two roads leading into Cape
Vincent, NYS Route 12 from Chaumont and from Clayton. These turbines
should be moved back considerably in order to preserve the basic assets of
the community. The project will jeopardize the historic preservation
19 3 Bragdon, Brooks designation of my home and my real estate development company. The
project will adversely affect the historic and cultural significance of the
community. Setbacks from the main roads leading into the community,
away from the St. Lawrence River, and from the village and historic
properties are essential to preserve the culture of the community.
A large percentage of the property tax assessment base is made up of
19 4 Bragdon, Brooks waterfront and water view properties and would be adversely affected by
the imposition of the economic will of a minority of the tax assessment
base.
20 1 Bragdon, Brooks Who negotiates PILOT payments for our town is not addressed.
20 2 Bragdon, Brooks What is the estimated cost per kilowatt hour produced for the first year of
the project, first five years, and the first 10 years?
There is no mention of Payment, Performance, and Maintenance Bonding
for this project. If the project is not bonded, neither the towns nor
20 3 Bragdon, Brooks leaseholders have any guarantee that promises will be kept, construction
completed, payments made, maintenance done, and dismantling
completed.
Most DEISs I have reviewed for wind power projects include the results of a
20 4 Bragdon, Brooks Job and Economic Development model. None was referenced in this DEIS
so it appears that the Socioeconomics section was based upon
assumptions.
20 5 Bragdon, Brooks There is insufficient documentation to back up the claim that downsizing the
project is not considered an economically viable solution.

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Since turbines are considered a utility then shouldn't the land on which they
20 6 Bragdon, Brooks are placed by assessed as industrial use and taxed accordingly and not
taxes as agriculture?
I am concerned that the DEIS does not adequately address who will
20 7 Bragdon, Brooks compensate businesses and individuals if the proposed wind project results
in loss of fishing revenues.
20 8 Bragdon, Brooks How will historic designated properties near towers be compensated?
20 9 Bragdon, Brooks How does SLWF plan to compensate Indigenous Americans if Indian burial
grounds are discovered?
20 10 Bragdon, Brooks Why no mention of Dodge Bay in the historical Architecture Resource
Investigation section of the DEIS/Supplemental?
The SDEIS is incomplete and not adequate for public comment and should
not have been accepted by the Town of Cape Vincent Planning Board.
Dramatic adverse impacts are proposed in the SDEIS without adequately
20 11 Bragdon, Brooks describing these impacts. There is no discussion to avoid adverse impacts,
there is no mention of alternate sites for the turbines, and no opportunity for
interested parties such as myself to communication concerns and
suggestions about the adverse impacts.
A letter dated May 28, 2008 from John A Bonafide of the NYS Historic
Preservation Office to Andrew C Davis of the NYSDPS advises that the
project shall result in adverse impacts, that "visual analysis be used to
explore alternatives to avoid the adverse impacts, suggests discussion of
20 12 Bragdon, Brooks relocation of the turbine units as well as a reduction in height and the
number of turbines. Only after potential avoidance options have been
established should mitigation measures be discussed and this
communication should involve supervision state and federal agencies.
There is no such communication in the SDEIS.
Objections to the location of turbines near the two roads leading into Cape
20 13 Bragdon, Brooks Vincent, NYS Route 12 from Chaumont and from Clayton. These turbines
should be moved back considerably in order to preserve the basic assets of
the community. The project will jeopardize the historic preservation

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
designation of my home and my real estate development company. The
project will adversely affect the historic and cultural significance of the
community. Setbacks from the main roads leading into the community,
away from the St. Lawrence River, and from the village and historic
properties are essential to preserve the culture of the community.
The SDEIS is grossly incomplete. It should be returned to the developer to
be redone. The rights of interested parties in the community must be
respected. In my view, turbines may be allowed but in an area away from
20 14 Bragdon, Brooks unique community assets. Should I personally suffer economic loss as a
result of having my rights under the SEQR review process suppressed I
shall be obliged to defend myself legally in order to reverse any economic
losses I should suffer.
I am writing to clarify my comments on the SDEIS in regard to setbacks
[Comments 19.3 and 20.13]. The setbacks I proposed are intended to be
consistent with the Introductory Provisions of the Cape Vincent Zoning Law
which calls for the following: protecting existing development while
protecting the existing assets of the community, conserving property
values, minimizing negative environmental impacts of development,
protecting visually and environmentally sensitive areas such as viewsheds
along the lake and river, protecting scenic views and agricultural lands,
protecting historically significant land and buildings, allowing landowners to
20 15 Bragdon, Brooks make beneficial economic use of their land provided that such uses are not
harmful to neighboring properties.
I maintain that no turbines should be allowed on the lake side of or near
Route 12 from Cape Vincent to Chaumont and also not near Route 12 from
Cape Vincent to Clayton. Rather the turbines should be setback sufficiently
to protect the basic scenic sense and spirit of the community. This setback
may be variable depending on the landscape, but a starting point for
discussion would be 4000 ft inland from Route 12. The development should
fit in with the community, not vice versa. Interested parties in the community
must be allowed the right to have input into the SEQR review process and
any analysis of adverse effects and proposals to mitigate.

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
The SDEIS is a dishonest document which avoids moving the turbines to
reasonable locations. If the project is allowed as proposed it would harm
20 16 Bragdon, Brooks the majority tax assessment comprised of waterfront and waterview
properties in favor of the minority interests of the relatively modest number
of landowners who have contracts for turbines.
Any turbines allowed should be setback so as to not change this unique
and lovely community. Views should be protected. The spirit of the
21 1 Brown, Mary Jane community should not be ruined. The SEQR process is not being carried
out fully and there has been no opportunity for input into the approval
process.
The proposal has too many turbines dominating the landscape. This would
22 1 Burpee, Edith destroy the community particularly together with the other proposed project.
Any turbines allowed should be setback so as not to damage the loveliness
of the community setting along the St. Lawrence River.
Commentary objecting to misinformation about the adverse impacts from
wind projects that have been suggested in other comments. My opinion is
that there are people in our community that just do not want wind power in
23 1 Burton, Darrell the area. I have observed the members of our planning board in action
since this project started. I believe you all have been very open minded and
conducted business properly. I think the results of the SDEIS are an
adequate report.
Commentary supporting the wind energy project and the benefits of wind
energy as opposed to other forms of energy production. Commentary
24 1 Burton, Marlene objecting to misinformation about the adverse impacts from wind projects
that have been suggested in other comments. I truly believe Tom Rienbeck,
Rich Edsall, and the Board Members are doing an honest, legally,
thankless job and should be applauded for the work they have done.
The poles used for the overhead 34.5 kV and 115 kV transmission lines can
cause interference with agriculture operations when located on farmland.
25 1 Byrne, Tatyana As a result, the Department [NYS Ag & Mkts] recommends that the 34.5 kV
lines be buried in agricultural fields. Why are you not burying the lines in
farmland?

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
In paragraph 2.6.2 St. Lawrence Wind states that in active agricultural
areas, agricultural protection measures in accordance with the guidelines of
25 2 Byrne, Tatyana the NYS Ag & Mkts will be followed and the cable will be placed at a
minimum depth of 48 inches or 6 inches beyond the depth of bedrock. NYS
Ag & Mkts says that at now time [sic] will the depth be less than 24 inches
below the soil surface. Is it 24 inches or 6 inches?
Concerns regarding impacts of bedrock excavation on water resources.
There is no indication that any fieldwork has been done to establish major
springs and their use or flow prior to construction, thus no baseline to
25 3 Byrne, Tatyana measure the impact of construction. Nor is there any information on wells
and springs within 500 feet of where blasting will occur. Will this information
be included in the FEIS? Also, what is St. Lawrence Wind's plan to provide
citizens with potable water if well problems occur?
St. Lawrence Wind does not say if the concrete will be mixed on site or
hauled in from off site. In either case will the FEIS include a description of
25 4 Byrne, Tatyana specific processes that will be implemented to ensure the concrete is
handled properly during construction to limit the impacts to surface waters,
wetlands, and underground waters, given the existence of karst topography
in the project area?
St. Lawrence Wind states that the final overhead transmission line right-of-
25 5 Byrne, Tatyana way will be identified post-construction on as-built drawings which will be
filed with the Towns of Cape Vincent and Lyme. Why not be identified pre-
construction?
Why doesn't the decommissioning plan include the long distance
25 6 Byrne, Tatyana transmission lines? What is the plan to ensure that there are sufficient
funds available to execute the plan? If it includes bonding, which I favor,
how will that bonding follow to successive owners?
25 7 Byrne, Tatyana Will the geotechnical investigation, necessary for project construction and
design, be included in the FEIS?
25 8 Byrne, Tatyana 3.1.3.3 In this paragraph, SLWF does not mention the use of an
environmental monitor. In order to provide proper oversight of these

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
activities it is important that an environmental monitor be onsite for all pre-
construction survey and any construction activities that involve excavation
to bedrock or are located in proximity to known karst features. Will an
environmental monitor be present?
25 9 Byrne, Tatyana 3.2.3.3 The discussion on soil is too general. Each turbine site, access
road, electric line pole, and substation needs a soil map.
25 10 Byrne, Tatyana 3.4.2 Will the comprehensive transportation study, delivery routes, and
crane assembly areas be part of the FEIS?
3.9.1 There is no discussion of the impact of the turbines on the ozone level
25 11 Byrne, Tatyana which is already out of compliance with EPA guidelines. What is the impact
and if so, how will you mitigate?
3.11.3 To mitigate impacts to local roads during construction, any
construction-related damage or improvements to roads would be the
25 12 Byrne, Tatyana responsibility of the Applicant and would be undertaken at no expense to
the municipalities. How long after project completion is this going to
continue.
3.13.1.2 The study used in the discussion if ice shedding (Morgan,
25 13 Byrne, Tatyana Bossanyi, and Siefert, 1998) is an 11-year old study. Why aren't you using
a more recent one?
4.1.3.2 This section indicates that white nose syndrome will have a greater
25 14 Byrne, Tatyana cumulative effect on Indiana bats than the wind energy development. What
is the cumulative impact of both white nose syndrome and wind turbines on
Indiana bats?
25 15 Byrne, Tatyana 4.1.11.2 Since the housing market has changed so dramatically since 2007
why haven't you done a more recent "housing value study."
7.2 This section states that the Project will meet all of the following
setbacks required by the Planning Board of Cape Vincent. Are these
25 16 Byrne, Tatyana current?
- 1500 feet from Village of Cape Vincent boundary line
- 1000 feet to a non-participating property line
- 1250 feet to a non-participating residence

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
- 750 feet to a participating residence
25 17 Byrne, Tatyana 7.6 Table 7-1. What compensation are the three non-participating
homeowners with over 48 db going to get?
25 18 Byrne, Tatyana Appendix E. The avian and bat study was conducted in one year. Why
didn't you do a multi-year study?
25 19 Byrne, Tatyana Appendix E1. The bat studies were done with radar. Why not also sonar?
Appendix E1. In this Appendix SLWF says that there is no statistical
evidence that Indiana Bats are in the project area, but Appendix E3 Section
3.0 July Aug 2007 states that four were captured and tracked. Appendix E6
25 20 Byrne, Tatyana July Aug 2007 1.0 states that six captures Indiana bats were radio tracked
and roost sites were identified in the project area [sic]. Appendix E4 June
2008 states that no Indiana bats were captured during that study. Appendix
F3 says they are present. Are there Indiana bats in the project area or not
and if there are, what mitigation actions will you take?
25 21 Byrne, Tatyana Appendix E3 is labeled Blanding Turtle but reports on bats.
25 22 Byrne, Tatyana Appendix E7. Which of the Blanding Turtle mitigation recommendations will
be adopted and which will not and why not?
25 23 Byrne, Tatyana Appendix J. What will you do to mitigate shadow flicker if your analysis is
wrong?
25 24 Byrne, Tatyana Appendix L. The data in Table 2.2.1 does not match the data from our paid
consultant (elaborate).
25 25 Byrne, Tatyana Appendix L.3.6 The negative impacts of low frequency sound are dismissed
as corrected by design change. Where is the medical data?
25 26 Byrne, Tatyana Appendix N2. Who pays to mitigate the loss of TV signals in the project
area?
What are the migratory patterns of the herons and how do they fly when
25 27 Byrne, Tatyana they are migrating? How long do they stay in Cape Vincent? When do they
arrive and when do they depart? Why isn't this addressed in the DEIS?
25 28 Byrne, Tatyana Impacts of shadow effect on wildlife should be part of the DEIS.

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
25 29 Byrne, Tatyana Individuals, guides, and town must be compensated if towers result in loss
of fishing revenues.
25 30 Byrne, Tatyana SLWF needs to establish who the environmental monitor works for and how
he/she sends reports to.
The development of a long-term environmental management plan should
be considered to incorporate plans for restoration of environmental impacts
25 31 Byrne, Tatyana during the following construction [sic], environmental considerations to be
included in the ongoing maintenance facility, a contingency plan to assess
and minimize environmental impacts during major repairs, and assessment
and mitigation of environmental impacts during decommissioning process.
25 32 Byrne, Tatyana It is important to know the impacts of shadow effect on the fish in the water.
How can the impact on wells and springs be evaluated if there is now
baseline for the springs or wells? Fieldwork should be done to establish
25 33 Byrne, Tatyana major springs and their use or flow prior to construction. I would like to see
identification of all wells and springs within 500 feet of where blasting will
occur. Also address the steps to be made to provide citizens with potable
water if problems occur.
25 34 Byrne, Tatyana The project may require an Article 24 Freshwater Wetland Permit and
Section 401 Water Quality Certification.
Since issues regarding potential medical problems related to wind turbines
25 35 Byrne, Tatyana come up with proposals around the state, it would seem appropriate to
include a section on medical issues in the DEIS.
Critical information is needed to evaluate potential impacts resulting from
the project not performed as part of the DEIS. The DEIS should be updated
to include: geotechnical field data, groundwater studies, wetland field
25 36 Byrne, Tatyana survey, and hydrogeological balance study based upon long-term runoff. By
omission of this information during the design and review stage with a
disclaimer that it will be obtained "prior to construction" the developer
avoids all accountability from the Lead Agency, involved agency, and public
comment.
25 37 Byrne, Tatyana At best the studies to date may be considered pilot efforts requiring 3-5

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
years of intense further studies of many groups before any consultation of
value may be drawn.
Are you and the Audubon Society aware of the IBA (Important Bird Habitat)
25 38 Byrne, Tatyana on Pleasant Valley Road? How will it be affected? What does Audubon
say?
25 39 Byrne, Tatyana The lease with SLWF takes away landowners' constitutional rights to sue
for punitive damages and the right to jury trial. Why is this acceptable?
Section 2.6.4 of the SDEIS needs to include a description of specific
processes that will be implemented to ensure the concrete is handled
25 40 Byrne, Tatyana properly during construction to limit the impacts to surface waters,
wetlands, and underground waters, given the existence of karst topography
in the project area.
The report should specifically state that the habitat type located at
25 41 Byrne, Tatyana Chaumont Barrens and Three Mile Creek will not be impacted by the
project.
Section 3.2 shows that no biotic or water quality data is provided but this
25 42 Byrne, Tatyana information should be included in the report along with a discussion of
potential impacts from project construction.
Section 3.3 of the DEIS does not identify if the wind project will impact to
25 43 Byrne, Tatyana establish [sic] the St. Lawrence Wetland and Grassland Management
District (SLWGMD). Nor does it mention if it is compatible with the
SLWGMD.
Section 3.3.6 NYS Fish and Wildlife strongly recommend that the Smith
25 44 Byrne, Tatyana (2007) be considered by the project sponsor in siting the project features
[sic].
Section 3.3.6 NYS Fish and Wildlife found insufficient data exists to
25 45 Byrne, Tatyana adequately conduct a risk assessment and predict wildlife mortality for this
project.
The DEIS falls short of providing the necessary information in a
25 46 Byrne, Tatyana comprehensive manner. The DEIS states that additional data on wildlife
use and potential impacts is forthcoming. NYS Fish and Wildlife will review

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
this information prior to making a final determination.
25 47 Byrne, Tatyana Who negotiates PILOT payments for our town is not addressed.
25 48 Byrne, Tatyana What is the estimated cost per kilowatt hour produced for the first year of
the project, first five years, and the first 10 years?
There is no mention of Payment, Performance, and Maintenance Bonding
for this project. If the project is not bonded, neither the towns nor
25 49 Byrne, Tatyana leaseholders have any guarantee that promises will be kept, construction
completed, payments made, maintenance done, and dismantling
completed.
Most DEISs I have reviewed for wind power projects include the results of a
25 50 Byrne, Tatyana Job and Economic Development model. None was referenced in this DEIS
so it appears that the Socioeconomics section was based upon
assumptions.
25 51 Byrne, Tatyana There is insufficient documentation to back up the claim that downsizing the
project is not considered an economically viable solution.
Since turbines are considered a utility then shouldn't the land on which they
25 52 Byrne, Tatyana are placed by assessed as industrial use and taxed accordingly and not
taxes as agriculture?
I am concerned that the DEIS does not adequately address who will
25 53 Byrne, Tatyana compensate businesses and individuals if the proposed wind project results
in loss of fishing revenues.
25 54 Byrne, Tatyana How will historic designated properties near towers be compensated?
25 55 Byrne, Tatyana How does SLWF plan to compensate Indigenous Americans if Indian burial
grounds are discovered?
25 56 Byrne, Tatyana Why no mention of Dodge Bay in the historical Architecture Resource
Investigation section of the DEIS/Supplemental?
Since the coal/gas generators just go on standby while the wind generator
25 57 Byrne, Tatyana is generating please explain how wind power eliminates pollutants and
greenhouse gases during the production of electricity, thus benefiting
ecological water resources, as well as human health.

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Please explain who maintains service roads to individual towers and
25 58 Byrne, Tatyana takeaway lines and what level of maintenance priority will these roads have
vs. residential roads.
25 59 Byrne, Tatyana I am concerned that there are no safety measures to ensure children don't
get near the wind mills.
25 60 Byrne, Tatyana The assumptions used to complete the DEIS/Supplemental are not listed.
The DEIS should include the Planning Board's Energy Facilities Ordinance
25 61 Byrne, Tatyana that governs the application and decision-making process for the special
permits associated with the wind farm project.
The substation/collection station and operations and maintenance facility
should be represented with a plan and profile figures indicating proposed
25 62 Byrne, Tatyana layout, elevation drawings indicating all major equipment, architectural
features, fencing, exterior lighting, and access road in relation to the NMPC
transmission facilities.
A real-time 3D computerized simulation of the project's area of impact with
selected resources digitized would give the Lead Agency, Involved
25 63 Byrne, Tatyana Agencies, and the public a better understanding of the project's impacts.
Due to the scale of the project, it is virtually impossible to assess the
project's impacts through GIS maps, line of sight cross sections, and photo
simulations alone.
The decommissioning process is inadequate. Watertight policies must be
put into contract form which ensures that sufficient funds are available to
dismantle and remove the complete project and to restore the land to its
25 64 Byrne, Tatyana original condition before the FEIS is accepted. Additionally, triggers need to
be set to clearly provide parameters under which a decommissioning
process must occur. The citizens of the town must then be given sufficient
time and opportunity to review and comment on the revised process before
the FEIS is signed.
I urge the Lead Agency to insist upon nothing short of full bonding for
25 65 Byrne, Tatyana performance, payment, public improvements, and decommissioning. You
will need to figure out how that bonding follows to successive owners,

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
because the IRS tax structure for wind turbines is a huge incentive to sell
the project every two years.
I am concerned that the maximum power generation of the wind farm will
25 66 Byrne, Tatyana come close to the transmission capacity and the impact that will have on
future power requirements for the area.
SLWF has concluded that the transmission line on which the project would
25 67 Byrne, Tatyana interconnect has limited capacity, which limits a larger project. In that case,
they are blocking other power generators (bio/solar) from generating power
unless they pay to increase the capacity of the transmission line.
25 68 Byrne, Tatyana The DEIS states that the project will augment local electricity supply. Is this
a true statement?
Neither the DEIS or the Supplemental discuss the Comprehensive Plan
25 69 Byrne, Tatyana adopted by the Town and how the project will fit into the goals set forth in
the plan. The discussion should include potential impacts to the scenic
byway and tourism in the area.
The Planning Board in their 11 July 2007 letter to SLWF in paragraph 6
25 70 Byrne, Tatyana asked that SLWF work with BP on the transmission line and asked that any
response by BP be provided to the Planning Board. That response belongs
in the Supplement but is not provided. Why not?
The Planning Board in their 11 July 2007 letter to SLWF in paragraph 7
25 71 Byrne, Tatyana asked that SLWF produce a revised visual impact study based upon the
new project map. They asked that seven specific locations be included.
That response belongs in the Supplement but is not provided. Why not?
The Planning Board in their 11 July 2007 letter to SLWF in paragraph 8
25 72 Byrne, Tatyana asked that SLWF include measures of commercial and pleasure watercraft
in the background ambient sound measurement. There are no such
measures in Supplemental Appendix L1 and L2. Why not?
The Planning Board in their 11 July 2007 letter to SLWF in paragraph 9
25 73 Byrne, Tatyana asked that SLWF meet with Cape Vincent Fire Department and work out an
emergency fire and ambulance response plan. Why isn't it included in
Appendix B Emergency Response Plan?

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
There are many variables that could impact the number of turbines you can
25 74 Byrne, Tatyana site in the Project Area. What is the number that keeps the project
commercially viable?
26 1 Cullen, Geoffrey I wish to express my profound concern regarding the proposed SLWF. I
have reviewed the SDEIS and feel it is inadequate.
26 2 Cullen, Geoffrey One only has to look across the river to Wolfe Island to see how radically
and permanently the landscape will be changed.
Property values will inevitable suffer if this project moves forward. What
26 3 Cullen, Geoffrey compensation is planned for those of us who will not have turbines but will
see a drop in our home and property values?
While I firmly believe in renewable energy, I also feel there are other more
26 4 Cullen, Geoffrey compelling issues to consider. The SDEIS is not adequate. The setbacks
are too low. I request that you reject the SDEIS.
I frequently drive through the town of Cape Vincent. I feel Cape Vincent is
not the right community for wind turbines. The roads and fields are lovely
27 1 Daub, Patricia and are to be protected as rural landscapes with historic preservation stone
farmhouses and old barns under the New York State preservation laws.
Input under the SEQR process has been inadequate.
The Planning Board in their 11 July 2007 letter to SLWF in paragraph 6
28 1 Docteur, David asked that SLWF work with BP on the transmission line and asked that any
response by BP be provided to the Planning Board. That response belongs
in the Supplement but is not provided. Why not?
The Planning Board in their 11 July 2007 letter to SLWF in paragraph 7
28 2 Docteur, David asked that SLWF produce a revised visual impact study based upon the
new project map. They asked that seven specific locations be included.
That response belongs in the Supplement but is not provided. Why not?
The Planning Board in their 11 July 2007 letter to SLWF in paragraph 8
28 3 Docteur, David asked that SLWF include measures of commercial and pleasure watercraft
in the background ambient sound measurement. There are no such
measures in Supplemental Appendix L1 and L2. Why not?

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
The Planning Board in their 11 July 2007 letter to SLWF in paragraph 9
28 4 Docteur, David asked that SLWF meet with Cape Vincent Fire Department and work out an
emergency fire and ambulance response plan. Why isn't it included in
Appendix B Emergency Response Plan?
There are many variables that could impact the number of turbines you can
28 5 Docteur, David site in the Project Area. What is the number that keeps the project
commercially viable?
Docteur, Dennis and Comments expressing support for the project and the Town Board's
29 1
Donald decisions. Comments requesting approval of the project not be delayed.
Comments supporting the project and objecting to information presented by
30 1 Docteur, Lee a vocal minority that has been opposed to the project. Comments
expressing the positive net benefits of wind power. Please do your civic
duty to uphold the rights of the majority.
4.1.3.2 This section indicates that white nose syndrome will have a greater
31 1 Docteur, Mary cumulative effect on Indiana bats than the wind energy development. What
is the cumulative impact of both white nose syndrome and wind turbines on
Indiana bats?
31 2 Docteur, Mary 4.1.11.2 Since the housing market has changed so dramatically since 2007
why haven't you done a more recent "housing value study."
7.2 This section states that the Project will meet all of the following
setbacks required by the Planning Board of Cape Vincent. Are these
current?
31 3 Docteur, Mary - 1500 feet from Village of Cape Vincent boundary line
- 1000 feet to a non-participating property line
- 1250 feet to a non-participating residence
- 750 feet to a participating residence
31 4 Docteur, Mary 7.6 Table 7-1. What compensation are the three non-participating
homeowners with over 48 db going to get?
31 5 Docteur, Mary Appendix E. The avian and bat study was conducted in one year. Why
didn't you do a multi-year study?

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
31 6 Docteur, Mary Appendix E1. The bat studies were done with radar. Why not also sonar?
Appendix E1. In this Appendix SLWF says that there is no statistical
evidence that Indiana Bats are in the project area, but Appendix E3 Section
3.0 July Aug 2007 states that four were captured and tracked. Appendix E6
31 7 Docteur, Mary July Aug 2007 1.0 states that six captures Indiana bats were radio tracked
and roost sites were identified in the project area [sic]. Appendix E4 June
2008 states that no Indiana bats were captured during that study. Appendix
F3 says they are present. Are there Indiana bats in the project area or not
and if there are, what mitigation actions will you take?
31 8 Docteur, Mary Appendix E3 is labeled Blanding Turtle but reports on bats.
31 9 Docteur, Mary Appendix E7. Which of the Blanding Turtle mitigation recommendations will
be adopted and which will not and why note?
31 10 Docteur, Mary Appendix J. What will you do to mitigate shadow flicker if your analysis is
wrong?
31 11 Docteur, Mary Appendix L. The data in Table 2.2.1 does not match the data from our paid
consultant (elaborate).
31 12 Docteur, Mary Appendix L.3.6 The negative impacts of low frequency sound are dismissed
as corrected by design change. Where is the medical data?
31 13 Docteur, Mary Appendix N2. Who pays to mitigate the loss of TV signals in the project
area?
The SDEIS should not be accepted as written. There are too many issues
32 1 Docteur, Paul pertaining to the health, safety, and welfare of all residents of the
community. Over the past couple of years, many of us have learned a great
deal about the effects of noise and its effects on our health.
Shadow flicker also can have a very detrimental effect on our health as well
32 2 Docteur, Paul as safety issues. My wife is plagued with benign positional vertigo. It is
impossible for her to drive through the turbines on Route 177, making
setbacks a very important issue.
32 3 Docteur, Paul The other issue of importance is the Conflict Resolution Board. This cannot
be controlled by the wind company.

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Mr. Reinbeck, as our Supervisor, you are in charge. Put an end to this
hostile sell out of this most beautiful and historical part of the world.
32 4 Docteur, Paul Implement a two year moratorium immediately. Put together a legitimate
steering committee, which will document a zoning law for turbines, to clarify
it if can occur with our already accepted comprehensive plan.
The Blanding Turtle study conducted by SLWF is flawed. Results show only
one turtle found in 2005 and one in 2007. We gave permission to the
NYSDEC to study Blanding Turtles on our property during 2007 and 2008.
Numerous Blanding turtles have been found on our property in the
wetlands, farm pond and resting in hayfields. We have seen many crossing
Estelle, Douglas and the street from our property to the wetlands which continue on the opposite
33 1 side of the street. In addition, numerous Blanding turtles have been found
Michelle
on our neighbor's property, Francis & Brenda Aubertine, on Pelo Road.

The study was conducted when there wouldn't be much movement by


turtles, in mid-November. They even state that the active time for Blanding
turtles is in June, so why did they do it in winter? This is why it is so
important for the Town to do their own studies.
Freislich, John and Comments expressing concern regarding affects of the project, shadow
34 1 flicker and noise in particular, on existing health problems, fibromyalgia and
Michelle
Graves Disease.
The potential sleep disruption from turbine noise has me generally
concerned. The noise study is flawed. First, why should there be no sound
meters along the river from Burnham Pt to Sand Bay? The bulk of the
dwellings are located along the river on both sides of 12E as you well know.
Freislich, John and Why would the only location be at Wood's Farm? They are a participant so I
34 2 fail to see how this would be representative of the effect on the bulk of the
Michelle
populace. Why did the Planning Board not challenge the lack of additional
data affecting the populated areas? Secondly, the length of time spent
studying the ambient noise is laughable if it wasn't so serious a factor.
Seventeen days? One of the most critical issues and that was the total
winter test duration?

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Why was no measuring device placed at the school? Why no devices near
Beadles Pt, Millen's Bay, or further west near the trailer parks? Why did the
Town of Cape Vincent not hire an independent firm to conduct this critical
research?
Freislich, John and This SDEIS does nothing to guarantee that there will be no impact on my
34 3
Michelle quality of life.
Since the coal/gas generators just go on standby while the wind generator
35 1 Doull, Melodee is generating please explain how wind power eliminates pollutants and
greenhouse gases during the production of electricity, thus benefiting
ecological water resources, as well as human health.
Please explain who maintains service roads to individual towers and
35 2 Doull, Melodee takeaway lines and what level of maintenance priority will these roads have
vs. residential roads.
35 3 Doull, Melodee I am concerned that there are no safety measures to ensure children don't
get near the wind mills.
35 4 Doull, Melodee The assumptions used to complete the DEIS/Supplemental are not listed.
The DEIS should include the Planning Board's Energy Facilities Ordinance
35 5 Doull, Melodee that governs the application and decision-making process for the special
permits associated with the wind farm project.
The substation/collection station and operations and maintenance facility
should be represented with a plan and profile figures indicating proposed
35 6 Doull, Melodee layout, elevation drawings indicating all major equipment, architectural
features, fencing, exterior lighting, and access road in relation to the NMPC
transmission facilities.
A real-time 3D computerized simulation of the project's area of impact with
selected resources digitized would give the Lead Agency, Involved
35 7 Doull, Melodee Agencies, and the public a better understanding of the project's impacts.
Due to the scale of the project, it is virtually impossible to assess the
project's impacts through GIS maps, line of sight cross sections, and photo
simulations alone.
35 8 Doull, Melodee The decommissioning process is inadequate. Watertight policies must be

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
put into contract form which ensures that sufficient funds are available to
dismantle and remove the complete project and to restore the land to its
original condition before the FEIS is accepted. Additionally, triggers need to
be set to clearly provide parameters under which a decommissioning
process must occur. The citizens of the town must then be given sufficient
time and opportunity to review and comment on the revised process before
the FEIS is signed.
I urge the Lead Agency to insist upon nothing short of full bonding for
performance, payment, public improvements, and decommissioning. You
35 9 Doull, Melodee will need to figure out how that bonding follows to successive owners,
because the IRS tax structure for wind turbines is a huge incentive to sell
the project every two years.
I am concerned that the maximum power generation of the wind farm will
35 10 Doull, Melodee come close to the transmission capacity and the impact that will have on
future power requirements for the area.
SLWF has concluded that the transmission line on which the project would
35 11 Doull, Melodee interconnect has limited capacity, which limits a larger project. In that case,
they are blocking other power generators (bio/solar) from generating power
unless they pay to increase the capacity of the transmission line.
35 12 Doull, Melodee The DEIS states that the project will augment local electricity supply. Is this
a true statement?
Neither the DEIS or the Supplemental discuss the Comprehensive Plan
35 13 Doull, Melodee adopted by the Town and how the project will fit into the goals set forth in
the plan. The discussion should include potential impacts to the scenic
byway and tourism in the area.
Concerns regarding impacts to aquifer providing water to spring off of
Mason Road as a result of possible blasting for wind turbine footings in the
36 1 Henchy, Harold general vicinity of the spring. What is the plan of the Town to provide water
to my home in a timely manner, within 24 hours, if the aquifer is
compromised?
37 1 Hetzler, Eileen Concerns regarding the impact of the project on property values and

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PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
existing tourism from visual impacts.
Concerns regarding the impact of the project on property values from visual
38 1 Hetzler, Stephen impacts. Also concerns that the escrow for the warranty of the wind turbine
generators would more than likely be used up before the warranty period is
over.
Concerns that there has not been sufficient time for public review of the
39 1 Hirschey, Urban SDEIS. The SDEIS was submitted over 2 years after the DEIS and is twice
as long yet public was given only half the time to review and make
comments.
Concerns regarding the cumulative impacts from the BP Cape Vincent
project, as well as the proposed, dormant PB application for a project in
Lyme which would also share the same transmission line. Also, the
39 2 Hirschey, Urban Alternatives Section Table 7-1, states that the 53-turbine project will
encompass 7849 acres. This amounts to 148 acres per turbine and if you
include the 140 turbines of BP that would total over 28,000 acres which
amounts to 88% of the mainland area of the Town of Cape Vincent.
Concerns regarding the adequacy of the ice shedding discussion in the
SDEIS, specifically the lack of an ice shedding study and relevance of the
existing research referenced in the discussion.

The Morgan, Bossani, and Siefert 1988 study calls for ice studies to be
completed in three stages. An estimate should be made of the time
(number of days per year) during which icing conditions occur at the turbine
40 1 Hludzenski, Kathryn site:
- "heavy icing" more than 5 days, less than 25 days icing per year
- "moderate icing" more than 1 day, less than 5 days icing per year
- "light icing" less than 1 day icing per year
- "no icing" no appropriate icing conditions occur

Also, the report is now old. Since it was written, many cases of injury from
turbine ice shed have been documented. For example,
http://www.caithnesswindfarms.co.uk/fullaccidents.pdf.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Concerns that the Cape Vincent Indiana bat studies are insufficient.

The length of time may not be sufficient to determine bat presences


because weather conditions changes from year to year and this could affect
bat activity. The Cape Vincent test was done in July/August 2007 but is not
clear on how many days were spent in the field and under what conditions.

41 1 Hludzenski, Kathryn Sampling was done in July and August but the report for the Horse Creek
Wind Farm in neighboring Clayton, New York trapped their first bat on June
2 and after July 31st capture rates significantly decreased. Depending on
when the Cape Vincent studies were done, this may have had an effect on
the results also.

The study did not do thermal imaging or use acoustical radar. The Indiana
brown bat is difficult to distinguish from the little brown bat therefore
additional mist net surveys are needed during spring and fall migration.
Concerns regarding cumulative impacts from the several wind projects in
the area: operational Wolfe Island project (86 turbines), Horse Creek in
41 2 Hludzenski, Kathryn Clayton (62 turbines), Galoo Island (77 turbines), BP's Cape Vincent wind
project (140 turbines), and the SLWF (53 turbines). All for a total of 418
turbines within a 25 mile radius of the Indiana bat hibernacula in Glen Park,
New York.
Concerns regarding mortality to Indiana bats from the wind project, from
fragmenting its habitat and destroying its foraging ground and pressure
changes that spinning blades have on the lungs of bats. A more extensive
41 3 Hludzenski, Kathryn study is necessary to know how many Indiana bats are actually in the area
and the impact the project would have. Not only do I think that the bat
studies are inadequate, but I think that due to the plight of the Indiana bat
and the sensitive nature of the area, the project should not be in Cape
Vincent.
41 4 Hludzenski, Kathryn Were the transmission line routes also included as part of the area being
tested?

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
What are the migratory patterns of the herons and how do they fly when
42 1 Hubbard, Sandy they are migrating? How long do they stay in Cape Vincent? When do they
arrive and when do they depart? Why isn't this addressed in the DEIS?
42 2 Hubbard, Sandy Impacts of shadow effect on wildlife should be part of the DEIS.
42 3 Hubbard, Sandy Individuals, guides, and town must be compensated if towers result in loss
of fishing revenues.
42 4 Hubbard, Sandy SLWF needs to establish who the environmental monitor works for and how
he/she sends reports to.
The development of a long-term environmental management plan should
be considered to incorporate plans for restoration of environmental impacts
42 5 Hubbard, Sandy during the following construction [sic], environmental considerations to be
included in the ongoing maintenance facility, a contingency plan to assess
and minimize environmental impacts during major repairs, and assessment
and mitigation of environmental impacts during decommissioning process.
42 6 Hubbard, Sandy It is important to know the impacts of shadow effect on the fish in the water.
How can the impact on wells and springs be evaluated if there is now
baseline for the springs or wells? Fieldwork should be done to establish
42 7 Hubbard, Sandy major springs and their use or flow prior to construction. I would like to see
identification of all wells and springs within 500 feet of where blasting will
occur. Also address the steps to be made to provide citizens with potable
water if problems occur.
42 8 Hubbard, Sandy The project may require an Article 24 Freshwater Wetland Permit and
Section 401 Water Quality Certification.
Since issues regarding potential medical problems related to wind turbines
42 9 Hubbard, Sandy come up with proposals around the state, it would seem appropriate to
include a section on medical issues in the DEIS.
Critical information is needed to evaluate potential impacts resulting from
42 10 Hubbard, Sandy the project not performed as part of the DEIS. The DEIS should be updated
to include: geotechnical field data, groundwater studies, wetland field
survey, and hydrogeological balance study based upon long-term runoff. By

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
omission of this information during the design and review stage with a
disclaimer that it will be obtained "prior to construction" the developer
avoids all accountability from the Lead Agency, involved agency, and public
comment.
At best the studies to date may be considered pilot efforts requiring 3-5
42 11 Hubbard, Sandy years of intense further studies of many groups before any consultation of
value may be drawn.
Are you and the Audubon Society aware of the IBA (Important Bird Habitat)
42 12 Hubbard, Sandy on Pleasant Valley Road? How will it be affected? What does Audubon
say?
42 13 Hubbard, Sandy The lease with SLWF takes away landowners' constitutional rights to sue
for punitive damages and the right to jury trial. Why is this acceptable?
Section 2.6.4 of the SDEIS needs to include a description of specific
processes that will be implemented to ensure the concrete is handled
42 14 Hubbard, Sandy properly during construction to limit the impacts to surface waters,
wetlands, and underground waters, given the existence of karst topography
in the project area.
The report should specifically state that the habitat type located at
42 15 Hubbard, Sandy Chaumont Barrens and Three Mile Creek will not be impacted by the
project.
Section 3.2 shows that no biotic or water quality data is provided but this
42 16 Hubbard, Sandy information should be included in the report along with a discussion of
potential impacts from project construction.
Section 3.3 of the DEIS does not identify if the wind project will impact to
42 17 Hubbard, Sandy establish [sic] the St. Lawrence Wetland and Grassland Management
District (SLWGMD). Nor does it mention if it is compatible with the
SLWGMD.
Section 3.3.6 NYS Fish and Wildlife strongly recommend that the Smith
42 18 Hubbard, Sandy (2007) be considered by the project sponsor in siting the project features
[sic].
42 19 Hubbard, Sandy Section 3.3.6 NYS Fish and Wildlife found insufficient data exists to

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
adequately conduct a risk assessment and predict wildlife mortality for this
project.
The DEIS falls short of providing the necessary information in a
42 20 Hubbard, Sandy comprehensive manner. The DEIS states that additional data on wildlife
use and potential impacts is forthcoming. NYS Fish and Wildlife will review
this information prior to making a final determination.
The Complaint Appeal Procedure states that the Complaint Resolution
Board shall consist of three members: an SLWF designee, a Town Officer
or Employee appointed to the position annually, and an independent third
party expert."

Since the appeal procedure follows the original complaint which "SLWF will
make every reasonable effort to resolve" it does not make any sense that
SLWF would also be included in an appeal board. If they had resolved the
43 1 Jury, Charles complaint in the first place the appeal would not be necessary.

The appendix also states "in making such decision, the Complaint
Resolution Board shall take into account the terms and conditions of the
special use permit and approved site plans, and shall not require any
resolution that is inconsistent with such terms." This seems to say that as
long as the permit and site plans are approved there is no way any
complaint will be heard. This statement should be eliminated from the
SDEIS.
Regarding the TV analysis and the statement that TV programming by
alternative means can be offered to mitigate the issue of loss of coverage,
who will determine whether there is a problem and who will pay for the
44 1 Jury, Ellen alternative method? It should also be noted that cable TV is not available to
all areas of Cape Vincent and that DBS does not offer all local channels.
These local channels are necessary for local news, emergency information,
weather alerts, school closings, security alerts, etc.
45 1 LaMora, David Concerns regarding conflict of interest of the Planning Board members in
reviewing the SLWF. A majority of the Planning Board, which I believe

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
illegally voted itself Lead Agency for this process, have prohibitive conflicts
of interest, which you refuse to acknowledge or seek an authoritative
decision on in the best interest of this community.
Further information is necessary to substantiate the conclusion that the
wind project will have a positive benefit to air quality. In many cases, the
45 2 LaMora, David existing plants that provide electricity at a much higher efficiency level do
not shut down when wind-generated power is being substituted; they
merely redirect their energy source so it is available to ramp up with the
wind stops blowing.
The visual impacts from the project are enough to prevent acceptance of
45 3 LaMora, David the SLWF on the basis of the zoning law, which specifies that if any
deleterious effect cannot be mitigated then the subsequent site plan review
must be disapproved.
The SLWF is not compliant will all town zoning and land use regulations
because the project does not comply with the Comprehensive Plan, which
guides all land use laws in Cape Vincent. The Plan states that one of its
45 4 LaMora, David goals is to encourage development that minimizes any negative impact on
the natural vistas and scenic landscapes. This is in complete contradiction
to the claim SLWF makes that this project complies with all land use
regulations by its own admission that it cannot mitigate the visual impact of
these turbines.
In Section 3.5.1.3 this report states that turbine locations and other project
components will conform to setbacks and standards required by the Town
Planning Board in response to public comments on the SLWF DEIS. These
setbacks and standards are not legitimate validated criteria for site plan
45 5 LaMora, David review. According to the Cape Vincent Zoning Law all zoning criteria must
be legislated by the Town Board. Stipulating that these standards must be
conformed to is an illegal attempt to circumvent the proscribed legislative
process and cannot be allowed to guide the SEQR process. The planning
board must not allow this, since these criteria would not hold up to a
challenge by either the developer or a dissenting landowner.
45 6 LaMora, David The noise analysis has flaws. Why were 5 to 6 testing locations chosen

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
only at participating properties? They should have tested at non-
participating properties, because impacts to non-participating residents
should be evaluated. Also, the equipment used to collect the data was not
suitable for sever winter weather and didn't provide a statistically adequate
percentage of raw data.
My final comment concerns the complaint resolution process. It is obvious
that even though they go to great lengths to detail every impact and
describe what they consider a suitable mitigation for each impact, they are
certain that the criteria suggested to site this project are inadequate to the
extent that it will require a sophisticated and complex complaint resolution
process to deal with noncompliance. I believe it is inherent in the biased
45 7 LaMora, David unwillingness of the Town Board and Planning Board to significantly restrict
this development that will lead to this compliance nightmare. The final insult
to the residents of Cape Vincent is the proposed makeup of SLWF's
resolution board. If it is true that we require resolution beyond what the
Zoning Board of Appeals can provide then the process should not be
determined by the developer and certainly not controlled by them to the
extent they propose. A resolution board should be designed and controlled
by members of the community just as any zoning regulations should be.
If this Supplemental Study is approved by this Planning Board, it will do
nothing but illuminate the severity of the bias produced by the conflicts of
45 8 LaMora, David interest prevalent in this government. I sincerely hope you will consider the
ramifications of approving this document and instead will either ask for
another Supplemental Review of halt the process until this community can
resolve some of these issues for ourselves.
The wind turbine setbacks are in violation of several paragraphs under
46 1 Leschord, Paul Article I, Section 115 of the Cape Vincent Planning and Zoning Introductory
Provisions. Setbacks should be examined in miles, not feet. Anything else
creates visual impacts.
Concerns regarding the cumulative impacts from both Cape Vincent and
47 1 LeTendre, Gerard the other proposed project on wildlife. The SDEIS does not adequately
address this and does not have adequate studies of impacts to wildlife.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
We had deep rooted problems in attempting to resolve the wind tower issue
in this town. The Town Board is conflicted as is the Zoning Board (including
47 2 LeTendre, Gerard the Chairman). These people that have little or no biological training are
making decisions favoring the developer that will affect the town drastically
in the future. Favorable decisions are often rendered no matter how poor or
wrong the information is that is provided.
The bird and turtle studies are inadequate and never even develop an
accurate portrayal of the various populations as they exist today. The
47 3 LeTendre, Gerard developer fills many pages with information about other wind farms that
don't apply to Cape Vincent and then neglects local information such as the
data generated in the 1980 and 1984 NYS Breeding Bird Atlas.
Blanding Turtles: The developer and paid consultants have been unable to
determine where the turtles exist in town so they have no idea of population
size. Yet, they want us to believe that once the wind towers are in place the
47 4 LeTendre, Gerard turtles will survive. Additional effort is required to locate this species. Once
location and numbers are known they can move forward and determine
possible adverse effects and develop a wind turbine placement plan that
will avoid the turtle habitat or mitigate the problem.
Bats: Studies have been completed. Several Indiana Bats were captured in
2006, but in the SDEIS there is no report of follow-up studies on the Indiana
Bat. The studies done are too narrow in scope and avoid review of such
problems as white nose syndrome and how that relates to expected
47 5 LeTendre, Gerard mortality rates caused by wind tower blades. Much more and better
information is necessary in order to mitigate turbine mortality of bats. Cape
Vincent is near the Glen Park, NY hibernaculum and at least 3 years of
sound pre-construction bat studies should be required to learn how the
wind towers will effect the various populations of bat species.
Hawks: The studies done to date are minimal. A case in point is the
Northern Harrier that is NYS threatened and not adequately studied. These
47 6 LeTendre, Gerard birds nest in our town and will require protection. Acciona consultants are
not providing population status and no mitigation to protect species can be
applied at this time. Other hawks such as rough-legged, sharp-shinned,

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
coopers and American kestrel depend on areas such as Cape Vincent for
their survival. Rough-legs require over-wintering habitat while the other
three species successfully nest here. The fact that all local hawks are
stressed means more and better studies are required.
Owls: Cape Vincent habitat is of particular importance to short-eared owl
survival. It is inconceivable that people hired to study birds in the Acciona
wind tower area never even located one! The developer either hired
unqualified people to collect bird data or they simply don't care. I have
47 7 LeTendre, Gerard personally shown short-eared owls to many bird watchers and nature lovers
that visited the area in recent years. Yes, they are here and require
protection from wind towers. The developer has not located the species and
therefore is unable to determine the number of short-eared owls present.
Once they know where the owls are and how many they can begin the
process of mitigating potential damage. Several years will be required.
Migrating Birds: The studies of migrating birds are especially poor. The
counters are not able to identify ducks and geese in flight and this is
compounded by short study times and too few counts. Information is
required on all bird migration and what can be done to avoid collisions.
Wind tower siting should not be anticipated until this is completed.
Note: In 2005, I spent one May morning watching birds on Gosier Road in
Cape Vincent. This site is the Acciona footprint. Large numbers of ducks
47 8 LeTendre, Gerard and geese were migrating north and I decided to make an impromptu
count. Over 20,000 ducks and geese were counted that morning. Of these,
over 1,000 were Snow Geese, a few hundred were Mallard Ducks and
approximately 19,000 Canada Geese were tallied. This was in a one mile
wide area that I selected because they were outside the count area. I
believe that more birds migrated through the area that morning than were
represented in all studies conducted and reported in the DEIS and the
SDEIS.
Breeding Birds: This study should start from scratch. A good place to start
47 9 LeTendre, Gerard is the 2000 to 2004 New York State Breeding Bird Atlas. Major problem
identified in bird studies: Adequate bird studies can't be completed unless

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
you have competent bird counters that can identify birds by site and sound.
Counts of hawks, owls, ducks, geese, gulls, and songbirds were all poorly
done and should be expanded and repeated.
Invasive Plants: The disturbed earth created by wind farm construction will
compromise the ongoing swallow-wort control effort in the entire Town of
Cape Vincent. This invasive species is being controlled with funding by
47 10 LeTendre, Gerard NYS at the present time. There is no specific mention in the SDEIS of this
control effort which is funded for two more years. Stopping the possible
spread of swallow-wort and other invasive species should be given high
priority. Methodology for implementing this stoppage must be developed
prior to wind tower approval.
Noise: The noise issue is the most interesting and confounding issue of the
Cape Vincent wind tower sites. The developer hired a consultant (Hessler)
that appears to know exactly what decibel levels are required for maximum
placement of wind towers. Amazingly, the data provided by this consultant
came out at just the proper level for maximum wind tower placement.
This information on decibel background levels and the methodology
Hessler used is being challenged by several noise experts. I believe the
47 11 LeTendre, Gerard consultant hired by the Town of Cape Vincent (Cavanaugh Tossi
Associates Inc) came up with lower decibel background levels. It is
imperative that the Town Board and Zoning Board members get this right
because all the residents will be affected by the noise levels.
In addition to the consultant Cape Vincent hired, another consultant was
hired (Shomer and Associates) and neither of these (Shomer or
Cavanaugh) agreed with the results produced by Hessler. Paul Carr, a local
noise expert, also does not agree with Hessler.
Request for a moratorium of at least 12 months to investigate and
determine if this project is safe for the town. The issues of accurate
LeTendre, Jerry and measurement of ambient noise levels, nighttime noise levels affecting
48 1
Judith sleep, project effect on our water supplies, shadow flicker effects, migratory
bird impact, and the dominant visual impact of 390 foot tall turbines on our
landscape need to be resolved.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
49 1 Macura, David Will the geotechnical investigation, necessary for project construction and
design, be included in the FEIS?
3.1.3.3 In this paragraph, SLWF does not mention the use of an
environmental monitor. In order to provide proper oversight of these
49 2 Macura, David activities it is important that an environmental monitor be onsite for all pre-
construction survey and any construction activities that involve excavation
to bedrock or are located in proximity to known karst features. Will an
environmental monitor be present?
49 3 Macura, David 3.2.3.3 The discussion on soil is too general. Each turbine site, access
road, electric line pole, and substation needs a soil map.
49 4 Macura, David 3.4.2 Will the comprehensive transportation study, delivery routes, and
crane assembly areas be part of the FEIS?
3.9.1 There is no discussion of the impact of the turbines on the ozone level
49 5 Macura, David which is already out of compliance with EPA guidelines. What is the impact
and if so, how will you mitigate?
3.11.3 To mitigate impacts to local roads during construction, any
construction-related damage or improvements to roads would be the
49 6 Macura, David responsibility of the Applicant and would be undertaken at no expense to
the municipalities. How long after project completion is this going to
continue.
3.13.1.2 The study used in the discussion if ice shedding (Morgan,
49 7 Macura, David Bossanyi, and Siefert, 1998) is an 11-year old study. Why aren't you using
a more recent one?
50 1 Macura, Joan Why not bury the overhead lines in the farmland?
50 2 Macura, Joan Will the cable depth be 24" or 6" below the soil surface?
50 3 Macura, Joan Will nearby well/spring info be included in the FEIS? Are there any plans to
provide potable water to citizens if well problems occur?
50 4 Macura, Joan How will concrete be handled during construction?
50 5 Macura, Joan Why not identify final overhead transmission line right-of-way pre-
construction?

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
50 6 Macura, Joan Why doesn't it include long-distance transmission lines? What is the plan to
ensure sufficient funds? How will bonding follow to successive owners?
51 1 Mahrer, Carolyn Request for 12 month moratorium to investigate project safety.
Mahrer, Michael and Request for more time to review impacts and 1 year moratorium.
52 1
Susan
Mason, Elaine and Expressed support of the project.
53 1
Paul
54 1 Metzger, Donald Request for 30 days of public comment period
54 2 Metzger, Donald What is the second of the two alternative pathways? If second pathway is
taken, what are the steps involved?
54 3 Metzger, Donald Discuss decommissioning overhead collection lines. Confusion and
skepticism over decommissioning process.
54 4 Metzger, Donald Confusion regarding decommissioning concrete foundations.
54 5 Metzger, Donald Overhead transmission line shares same right-of-way with water line -
potential issue?
54 6 Metzger, Donald Request for testing of stray voltage every 6 months.
54 7 Metzger, Donald Who appoints the Complaint Resolution Board Town Officer member?
What town is represented?
54 8 Metzger, Donald Request for pre- and post-construction tests for signal quality.
54 9 Metzger, Donald Request for Saratoga Associates to apologize for calling community "late
risers."
54 10 Metzger, Donald Request for testing of all wells within 500' radius of turbines.
54 11 Metzger, Donald Expressed concern over cumulative effects of overall project.
55 1 Metzger, Donald Same as comment letter #54
56 1 Moehs, Charles Request public health/medical impact research
56 2 Moehs, Charles Request for mitigation of impacts through setbacks if impacts exist
57 1 Radley, Jerry Will people want to come to the area if they see turbines everywhere?
57 2 Radley, Jerry How will turbines affect child and adult health?

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
57 3 Radley, Jerry Request for more research on wildlife.
57 4 Radley, Jerry Will turbines decrease property values? Will industrialization affect
seasonal residents?
58 1 Radley, Pattie Marie Expressed support of the project.
Reed, Alfred and Turbine #38 will decrease property value.
59 1
Maria
Reed, Alfred and Noise from turbines #38 and #39 will affect their way of life.
59 2
Maria
60 1 Ross, Pat Request for 12 month moratorium to investigate project safety.
61 1 Ryon, Doug Expressed concern over visual effects of overall project.
62 1 Schneider, Clifford Maps showing non-resident receptors are inadequate.
62 2 Schneider, Clifford Request for new survey that represents background noise for non-
participating residents.
62 3 Schneider, Clifford References to LEQ noise metrics in SEQR should be struck.
62 4 Schneider, Clifford Request to conduct another background survey using more representative
monitoring sites and incorporate recommendations from Town's consultant.
62 5 Schneider, Clifford Request to conduct project layout and impact analysis that assumes 26
dBA background sound along with the NYSDEC noise impact allowance.
62 6 Schneider, Clifford Provide details on source levels presented in Table 3-30.
62 7 Schneider, Clifford Request to recast analysis using 31 dBA as critical operational design level.
62 8 Schneider, Clifford Request to correct the ground absorption coefficient.
62 9 Schneider, Clifford Request to adjust model analysis (including setbacks) that will reduce
predicted noise levels by 5 dBA.
62 10 Schneider, Clifford Request to adjust siting plan to ensure non-participating residences will not
have noise impacts that exceed state guidelines.
62 11 Schneider, Clifford Provide siting plan and design level based on 31 dBA impact contour for
Project only noise addition.
62 12 Schneider, Clifford Remove comments and opinions that diminish importance of State

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
guidelines.
62 13 Schneider, Clifford Increase the setback from the nearest offending turbines to reduce noise
impacts.
62 14 Schneider, Clifford Complaint Resolution Board Town Officer membership appointment issues.
62 15 Schneider, Clifford SLW Noise Impact Assessment - Provide measures of background noise
based on more conventional standards.
62 16 Schneider, Clifford SLW Noise Impact Assessment - Issues with background sounds -
misrepresentation of summertime noise levels.
62 17 Schneider, Clifford SLW Noise Impact Assessment - Van Der Berg references impacts would
be 15-18 dBA higher than expected.
62 18 Schneider, Clifford Noise Modeling Methodology - Request to re-do noise modeling
62 19 Schneider, Clifford Model Results - Redesign the layout plan accounting for background levels
at least 10 dBA lower than provided.
63 1 Schoeberlein, Donna Expressed concern over human and environmental health effects of project.
Requested more time to determine health effects.
63 2 Schoeberlein, Donna Who will purchase more expensive form of energy? What will this project
do to tourism revenue?
64 1 Simpson, Carol What is cumulative impact of both White Nose Syndrome and continued
human encroachment?
64 2 Simpson, Carol A more recent housing value impact study should be done due to the recent
changes in the housing market.
64 3 Simpson, Carol Are the listed setbacks correct?
64 4 Simpson, Carol Compensation for non-participating residents with noise over 40 dBA?
64 5 Simpson, Carol Why not multi-year study?
64 6 Simpson, Carol Are there Indiana Bats within the project area? If so, mitigation?
64 7 Simpson, Carol Appendix E3 is labeled "Blanding Turtles" but is about bats.
64 8 Simpson, Carol Appendix E7 - Which of the mitigation efforts for Blanding Turtles will be
adopted, which not?

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
64 9 Simpson, Carol Appendix J - if analysis is wrong, what will be done to mitigate?
64 10 Simpson, Carol Appendix L - The negative impacts of low frequency noise are dismissed.
Where is the medical data?
64 11 Simpson, Carol Appendix N2 - who pays to mitigate loss of TV signals?
65 1 Simpson, Carol The SDEIS should provide specific impacts to specific
threatened/endangered.
What is the potential impact to Northern Harrier? How many breeding pairs
could be affected? Is this a significant portion of the breeding population in
65 2 Simpson, Carol the area? How will the impact be mitigated? What is the range of
reasonable alternatives considered to avoid this species pursuant to
617.9(b)(5)(iv)?
65 3 Simpson, Carol Cumulative Impacts on bird species with regard to Wolf Island
66 1 Steinhouse, Barbara Request for 12 month moratorium to investigate project safety.
Thomas, Carol and Who negotiates PILOT payments for the town?
67 1
Dan
Thomas, Carol and What is the estimated cost per kilowatt hour produced for the first year of
67 2
Dan the project, first 5 years and the first 10 years?
Thomas, Carol and No mention of payment, performance and maintenance bonding. If project
67 3
Dan is not bonded, how will promises be kept?
Thomas, Carol and No Economic Development Impact Model, so it appears the
67 4
Dan socioeconomics section was based on assumptions.
Thomas, Carol and Insufficient documentation to backup project downsizing claim.
67 5
Dan
Thomas, Carol and Since the turbines are a utility, then shouldn't the land be zoned as
67 6
Dan industrial and taxed accordingly.
Thomas, Carol and SDEIS does not address who will compensate business and individuals if
67 7
Dan proposed project results in loss of fishing revenues.
68 1 Uhlig, Bob and Ruth Who is responsible for the safety, repairs, maintenance, and removal of
turbines?

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
What evidence do we have to keep swallow wort from spreading? Will
68 2 Uhlig, Bob and Ruth equipment be power washed when moved from site to site? Will turbines
spread seeds? Will farmers discontinue to plow fields which allows swallow
wort to spread?
68 3 Uhlig, Bob and Ruth Visible damage at Wolfe Island. Will this happen to Cape Vincent?
69 1 Vooder, Linda Request for 12 month moratorium to investigate project safety.
Wiley, Karen and Request for 12 month moratorium to investigate project safety.
70 1
Richard
71 1 Williams, Sharon Request for 12 month moratorium to investigate project safety.
72 1 Williams, Tina Request to set turbines back from roads, views of the St. Lawrence River,
and village.
72 2 Williams, Tina The SEQR process should allow for input from interested parties.
72 3 Williams, Tina Feels the SDEIS is incomplete.
73 1 Grant, Cindy General concerns over health and safety of residents within 2 mile radius of
project.
73 2 Grant, Cindy Believes residents will be harmed by low frequency noise, or infrasound.
Noise should be measured using dBC in addition to dBA.
73 3 Grant, Cindy Project area is highly populated. Other wind farms are in less populated
areas, far enough away so people are not harmed.
Typically industrial wind turbines cause the most disturbance at night, when
73 4 Grant, Cindy the winds at ground level are still but the wind up at the hub height are still
blowing, and the noise from the turbine will be very noticeable in the home.
Noise studies done at an industrial wind project sites after they have been
73 5 Grant, Cindy up and running often show that they are making much more noise than the
developers said they would, but by then it's too late.
73 6 Grant, Cindy Also believes that the residents will be harmed by the shadow flicker effect,
especially people who already suffer from migraines, epilepsy and vertigo.
73 7 Grant, Cindy Believes that large oil companies are not good to do business with, and
residents may never see compensation citing Exxon Valdez as an example.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Believes there is also no way that the town of Cape Vincent residents will
ever be able force developer to make right any violations against the
73 8 Grant, Cindy residents that live near this project unless proper regulations are put into
effect now. Before this project is allowed, requests more safeguards in
place now.
Expressed concern over raptor area. States that issues are barely
73 9 Smith, Gerry addressed, and they are not addressed significantly, especially on the part
of the field teams that were out looking at these birds and bats, specifically
short-eared owl. Also, disagrees with breeding bird summary.
73 10 Metzger, Don The SDEIS doesn't state anything about alternative two. What is alternative
two?
The public only gets ten days in which to consider the final Environmental
73 11 Metzger, Don Impact Statement. Believes that ten days to consider a project of this size is
insufficient for the community.
Do the foundations go, the collection cables, the 37 miles of underground
73 12 Metzger, Don collection cables? At one point a depth of 44 inches is used. Believes that's
a misprint.
Concerns about the safety and integrity of the Development Authority of the
North Country's western Jefferson County regional water line, the 12-inch
interior diameter water line that goes for 25 miles from Cape Vincent to
73 13 Metzger, Don Glen Park, serving four towns, five villages, the General Brown School, and
many, many water hydrants. That is a potential -- with the poles there being
set 15 feet into the ground, there is a physical integrity, physical security
problem.
73 14 White, Beth In favor of accepting SDEIS and supports the proposed wind farm.
73 15 Doull, Melodee States that the project is not in compliance with the local zoning ordinance
and land use regulations.
73 16 Doull, Melodee Claims setbacks have not been legally adopted.
73 17 Doull, Melodee Claims downsizing is not enough to mitigate visual impacts.
73 18 Doull, Melodee There is no mention of the transmission lines; there is no mention of secure

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
funds to implement the plan. Will there be bonding? What happens when
the wind farm is sold to another company?
What happens when the wind farm is sold to another company? Will the
73 19 Doull, Melodee new company adhere to the decommissioning plan as described in the
SDEIS?
73 20 Doull, Melodee A mitigation solution would be to increase turbine setbacks in order to
lessen the effects of flicker, noise, and vibration concerns.
73 21 Hirschey, Urban Feels 5 months are necessary for SDEIS comment period.
73 22 Hirschey, Urban Disagrees with separating two (BP and Acciona) Cape Vincent projects.
73 23 Hirschey, Urban Concerned that Lyme project was not considered in projects within 13 miles
of site.
73 24 Ciocci, Theresa Concerns over overall impacts to human health.
73 25 Byrne, John Expressed concern over 5 dB increase in background noise.
73 26 Docteur, David Why is this area even considered when there can be visual and health
impacts? Specifically, disease from vibrations.
Claims a 1,250-foot setback from a nonparticipating residence results in
putting the generating plant practically on top of them and will cause
73 27 Docteur, David intolerable conditions with the shadows, flicker, and noise. Says it is
recommended that there be a one-and-a-half-mile setback, not two-tenths
of a mile.
73 28 Docteur, David Land will become undevelopable. Why does St. Lawrence want to do this?
73 29 White, Kenneth In favor of accepting SDEIS and supports the proposed wind farm.
73 30 King, Gary In favor of accepting SDEIS and supports the proposed wind farm.
73 31 Chapman, Tom Does not feel that wind energy is green energy and does not create jobs.
73 32 Lawrence, Rick Supports the proposed wind farm.
73 33 Johnson, Warren Expresses concern over overhead lines and requests burying lines
underground.
73 33 LeTendre, Jerry Disagrees with SDEIS findings on impacts to birds.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
73 34 Sirianni, Paul Supports the proposed wind farm.
73 35 Clark, John Supports the proposed wind farm.
73 36 Gauthier, Bob Supports the proposed wind farm.
73 37 Mason, Paul Supports the proposed wind farm.
73 38 Kenney, Gail Resident of Wolfe Island warns of negative impacts.
73 39 Brown, Tom Wants to know why other potentially less visually intrusive sites were not
considered.
73 40 Brown, Tom Disagrees with exempting alternative sites.
Disagrees that during operation approximately 48 residences would have a
73 41 Ebbing, Chuck nominal project sound level slightly above the project impact threshold of
60B over the estimated 42 dBA.
Challenges Table 1-1 when it talks about impacts, potential impacts and
73 42 Ebbing, Chuck what they're going to do. Disagrees that the project will not have significant
noise impacts during operation.
73 43 Ebbing, Chuck Challenges overall noise study, claims it is biased.
73 44 Schneider, Clif Challenges overall noise study, says estimate of ambient at 37 dB is about
10 dB high.
73 45 Haskins, Janet Concern over living adjacent to turbines.
Insists that the town and the developer fully give rights under the SEQR
73 46 Bragdon, Brooke law, the National Federal Historic Preservation laws, and other -- the local
zoning law.
73 47 Cullen, Cyril How is decommissioning going to be funded, bonding, no bonding,
deposits, etc.?
73 48 Cullen, Cyril Requests for a moratorium and zoning law.
73 49 Kobylarz, Virginia Climate may not be adequate for wind power.
73 50 Kobylarz, Virginia Concern over migrating birds.
73 51 Kobylarz, Virginia Who is responsible for repair, decommissioning, and restoration?
73 52 Radley, Jarvis Supports SDEIS findings and the proposed wind farm.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Requests identification of liability in the case of damages caused by the
73 53 Jolliff, Tom wind farm to persons or property and how they would be handled, such as
by insurance.
73 54 McTaggert, Pat Requests further health studies.
73 55 Boss, Sally Projects turbines will take-up 88% of land mass and requests a moratorium.
73 56 White, Harvey Supports SDEIS findings and the proposed wind farm.
73 57 Chase, Hester Requests clarification on sound/distance relationship.
73 58 Chase, Hester Proposes development of alternatives.
73 59 Falcon, Mary Concerns over red light at night.
73 60 Falcon, Mary Concerns over protecting water during construction.
73 61 Falcon, Mary Concerns over subsidies - feels that citizens will be paying for putting it up
and taking it down.
73 62 Bourquin, Don Supports the Planning Board.
73 63 Bowers, Bert Does not believe 79.5 megawatts of power will be produced.
Production of this clean, renewable energy will not create air or water
73 64 Bowers, Bert pollution or add to greenhouse gases in the atmosphere. This statement
again is totally false as it pretends that industrial wind power can be an
independent stand-alone source of power.
73 65 Bowers, Bert Concern over 10 to 15-decibel sound level increase.
73 66 Falcon, Spencer Concern over psychiatric impact.
73 67 DeLong, Sam Concern over the effect on his vertigo and migraine health conditions.
73 68 Edgar, Chris Supports the SDEIS and proposed wind farm.
73 69 Moehs, Charles Concerns over low frequency noise, cardiac issues, children, elderly, and
learning disabilities, and sees no way of mitigating these issues.
73 70 Metzger, Don Concerns over decommissioning, with regard to long-distance transmission
line that would run to Lyme.
73 71 Metzger, Don Concern over proposed 485 turbines all within 17 miles of the building they
are in.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
Claims there will be a degradation of signal with the cell phone, with the AM
73 72 Metzger, Don radio, with the FM radio, with wireless communication, wireless internet,
issues with the VHF and UHF communication for police, fire, emergency
responders.
73 73 Ciocci, Theresa General health concerns.
73 74 Ciocci, Theresa Asks for liability of damages for both short- and long-term outcomes of
health risks.
73 75 Ciocci, Theresa Concerns regarding sleep deprivation.
Shadow flicker concerns, citing Maine Medical Association results of
73 76 Ciocci, Theresa shadow flicker and noise emissions from turbines on humans living within
3500 feet of industrial turbines
73 77 Schneider, Clif Finds SDEIS exceedances of acceptable noise levels.
73 78 Ebbing, Chuck Concern over night-time noise conditions. Overall concern with noise
study.
Requests ambient noise is measured in the area directly beside each
proposed turbine locations so that you have an accurate noise baseline to
73 79 Grant, Cindy start with and is performed by an independent acoustic engineer that is
chosen by the Town Board but paid for by the developer. Stresses
importance of measuring low frequency noise.
73 80 Grant, Cindy Requests testing of drinking water.
73 81 Grant, Cindy Suggests a buyout clause.
There is no further communication after this letter from Acciona to the
73 82 Bragdon, Brooke State, no follow-up whatsoever in terms of delineating what the adverse
impacts are, and no discussion whatsoever about relocating turbines or
coming up with greater setbacks.
73 83 Byrne, John Questions background noise levels. Feels that noise study is flawed.
What if a well goes dry while blasting for a turbine foundation is done
74 1 various landowners nearby? According to the SDEIS, pre-construction and post-construction
hydrological studies will be conducted to determine if project construction is

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 3-2
Saint Lawrence Windpower Project SDEIS Comment Summary
Agency/
Source ID1 Comment ID Commenter Comment Summary
Organization
responsible for any wells going dry. But what about the time between the
blasting and the post-construction studies? Will the landowner have to find
an alternative water supply and pay for it out of his own pocket, while
waiting for the post-construction study to be completed?
1
Source 73 represents oral comments received during May 16, 2009 Public Hearing.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
Alternatives Stilwell, David and Tim Sullivan USFWS 2.44
Alternatives Davis, Andrew NYSDPS 4.50
Alternatives Davis, Andrew NYSDPS 4.51
Alternatives Davis, Andrew NYSDPS 4.52
Alternatives Davis, Andrew NYSDPS 4.53
Alternatives Davis, Andrew NYSDPS 4.54
Alternatives Falcon, Mary 12.10
Alternatives Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 22.2
Alternatives Vail, Alan 26.1
Alternatives Vail, Alan 26.7
Alternatives Zovistoski, Mary 38.7
Alternatives Hirschey, Urban C. 40.7
Construction Tomasik, Steven for Jack Nasca NYSDEC 1.7
Construction Tomasik, Steven for Jack Nasca NYSDEC 1.19
Construction Stilwell, David and Tim Sullivan USFWS 2.3
Construction Stilwell, David and Tim Sullivan USFWS 2.9
Construction Stilwell, David and Tim Sullivan USFWS 2.11
Construction Stilwell, David and Tim Sullivan USFWS 2.12
Cultural Resources Tomasik, Steven for Jack Nasca NYSDEC 1.17
Cultural Resources Tomasik, Steven for Jack Nasca NYSDEC 1.18
Cultural Resources Davis, Andrew NYSDPS 4.8
Cultural Resources Davis, Andrew NYSDPS 4.34
Cultural Resources Davis, Andrew NYSDPS 4.36
Cultural Resources Davis, Andrew NYSDPS 4.37
Cultural Resources Davis, Andrew NYSDPS 4.38
Cultural Resources Uhlig, Robert Stone Building Appreciation Society 9.1
Cultural Resources Falcon, Mary 12.5
Cultural Resources Chase, Hester 14.5
Cultural Resources Bragdon, Brooks 18.1
Cultural Resources Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.9
Cultural Resources Gormel, Thomas 31.1
Cultural Resources Gormel, Joyce 33.1

4-2

003778
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
Cultural Resources Zovistoski, Mary 38.3
Cultural Resources Hirschey, Urban C. 40.3
Cultural Resources Bragdon, Brooks 48.1
Cultural Resources Bragdon, Brooks 48.2
Cultural Resources Gregory, Maureen Wiley 50.1
Cultural Resources Gregory, Maureen Wiley 51.1
Jefferson County Historical Society,
Cultural Resources Abel, Timothy J., PhD 69.1
Watertown, NY
Cultural Resources Hanson, Rollin V 71.2
Cultural Resources Boss, Sarah F. 79.1
Cultural Resources Bragdon, Brooks 83.1
Cultural Resources Bragdon, Brooks 86.1
Cumulative Impacts Tomasik, Steven for Jack Nasca NYSDEC 1.2
Cumulative Impacts Tomasik, Steven for Jack Nasca NYSDEC 1.16
Cumulative Impacts Stilwell, David and Tim Sullivan USFWS 2.43
Cumulative Impacts Davis, Andrew NYSDPS 4.47
Cumulative Impacts Davis, Andrew NYSDPS 4.48
Cumulative Impacts Davis, Andrew NYSDPS 4.49
Save the River and 1000 Islands
Cumulative Impacts Caddick, Jennifer and Aaron Vogel 19.1
Land Trust
Cumulative Impacts Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.7
Cumulative Impacts Brown, Thomas 65.2
Cumulative Impacts Gormel, Thomas 95.1
Cumulative Impacts Docteur, David 113.3
Cumulative Impacts Gormel, Thomas 113.6
Cumulative Impacts Hambrose, Johanna 113.8
Cumulative Impacts Hanson, Rollin V 113.9
Cumulative Impacts Henchy, Harold 113.10
Cumulative Impacts Hludzenski, Ed 113.13
Cumulative Impacts Metzger, Don 113.15a
Cumulative Impacts Schneider, Clifford P. 113.17a
Ecological Resources Tomasik, Steven for Jack Nasca NYSDEC 1.1

4-3

003779
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
Ecological Resources Tomasik, Steven for Jack Nasca NYSDEC 1.6
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.4
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.7
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.8
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.16
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.21
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.22
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.23
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.24
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.25
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.26
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.27
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.28
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.29
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.30
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.31
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.32
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.33
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.35
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.36
Ecological Resources Stilwell, David and Tim Sullivan USFWS 2.37
Ecological Resources Davis, Andrew NYSDPS 4.16
Ecological Resources Davis, Andrew NYSDPS 4.17
Ecological Resources Davis, Andrew NYSDPS 4.18
Ecological Resources Davis, Andrew NYSDPS 4.19
Ecological Resources Davis, Andrew NYSDPS 4.20
Ecological Resources Davis, Andrew NYSDPS 4.21
Ecological Resources Davis, Andrew NYSDPS 4.22
Ecological Resources Davis, Andrew NYSDPS 4.25
Ecological Resources Davis, Andrew NYSDPS 4.31
Ecological Resources Gary, Brianna NYSDEC 6.1
Ecological Resources Gary, Brianna NYSDEC 6.2

4-4

003780
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
Ecological Resources Gary, Brianna NYSDEC 6.3
Ecological Resources Gary, Brianna NYSDEC 6.4
Ecological Resources Gary, Brianna NYSDEC 6.5
Ecological Resources Gary, Brianna NYSDEC 6.6
Ecological Resources Gary, Brianna NYSDEC 6.7
Ecological Resources Gary, Brianna NYSDEC 6.8
Ecological Resources Gary, Brianna NYSDEC 6.9
Ecological Resources Gary, Brianna NYSDEC 6.10
Ecological Resources Gary, Brianna NYSDEC 6.11
Ecological Resources Gary, Brianna NYSDEC 6.12
Ecological Resources Gary, Brianna NYSDEC 6.13
Ecological Resources Gary, Brianna NYSDEC 6.14
Ecological Resources Gary, Brianna NYSDEC 6.15
Ecological Resources Evans, William R. Old Bird, Inc. 10.1
Ecological Resources Evans, William R. Old Bird, Inc. 10.2
Ecological Resources Evans, William R. Old Bird, Inc. 10.3
Ecological Resources Evans, William R. Old Bird, Inc. 10.4
Ecological Resources Evans, William R. Old Bird, Inc. 10.5
Ecological Resources Evans, William R. Old Bird, Inc. 10.6
Ecological Resources Evans, William R. Old Bird, Inc. 10.7
Ecological Resources Evans, William R. Old Bird, Inc. 10.8
Ecological Resources Evans, William R. Old Bird, Inc. 10.9
Ecological Resources LeTendre, Gerard 11.1
Ecological Resources LeTendre, Gerard 11.2
Ecological Resources LeTendre, Gerard 11.4
Ecological Resources LeTendre, Gerard 11.5
Ecological Resources LeTendre, Gerard 11.6
Ecological Resources Falcon, Mary 12.2
Ecological Resources Falcon, Mary 12.3
Ecological Resources Chase, Hester 14.1
Ecological Resources Chase, Hester 14.10
Ecological Resources Chase, Hester 14.11

4-5

003781
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
Ecological Resources Chase, Hester 14.14
Save the River and 1000 Islands
Ecological Resources Caddick, Jennifer and Aaron Vogel 19.2
Land Trust
Save the River and 1000 Islands
Ecological Resources Caddick, Jennifer and Aaron Vogel 19.5
Land Trust
Ecological Resources Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.1
Ecological Resources Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.14
Ecological Resources Faulknham, R. Dennis 24.2
Ecological Resources Gormel, Thomas 29.1
Ecological Resources Gormel, Joyce 34.1
Ecological Resources Hirschey, Urban C. 43.1
Ecological Resources Liner, Jillian M. Audubon New York 47.1
Ecological Resources Gregory, Maureen Wiley 53.1
Ecological Resources Gregory, Maureen Wiley 56.1
Ecological Resources Duehkind, Winnie 63.1
Ecological Resources Walker, Tom and Mabel 64.1
Ecological Resources Brown, Thomas 65.1
Ecological Resources Crossby, William and Barbara 68.1
Ecological Resources LaPlante, J.O. 70.1
Ecological Resources LaPlante, J.O. 70.2
Ecological Resources Article: Los Angeles Times 70.4
Ecological Resources Gormel, Joyce 75.8
Ecological Resources Boss, Sarah F. 79.6
Ecological Resources Boss, Sarah F. 79.8
Ecological Resources Brown, Thomas 80.1
Ecological Resources Brown, Thomas 80.2
Brown, Thomas; R. Dennis
Ecological Resources Faulknham, Gerard LeTendre, and 104.1
Clifford Schneider
Ecological Resources Smith, Gerald 109.1
Ecological Resources Docteur, David H. 110.2
Ecological Resources Schneider, Clifford P. 111.7

4-6

003782
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
Ecological Resources/Water
Davis, Andrew NYSDPS 4.13
Resources
Ecological Resources/Water
Davis, Andrew NYSDPS 4.14
Resources
Ecological Resources - Threatened &
Tomasik, Steven for Jack Nasca NYSDEC 1.11
Endangered Species
Ecological Resources - Threatened &
Stilwell, David and Tim Sullivan USFWS 2.38
Endangered Species
Ecological Resources - Threatened &
Stilwell, David and Tim Sullivan USFWS 2.39
Endangered Species
Ecological Resources - Threatened &
Stilwell, David and Tim Sullivan USFWS 2.40
Endangered Species
Ecological Resources - Threatened &
Stilwell, David and Tim Sullivan USFWS 2.41
Endangered Species
Ecological Resources - Threatened &
Stilwell, David and Tim Sullivan USFWS 2.42
Endangered Species
Ecological Resources - Threatened &
Davis, Andrew NYSDPS 4.24
Endangered Species
Facility Layout and Design Stilwell, David and Tim Sullivan USFWS 2.5
Facility Layout and Design Stilwell, David and Tim Sullivan USFWS 2.6
Facility Layout and Design Stilwell, David and Tim Sullivan USFWS 2.10
Facility Layout and Design Stilwell, David and Tim Sullivan USFWS 2.13
Facility Layout and Design Stilwell, David and Tim Sullivan USFWS 2.14
Facility Layout and Design Stilwell, David and Tim Sullivan USFWS 2.34
Facility Layout and Design Davis, Andrew NYSDPS 4.1
Facility Layout and Design Davis, Andrew NYSDPS 4.2
Facility Layout and Design Davis, Andrew NYSDPS 4.4
Facility Layout and Design Davis, Andrew NYSDPS 4.5
Facility Layout and Design Davis, Andrew NYSDPS 4.9
Facility Layout and Design Davis, Andrew NYSDPS 4.10
Facility Layout and Design Davis, Andrew NYSDPS 4.11
Facility Layout and Design Davis, Andrew NYSDPS 4.12

4-7

003783
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
Facility Layout and Design Davis, Andrew NYSDPS 4.35
Facility Layout and Design Davis, Andrew NYSDPS 4.45
Facility Layout and Design Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 7.1
Facility Layout and Design Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 7.2
Facility Layout and Design Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 7.3
Facility Layout and Design Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 7.4
Facility Layout and Design Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 7.5
Facility Layout and Design LeTendre, Gerard 11.3
Facility Layout and Design LeTendre, Gerard 11.8
Facility Layout and Design LeTendre, Gerard 11.9
Facility Layout and Design Falcon, Mary 12.6
Facility Layout and Design Chase, Hester 14.12
Facility Layout and Design Chase, Hester 14.13
Facility Layout and Design Chase, Hester 14.17
Facility Layout and Design Petras, Leigh and James 16.1
Facility Layout and Design Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.11
Facility Layout and Design Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.12
Facility Layout and Design Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.13
Facility Layout and Design Vail, Alan 26.6
Facility Layout and Design Gormel, Thomas 30.1
Facility Layout and Design Gormel, Joyce 37.1
Facility Layout and Design Zovistoski, Mary 38.5
Facility Layout and Design Zovistoski, Mary 38.8
Facility Layout and Design Hirschey, Urban C. 39.2
Facility Layout and Design Hirschey, Urban C. 40.1
Facility Layout and Design Hirschey, Urban C. 40.5
Facility Layout and Design Hirschey, Urban C. 40.8
Facility Layout and Design Hirschey, Urban C. 41.1
Facility Layout and Design Boss, Mark 45.4
Facility Layout and Design Gormel, Joyce 75.2
Facility Layout and Design Gormel, Joyce 75.7
Facility Layout and Design Gormel, Thomas 77.1

4-8

003784
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
Facility Layout and Design Boss, Sarah F. 79.5
Facility Layout and Design Boss, Sarah F. 79.9
Facility Layout and Design Boss, Sarah F. 79.10
Facility Layout and Design Boss, Sarah F. 79.12
Facility Layout and Design Cuda, Kenneth 82.1
Facility Layout and Design Cuda, Kenneth 85.1
Facility Layout and Design Brown, Thomas 93.1
Facility Layout and Design Wiley, Karen 99.2
Facility Layout and Design Schneider, Clifford P. 111.1
Facility Layout and Design Byrne, John 113.2a
Facility Layout and Design Metzger, Don 113.15b
Facility Layout and Design Reinhart, Marianna 113.16a
Facility Layout and Design Reinhart, Marianna 113.16b
Facility Layout and Design Simpson, Carol 113.18
General/Miscellaneous Davis, Andrew NYSDPS 4.23
General/Miscellaneous Davis, Andrew NYSDPS 4.3
General/Miscellaneous Chase, Hester 14.15
General/Miscellaneous Gaudette, Richard and Jan 15.1
General/Miscellaneous Dziekan, Andrew 17.1
General/Miscellaneous Merchant, Jerry 20.1
General/Miscellaneous Zovistoski, Mary 38.4
General/Miscellaneous Bracket, Mr. and Mrs. Montgomery 46.1
General/Miscellaneous Article: Source Unknown 70.5
General/Miscellaneous Gormel, Joyce 75.3
General/Miscellaneous Gormel, Joyce 75.5
General/Miscellaneous Pressly, Nicholas 81.6
General/Miscellaneous Bouchard, Gerry and Michelle 84.1
General/Miscellaneous Internet Article: Daily-John.com 90.1
General/Miscellaneous Gormel, Thomas 97.1
General/Miscellaneous Wiley, Karen 99.5
General/Miscellaneous Graf, David 100.1
General/Miscellaneous Callery, Judith Anne 101.1

4-9

003785
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
General/Miscellaneous Kemmis, Richard J. 102.1
General/Miscellaneous Brown, Thomas 103.1
General/Miscellaneous Brooks, Colin 107.3
General/Miscellaneous Bragdon, Brooks 108.1
Land Use and Zoning Davis, Andrew NYSDPS 4.30
Land Use and Zoning Davis, Andrew NYSDPS 4.33
Land Use and Zoning Chase, Hester 14.3
Land Use and Zoning Chase, Hester 14.4
Land Use and Zoning Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.6
Land Use and Zoning Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 22.1
Land Use and Zoning Hirschey, Urban C. 39.3
Land Use and Zoning Hirschey, Urban C. 43.3
Land Use and Zoning Hirschey, Urban C. 43.4
Land Use and Zoning Walker, Tom and Mabel 64.2
Land Use and Zoning Article: Watertown Daily Times 70.3
Land Use and Zoning Boss, Sarah F. 79.2
Land Use and Zoning Bragdon, Brooks 83.2
Land Use and Zoning Cape Vincent Zoning Law 83.3
Land Use and Zoning - Agriculture Brower, Matthew NYSDA&M 3.1
Land Use and Zoning - Agriculture Brower, Matthew NYSDA&M 3.2
Land Use and Zoning - Agriculture Brower, Matthew NYSDA&M 3.3
Land Use and Zoning - Agriculture Davis, Andrew NYSDPS 4.6
Noise Carr, Paul, Ph.D., P.E. Cape Vincent Township Engineer 7.7
Noise LeTendre, Gerard 11.9
Noise Chase, Hester 14.7
Noise Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.8
Noise Jury, Charles 25.1
Noise Hirschey, Urban C. 43.7
Letter to Editor: Watertown Daily
Noise 94.1
Times
Noise Schneider, Clifford P. 106.1
Noise Article: Utica Observer Dispatch 106.2

4-10

003786
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
Noise Schneider, Clifford P. 111.2
Noise Schneider, Clifford P. 111.3
Noise Schneider, Clifford P. 111.5
Noise Letter: NYSDEC 111.9
Noise Schneider, Clifford P. 113.17b
Operations and Maintenance/
Tomasik, Steven for Jack Nasca NYSDEC 1.9
Decommissioning
Operations and Maintenance/
Tomasik, Steven for Jack Nasca NYSDEC 1.10
Decommissioning
Physiography, Geology and Soils Macura, Daniel 61.1
Physiography, Geology, and Soils Tomasik, Steven for Jack Nasca NYSDEC 1.12
Physiography, Geology, and Soils Nasca, Jack NYSDEC 5.1
Physiography, Geology, and Soils Nasca, Jack NYSDEC 5.2
Physiography, Geology, and Soils Nasca, Jack NYSDEC 5.3
Physiography, Geology, and Soils Hirschey, Urban C. 40.10
Physiography, Geology, and Soils Boss, Sarah F. 79.7
Physiography, Geology, and Soils/
Chase, Hester 14.2
Construction
Physiography, Geology, and Soils/
Davis, Andrew NYSDPS 4.7
Construction/Agriculture
Physiography, Geology, and Soils/
Dimmick, Kris Bernier, Carr, and Associates 112.1
Construction/Agriculture
Physiography, Geology, and
Stilwell, David and Tim Sullivan USFWS 2.15
Soils/Wildlife
Project Purpose, Public Need and
Falcon, Mary 12.7
Benefits
Project Purpose, Public Need and
Chase, Hester 14.8
Benefits
Project Purpose, Public Need and
Chase, Hester 14.9
Benefits
Project Purpose, Public Need and
Gormel, Thomas 27.1
Benefits

4-11

003787
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
Project Purpose, Public Need and
Gregory, Maureen Wiley 52.1
Benefits
Project Purpose, Public Need and
Gregory, Maureen Wiley 58.1
Benefits
Project Purpose, Public Need and
Gormel, Joyce 75.6
Benefits
Project Purpose, Public Need and
Boss, Sarah F. 79.4
Benefits
Project Purpose, Public Need and
Gormel, Joyce 91.1
Benefits
Project Purpose, Public Need and
Brooks, Colin 107.2
Benefits
Project Purpose, Public Need and
Hirschey, Urban C. 113.12b
Benefits
Project Purpose, Public Need, and
Stilwell, David and Tim Sullivan USFWS 2.1
Benefits
Project Purpose, Public Need, and
Stilwell, David and Tim Sullivan USFWS 2.2
Benefits
Project Purpose, Public Need, and
Planning Board Members Cape Vincent Planning Board 112.2
Benefits
Project Purpose, Public Need, and
Planning Board Members Cape Vincent Planning Board 112.3
Benefits
Project Purpose, Public Need, and
Planning Board Members Cape Vincent Planning Board 112.4
Benefits
Project Purpose, Public Need, and
Planning Board Members Cape Vincent Planning Board 112.7
Benefits
Project Purpose, Public Need, and
Planning Board Members Cape Vincent Planning Board 112.10
Benefits
Project Purpose, Public Need, and
Planning Board Members Cape Vincent Planning Board 112.11
Benefits
Recreation Wiley, Karen 99.4
Safety and Security Davis, Andrew NYSDPS 4.46

4-12

003788
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
Safety and Security Falcon, Spencer, MD 13.1
Safety and Security Chase, Hester 14.6
Safety and Security Zovistoski, Mary 38.2
Safety and Security Hirschey, Urban C. 40.4
Safety and Security Hirschey, Urban C. 43.5
Safety and Security Boss, Mark 45.1
Safety and Security Moehs, Charles, MD, MPH 62.1
Safety and Security Hludzenski, Kathryn A. 67.1
Safety and Security Hludzenski, Kathryn A. 72.1
Safety and Security Freislich, Michele L. 73.1
Safety and Security Gormel, Joyce 75.4
Safety and Security Pundt, Art 76.1
Safety and Security Article: Telegraph 88.1
Safety and Security Article: Telegraph 89.1
Safety and Security Wiley, Karen 99.6
Safety and Security Haskins, Janet and James 105.1
Safety and Security Docteur, David H. 110.1
Safety and Security E-Mail 110.3
Safety and Security Hludzenski, Ed 113.14
Safety and Security/Facility Layout and
Boss, Sarah F. 79.14
Design
Safety and Security/Facility Layout and
Moehs, Charles, MD, MPH 92.1
Design
SEQR Process Falcon, Mary 12.4
Save the River and 1000 Islands
SEQR Process Caddick, Jennifer and Aaron Vogel 19.3
Land Trust
Save the River and 1000 Islands
SEQR Process Caddick, Jennifer and Aaron Vogel 19.4
Land Trust
SEQR Process Hanson, Rollin V 71.1
SEQR Process Simpson, Carol 74.1
SEQR Process Gormel, Joyce 75.1
SEQR Process Boss, Sarah F. 79.3

4-13

003789
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
SEQR Process Dziekan, Andrew 87.1
SEQR Process Levy, Ann E. 96.1
SEQR Process Drabicki, Judy, Esq. Wind Power Ethics Group 98.1
SEQR Process Drabicki, Judy, Esq. Wind Power Ethics Group 113.4
SEQR Process Nasca, Jack NYSDEC 113.19
Socioeconomics LeTendre, Gerard 11.7
Save the River and 1000 Islands
Socioeconomics Caddick, Jennifer and Aaron Vogel 19.8
Land Trust
Socioeconomics Vail, Alan 26.2
Socioeconomics Vail, Alan 26.3
Socioeconomics Vail, Alan 26.4
Socioeconomics Vail, Alan 26.5
Socioeconomics Gormel, Thomas 32.1
Socioeconomics Gormel, Joyce 35.1
Socioeconomics Gormel, Joyce 36.1
Socioeconomics Hirschey, Urban C. 40.2
Socioeconomics Hirschey, Urban C. 43.8
Socioeconomics Hirschey, Urban C. 43.10
Socioeconomics Hirschey, Urban C. 44.1
Socioeconomics Gregory, Maureen Wiley 57.1
Socioeconomics Gregory, Maureen Wiley 59.1
Socioeconomics Hludzenski, Kathryn A. 66.1
Socioeconomics Boss, Sarah F. 79.13
Socioeconomics Wiley, Karen 99.1
Socioeconomics Wiley, Karen 99.3
Socioeconomics Schneider, Clifford P. 111.4
Traffic and Transportation Davis, Andrew NYSDPS 4.26
Traffic and Transportation Davis, Andrew NYSDPS 4.27
Traffic and Transportation Davis, Andrew NYSDPS 4.28
Traffic and Transportation Fucillo, Thomas J. Menter, Rudin & Trivelpiece, P.C. 21.4
Traffic and Transportation Gormel, Thomas 28.1
Traffic and Transportation Zovistoski, Mary 38.1

4-14

003790
FINAL ENVIRONMENTAL IMPACT STATEMENT
PROPOSED ST. LAWRENCE WINDPOWER PROJECT
TOWNS OF CAPE VINCENT & LYME
JEFFERSON COUNTY, NEW YORK

Table 4-1
Saint Lawrence Windpower Project DEIS Response Summary Ordered by Subject
Comment
Subject Commenter Agency
ID 1
Traffic and Transportation Hirschey, Urban C. 43.2
Traffic and Transportation Boss, Mark 45.2
Traffic and Transportation Gregory, Maureen Wiley 54.1
Traffic and Transportation Gregory, Maureen Wiley 55.1
Traffic and Transportation Boss, Sarah F. 79.11
Traffic and Transportation/
Davis, Andrew NYSDPS 4.29
Construction
Utilities and Community Services Hirschey, Urban C. 39.1
Utilities and Community Services Boss, Mark 45.3
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