Avian advocate Clifford P. Schneider argues that Apex Clean Energy’s Galloo Island wind project should not move forward in the state Article 10 law review process because it lacks the sufficient environmental studies needed to assess the project’s potential impacts.
Mr. Schneider, a former fishery biologist for the state Department of Environmental Conservation, said Friday in a letter to the state Board on Electric Generation Siting and the Environment that the avian and bat studies from 2007, 2008 and 2009 the developer proposes to include in its project application are “stale” and “woefully inadequate” to assess the project. Mr. Schneider said the siting board should deem the application incomplete if the developer does not include new studies in its application.
While the Apex Clean Energy plans to submit avian and bat studies from 2015, according to its stipulation agreements with several state agencies, Mr. Schneider said the studies were conducted for the project’s previous owner, Hudson Energy Development, and Apex Clean Energy should conduct its own assessments. Mr. Schneider also argued the developer ignored concerns from Michael S. Caruso, an administrative law judge from DEC, about it using older studies, citing the transcript for a pre-application conference in July.
“You’ve probably got one of the most sensitive sites in New York state,” Mr. Schneider said. “You at least have to assume responsibility and do a little more than any other site.”
The former DEC biologist in his letter recommended a few additional avian studies he said Apex Clean Energy should conduct for the siting board to assess the project’s potential impacts.
Mr. Schneider said the developer should conduct two years of radar studies to determine the potential collision and mortality rates for migrating birds over the island, a similar request to one he made in November. While the developer planned to submit two radar studies conducted in 2008, one conducted in the fall and one conducted in the spring, Mr. Schneider said in his letter that the studies were “not only outdated, but have deficiencies” because their scope was too small and they do not account for the current project’s specifications.
“They should have done two or three years of surveys,” Mr. Schneider said.
The former DEC biologist also said in his letter that studies should be conducted to evaluate the potential impacts infrasound emitted from turbines could have on water birds at Little Galloo Island.
Mr. Schneider said DEC should collect feathers this year and next year for a corticosterone assessment to determine if future Galloo Island Wind operations lead to population declines and breeding problems. Corticosterone is a stress hormone in birds, Mr. Schneider said. He also said a laboratory study should be conducted on waterbird eggs in 2018.
“DEC has been tracking those populations on Little Galloo for years,” Mr. Schneider said. “(Little Galloo) is a special place and is one of a kind in New York State.”
Apex Clean Energy should also have new winter bird surveys conducted to assess the project’s potential impacts on bald eagles and other raptors that live on the island during the winter, Mr. Schneider said in his letter.
Mr. Schneider said descriptions of raptor abundance in Old Bird Inc.’s 2009 avian risk assessment and winter bird survey, which were conducted for Upstate NY Power’s Hounsfield Wind project, that Apex Clean Energy planned to submit in its final application are outdated and have too many discrepancies to assess the Galloo Island Wind project.
“(Apex Clean Energy) has worked closely with the relevant state agencies and qualified experts to develop study scopes,” said Neil T. Habig, senior director of project development for the developer. “We are confident that our application will address the Article 10 requirements.”
In addition to conducting additional studies, Mr. Schneider in his letter said the developer should provide proof of public need for a wind energy facility on the island in addition to the “casual references to a greater public need for renewable energy to combat climate change.” He also said the siting board should have a comparative assessment conducted for one of Apex Clean Energy’s other wind energy facilities in the country, adding that comparative assessments are required by the siting board for the Article 10 review process.
The developer claimed in the stipulations document that its subsidiary, Galloo Island LLC, which it listed as the “applicant,” does not have other sites for comparison other than “what is owned by or under option to the applicant on Galloo Island,” but proposes to describe the feasibility of developing solar energy facilities compared to wind energy development and a description of the project.
Mr. Schneider said that providing a comparative assessment was in the rules. “It was part of the law,”
Apex Clean Energy plans to build 30 turbines with each 3.6-megawatt turbine “just under” 600 feet. Mr. Habig said the developer will submit an application in the “coming weeks.”
“It takes a lot of effort to get the details coordinated,” he said.
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