The United States Fish and Wildlife Service (USFWS) sent two letters October 12, 2005 to David Perry, Executive Vice President of Chautauqua Windpower LLC, severely critical of the draft Avian Risk Assessment (ARA) completed by Chautauqua Windpower and its consultants for the proposed wind power development in the Towns of Ripley and Westfield, Chautauqua County, New York. The shorter of the two letters focuses on the ARA’s attention to migrating and resident American Bald Eagles; the longer of the two letters consists of a broader evaluation of the ARA and its attention to all resident and migrating birds. The pdf file below is a brief summary of the USFWS letters criticizing the risk assessment. The full text of the two USFWS letters is available via the link below.

Sue Sliwinski took a 9 day, 3000 mile trip visiting 7 wind farms across several states. Here's her report.

September 2, 2005 City of Lackawanna Planning and Development Board Room 311, City Hall 714 Ridge Road Lackawanna, NY 14218 Attn: Joseph G. Geyer Re: Steel Winds Wind Farm Route 5, Former Bethlehem Steels works Lackawanna, NY Dear Mr. Geyer; The New York Sate Department of Environmental Conservation (DEC) staff have performed an initial review of the information and material provided with the City of Lackawanna’s SEQR Notice of Coordinated Review and Declaration of Intent to Act as Lead agency. These materials include the Application for Site Plan Approval and Certain Area variances to Authorize Construction and Operation of a Wind Energy Facility on a Portion of the Former Bethlehem Steel Works Site in Lackawanna, New York (the Application), and the Analysis of Environmental Impacts pursuant to SEQR (The EA). Please be advised the DEC does not object to the City of Lackawanna assuming the role of lead agency, but the DEC does reserve the right to comment on this action if a positive determination is made. As indicated in the following text of this letter, DEC staff have concerns for the potential impacts of certain aspects of this project. Our comments and concerns are listed below under the appropriate topic.

In community after community where industrial-scale "wind farms" have been proposed, mundane and sparsely-attended board meetings have been transformed into standing-room-only affairs. Residents and property owners are anxious to know whether rumored plans to construct twenty, fifty or even a hundred of the 400-foot tall wind turbines are "a done deal." Most significantly, the electorate wants to know the extent to which their town has the power to decide whether or not wind farms will dominate their rural landscape. /p

I am writing on behalf of the Board of Directors for the Braddock Bay Bird Observatory concerning the recent EIS issued for the Prattsburgh/Italy Wind Farm.....All BBBO Board members are trained ornithologists with extensive knowledge about local breeding and migratory birds. In addition, the Board has considerable expertise in methodologies and techniques used to assess and census breeding and migratory bird use of the local landscape (e.g. radar, breeding and migratory bird surveys, bird banding, population demographic, etc).... BBBO’s Board of Directors was surprised and shocked to see our organization’s data used in Ecogen’s EIS. We were not informed or consulted about the use of our data and, furthermore, we were not sent a copy of the draft EIS to review.

"In response to emerging market conditions, and in recognition of the unique operating characteristics of wind generation, the New York Independent System Operator (NYISO) and New York State Energy Research and Development Authority (NYSERDA) commissioned a joint study to produce empirical information that will assist the NYISO in evaluating the reliability implications of increased wind generation. The work was divided into two phases. Phase 1, Preliminary Overall Reliability Assessment, was completed in early 2004. This initial phase provided a preliminary, overall, screening assessment of the impact of large-scale wind generation on the reliability of the New York State Bulk Power System (NYSBPS).

This document was prepared by General Electric International, Inc. in Schenectady, NY. It is submitted to THE NEW YORK STATE ENERGY RESEARCH AND DEVELOPMENT AUTHORITY (NYSERDA).

Editor's Note:

In the Executive Summary, GE argues that 'imbalance' penalties should not be imposed on wind: "subimbalance penalties should not be imposed on wind generation. Wind projects would need to settle discrepancies between their forecast and actual outputs in the energy balancing market. However, because wind is largely nondispatchable, any additional penalties for imbalance should be eliminated. [emphasis added] The FERC Order 888 allows imbalance penalties to be applied to generators that operate outside of their schedule. As applied in New York, any “overgeneration” can be accepted without payment and any “undergeneration” is priced at the greater of 150% of the spot price or $100/MWh. Strict application of these policies in the MAPS analysis performed would result in the loss of roughly 90% of the wind generation revenue, which would be disastrous to their future development."(page 2.8)

The DEC Staff's four major points are as follows:

(1) The proposed project area is an extremely important bird/raptor migration area

(2) Data collection methodology and duration for this project is extremely limited

(3) The mortality constant chosen and its application to available date are inappropriate

(4) Bald eagles and other protected species do and can be expected to us the project area.

"On November 10, 2004, the New York State Public Service Commission (“Commission”) published two Notices of Proposed Rulemaking (“Notices”), identified as SAPA No. 03-E-1088SA2 and SAPA No. 03-E-1088SA3, in the State Register. These Notices indicate that the Commission is requesting comments on certain proposed measures intended to implement the renewable portfolio standard (“RPS”) that was adopted by the Commission by order issued September 24, 2004 (“RPS Order”)."

In August 2004, Chautauqua County Citizens for Responsible Wind Power submitted a letter to the NYSERDA Board of Directors outlining our concerns about NYSERDA’s involvement with the proposed Chautauqua County wind energy project. Mr. Vincent DeIorio initially responded to us in a letter dated August 24, 2004. Mr. Peter Keane then provided a supplemental response in his September 29, 2004 letter. We find that both of these letters do not address the core issues outlined in our August 2004 letter. The following summarizes our concerns in context of the responses provided by NYSERDA to date:

...I want people to be well aware of the negative side of these giant windmills before allowing them to be built in your neighborhoods.