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It is not at all clear from the DEIS that state or federal law will be upheld in the Ellenburg Project with regard to wetlands. Because of the vagueness and apparent project dominance of decisions being made with regard to wetlands, on-site NYSDEC and federal (USACE) oversight will be critical to modify turbine placement decisions during the project planning phase, to oversee them (to prevent changes) during the construction phase, and to oversee other mitigation measures.
Abstract:
1) Benefits claimed for wind power are inflated by failure to use realistic, published capacity factors. No evidence is presented to support industry claims that production of wind-generated electricity lessens fossil fuel consumption.
2) The quality of the DEIS is superficial and presentation is deceptive. The avowed goal of the company which prepared the DEIS is fast permitting, not protection of environment or community.
3) Safety with regard to turbine fires, lightning strikes, and ice or blade throw is not adequately addressed.
4) Data on turbine stability in the presence of earthquakes is not presented. The DEIS preparers failed to note an earthquake of magnitude 5.1 which occurred 25 miles from the proposed project area in 2002 and caused $4 million worth of damage. Setback of 500 ft. from roads and 587 ft. from on-site buildings, as specified in the Ellenburg, Clinton, and Altona Wind Energy Facilities Ordinances, is not adequate to protect the public should one of these slender 400 ft. structures with 100 tons of equipment near the top fall over.
5) Noise standards adopted in the Ellenburg, Clinton, and Altona Wind Energy Facilities Ordinances do not comply with community noise standards promulgated by non-industry agencies such as the NYS DEC or the World Health Organization, and as such will not protect the public from the health impacts of excessive community noise. Noise modeling did not use up-to-date models of the known distant propagation of annoying noise from wind turbines under conditions of nighttime atmospheric stability. Noble Environmental’s acoustics consultant is well aware of these models and was negligent in not requiring their use. While recognizing that wind turbines produce low-frequency noise, the acoustics consultant appears to be ignorant of the medical research literature on the brain, lung, and heart pathology caused by long-term exposure to noise at frequencies too low to be heard.
6) Shadow flicker produces symptoms of motion sickness in susceptible people and has the potential to trigger seizures in individuals with epilepsy.
7) Bird and bat studies are inadequate with regard to standards communicated by USFWS to Noble with regard to migratory birds, threatened and endangered species, and eagles. No population figures can be derived from the data obtained and presented in the DEIS. Multi-year studies were not performed. There is no adequate baseline created here by which to use this wind turbine installation to study the effects of wind turbines on bird and bat populations.
8) The non-avian wildlife section shows incompetence. As in (7), no population data is presented on which to base studies of the effects of wind power development on game species such as deer and bear.
9) It is not clear in the DEIS that appropriate state and federal (Army Corps of Engineers) oversight and permitting has taken place with regard to wetlands within the project areas. In fact it has not, according to the responsible Army Corps of Engineers official I spoke to on May 31, 2006, at which point review of the Clinton Project application was in the early stages and review of the Ellenburg and Altona Project applications not yet under way. Permits are required for all activities impinging on any wetland or stream connected ultimately to a navigable waterway. Federal review under the Fish and Wildlife Coordination Act and the National Historic Preservation Act are also required, triggered by projects falling under Army Corps of Engineers jurisdictio
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