Heritage Landscapes offers the following comments on the SSEIS [Second Supplemental Environmental Impact Statement] for the Jordanville Wind Power project, on behalf of Otsego 2000. In our considered opinion the SSEIS fails to sufficiently address the scope of environmental and visual impacts for the project area. Specifically, the following impacts that were outlined in Heritage Landscapes’ response to the DEIS [Draft EIS], SDEIS [Supplemental EIS], and FEIS [Final EIS] have not been adequately addressed or revised in the SSEIS:
• Impacts to cultural resources
• Visual impacts, daytime and nighttime lighting visual impacts of project, and specifically impacts to sensitive receptors (e.g. scenic and cultural resources)
• Consideration of mitigation strategies that directly address proposed project impacts
After reviewing the SSEIS as well as supplemental information provided in Appendix K and Appendix M, Heritage Landscapes asserts that the SSEIS is incomplete and fails to address concerns regarding visual impacts to scenic and cultural resources. Impacts to these resources cannot be fully addressed if the SSEIS is incomplete. Overall, the the SSEIS fails in several aspects. More specifically the SSEIS:
• Inadequately addresses effective mitigation strategies including
– Relocating the project
– Downsizing the project further
– Moving turbines
– Lowering the height of turbines
– Mitigation impacts on more than adjacent properties
– Providing meaningful and comprehensive mitigation for the resources affected
• Skirts specific issues brought up in the review of the DEIS, SDEIS, and FEIS by using vague and unclear language and ignoring other issues altogether.
• Includes numerous inconsistent statements throughout on levels of wind turbine visibility and mitigation strategies.
• Significantly downplays impacts to cultural landscapes and other cultural resources to include the Holy Trinity Monastery, Glimmerglass Historic District, Lindesay Patent Rural Historic District, Waggoner Patent Historic District, Potential Jordanville Rural Historic District, New York State Route 20 Scenic Byway, Mohawk Valley Heritage Corridor, Erie Canal National Heritage Corridor, and Adirondack Park.
• Incorrectly compares wind turbines and related features to other modern intrusions such as utility lines, concrete silos, and signs that are modern intrusions that have previously altered settings of cultural resources. Comparison is expressed without acknowledgement of the large scale and context of the proposed multiple Jordanville project elements to impacts that can be predicted from the proposed wind turbines, new access roads and power transmission features.
In summary, the impacts of the proposed Jordanville Wind Power Project to designated, valued resources and cultural landscapes are significant and are not effectively mitigated.
The applicant has failed to fully explore alternatives or mitigation measures that would lessen impacts to scenic and cultural sites. Mitigation strategies were not explored in detail, but were summarily dismissed as unfeasible or not able to decrease or mitigate impacts. The project neither adequately addresses visual impacts within the project area, nor visual impacts outside of the 10-mile project radius claiming to abide by the OPRHP 5-mile guidelines, which are outlined in their “generic wind farm survey guidance.” (Page 1, OPRHP letter, dated 22 January 2007) However, previous comments have clearly expressed that the impacts of the Jordanville project range well beyond this generic 5-mile limit. …
Patricia M. O’Donnell, FASLA, AICP, Principal, Heritage Landscapes
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