BP Wind Energy has failed to meet several state requirements in its preliminary scoping statement for the proposed Cape Vincent Wind Farm and used a half-century-old map for its turbine site plan, according to state Department of Public Service staff.
“The mapping included in the PSS is seriously out-of-date United States Geological Survey (USGS) topographic quadrangles published circa 1958,” the department’s staff said, recommending that BP use the most recent 2012 edition.
The state Department of Environmental Conservation also criticized BP’s 222-page scoping document in a formal response, telling the wind developer that its PSS is not in compliance “with either the intent or spirit” of the requirements of Article X of state Public Service Law.
“It also appears to DEC that the PSS is, for the most part, very general in nature, lacking in specificity of important local elements to this particular project, and devoid of ‘as much information as is reasonably available concerning the proposed facility,’” DEC said. “Many of the applicant’s responses to comments and questions raised during consultations remain unanswered, or simply state that they will be addressed in the application.”
Both state agencies suggest that BP should have listed turbine model and specifications under consideration rather than keeping the scope of the project vague.
“The description of the proposed facility as being 124-turbine sites with a total size range of 200-285 MW (megawatt), and individual turbines sizes in a range of 1.7 to 3.0 MW is problematic, in that several of the exhibits required by the rules specify that data and information for specific turbines or turbine sizes is needed to complete the application,” DPS staff said.
Furthermore, if the developer proposes to erect 124 3-megawatt turbines, the wind project’s maximum output would be well over 285 megawatts, state staff pointed out.
Additionally, Department of Public Service staff makes many more requests and recommendations in its 60-page response to BP’s statement, several of which closely relate to local concerns raised during the public involvement program phase and upon the PSS submission.
Moving forward, DPS staff said, follow-up discussions should be planned to address this and related topics with interested parties in attendance “before the applicant advances to final scoping or application phases.”
DPS staff’s requests to the wind developer include:
■ Provide one or more alternative layouts with a reduced project footprint and an alternative arrangement that avoids locating wind turbines in exclusion zones identified in Cape Vincent’s zoning regulations.
■ Conduct noise studies pursuant to Cape Vincent’s zoning law and submit noise mitigation plans.
■ Include shadow flicker and land value impacts as potentially having effects on existing or potential future land use.
■ Provide a wind turbine collapse-and-blade-throw analysis.
■ Provide an analysis of public health issues due to a potential damage to the region’s water supply infrastructure during the construction phase.
■ Provide an analysis on reported problems of low-frequency or infrasound from operating wind energy projects.
■ Provide a breakdown of seasonal avian and bat mortality rates, in addition to annual calculations.
■ Abide by state requirements for wind turbine setback from electric transmission facilities of 1.5 times the turbine’s height, including the blades.
■ Prove the “function test program” for each turbine model under consideration and describe how it will ensure that the entire wind turbine has been thoroughly tested and all safety systems work.
■ Update the list of stakeholders to include the town and village of Clayton and the town of Brownville.
■ Conduct group interviews to identify important landscape characteristics and values attributed by landowners, residents, visitors/tourists, recreational users and others.
“The description of the scope of studies anticipated for many of the topic areas identified are general rather than specific as to methodologies to be employed, the study area parameters, and other details appropriate for indicating the methodology, intended extent and duration of studies proposed,” the department’s staff said.
Regarding some of BP’s responses to stakeholder comments, DPS staff said that it “found that the applicant’s responses provide no new information and failed to adequately address the issue/comment” and that the some of the information tables were “not well-organized or easy to understand.”
Department staff also asks that the developer’s “five-mile radius study area” be further expanded “as appropriate to address view shed resources that may be adversely affected by project siting and operation” and include the areas within Ontario, Canada.
Additionally, DPS staff asks for further discussions on several topics – such as land use analysis and impact mitigation considerations – between the applicant and other “interested parties.”
“In a region that has a significant reliance on tourism as an economic mainstay, the potential for adverse impacts on tourism, heritage and tourism resources and attractions should be undertaken as part of the application,” DPS’s staff said.