August 7 2009
Mr. Thomas Reinbeck, Supervisor
Town of Cape Vincent
PO Box 680
1964 NYS Rt 12E
Cape Vincent, NY 13618
Re: Wind Moratorium in Town of Cape Vincent
Dear Mr. Reinbeck,
Save The River respectfully submits the following comments regarding the establishment of the one-year moratorium on wind energy development in the Town of Cape Vincent. In short, Save The River urges the Town to enact a one-year moratorium throughout the entire Town, for all projects currently under development and future projects for one full year. Additionally, we recommend that a moratorium should not be lifted until additional study is completed on the potential ecological impacts of wind development in the Town and until a regional or state-wide process exists to examine cumulative regional impacts of wind energy development.
Save The River is supportive of alternative energy development but projects must be properly sited to minimize ecological damage and appropriate ecological impact studies must be fully completed. We remain very concerned about the lack of depth and breadth of the environmental studies conducted for both the Acciona and BP projects proposed in the Town of Cape Vincent, as well as the overall site review process.
As a result, Save The River urges the Town to implement a one-year moratorium on all wind energy development (current and future) or until the following conditions are met:
- Regional study and review process in place and active - The many wind energy projects proposed along the St. Lawrence River valley represent the largest industrial development in the region since the building of the St. Lawrence Seaway and related hydropower facilities. As with the Seaway, the ecological impacts of wind energy development are not constrained by political boundaries. A regional or state process must be put in place to review and assess potential areas that may be appropriate as well as potential areas that may not be appropriate for turbine placement. Additionally, a process must be in place for evaluating and making recommendations regarding the cumulative ecological impact of these facilities. Until a strong system is in place to evaluate and review regional impacts of these energy projects, it is irresponsible to move forward.
- Rigorous SEQR and EIS study and review - Over the past few years, Save The River has raised serious concerns about the limited nature of the ecological studies conducted as part of the environmental impact statements required by the SEQR review of projects proposed in the Town of Cape Vincent. To date, these concerns have not been addressed. Additionally, the reviews conducted by the SEQR process fail to show what the significant adverse environmental impacts might be and do not contain information necessary to evaluate project alternatives. Because the SEQR process has not been applied in a more rigorous nature and full scientific studies have not been conducted on the potential ecological impacts of the wind projects, the Town does not have enough information and data to move forward with decision-making about placement of wind energy facilities.
We encourage the Town of Cape Vincent to take the additional time necessary to review the potential environmental impacts of wind energy development in the Town by implementing a full, one-year moratorium. It is anticipated that wind energy facilities will be in operation for 20-30 years. Taking a relatively short amount of time to study, understand, and plan for the mitigation of any potential impacts will have long-term benefits in ensuring that this development has limited impact on the environment of our region.
Jennifer J. Caddick
Executive Director & Upper St. Lawrence Riverkeeper