APEX CLEAN ENERGIES GALLOO ISLAND WIND    SOCIOECONOMIC IMPACTS

The following is an excerpt from exhibit 27, of Apex Clean Energies recently submitted application to the Public Service Commission  for a Certificate of Environmental Compatibility and Public Need Pursuant to Article 10 to Construct a Wind Energy Project on Galloo Island, NY

Exhibit 27 Socioeconomic (p.4)


With respect to the Galloo Island Facility, the Applicant reviewed the default project cost values subtotaled by each of the following categories in the JEDI model to determine whether they were on par with the real costs as experienced by the Applicant: Equipment during Construction, Balance of Plant Construction, Labor during Operation & Maintenance, Materials and Services during Operation & Maintenance, Financial Parameters, Tax Parameters, Land Lease Parameters and Payroll Parameters.

Adjustments were made to specific default values and included replacing the default local tax value ($0) with the known estimated annual payment in lieu of taxes (PILOT) value ($816,750); increasing the default value of Land Easements during Construction ($0) to the known $6.3 million cost required for purchasing the Galloo Island parcel containing the turbines ($3 million) and a one-time lease of an underwater parcel for constructing the underwater high-voltage transmission line ($3.3 million); decreasing the default value of Annual Lease during Operating Years ($326,700) to the known value ($0); decreasing the default Total Cost of Equipment during Construction value from $136.8 million to a more reasonable value of $108.9 million (due to a lower cost for turbine components); and increasing the default Balance of Plant Total value from $47.4 million to a more reasonable value of $137.0 million (reflecting the higher cost of island development). The remaining cost values were uncertain at the time of analysis (July 2017), therefore the remaining default values were reviewed and determined to be reasonable estimates based on previous experience in wind energy development by the Applicant.

Full Exhibit

Letter ~ Galloo Island Wind LLC ~ Disregard_Hounsfield_Findings

December 05/2016 Letter to New York State Public Service Commission urging them to require APEX to to undertake a comprehensive series of studies in 2017 to build on the previous work, not to rely almost totally on the dated, eight-year old Hounsfield studies.

Galloo Application Incomplete



RE: GALLOO ISLAND WIND, LLC. Case No. 15-F-0327
Date: October 19, 2017
Document title: Galloo Application Incomplete
Submitted by:
Clifford P. Schneider, pro se





October 19, 2017
Mr. John B. Rhodes, Chair
NY Department of Public Service
Three Empire State Plaza
Albany, New York 12223-1350
RE: GALLOO ISLAND WIND, LLC. 15-F-0327
Dear Chairman Rhodes:
I am writing to you because as chair to the Siting Board you have the statutory responsibility to determine if the Application provided by Apex Clean Energy for their Galloo Island Wind Facility is complete. I am therefore requesting that you carefully consider Apex Clean Energy’s application, because there are serious survey deficiencies that require further investigation by the Applicant to ensure that the record is properly informed.
Apex’s application should be considered incomplete until those deficiencies can be properly addressed. Although I have outlined a number of concerns in previous filings to DPS, the most important study deficiency relates to quantifying avian migration activity over Galloo Island each spring and fall. This issue, if you recall, was also specified in the Power NY Act of 2011. Additionally, at the Pre-Application Conference for the Galloo project held on July 28, 2016 the presiding examiner remarked the avian report should be updated from eight to ten years ago.
First, Galloo Island and its neighbor Little Galloo Island, are special and unique habitats that are home to important, valuable avian and bat resources. There are a whole series of state and associated records and policies that testify to their importance, e.g., New York Open Space Management Plan, Lake Ontario Islands Wildlife Management Plan, NYSDEC Lake Ontario Bird Conservation Area, FEIS for NY Clean Energy Standard and Audubon Important Bird Area.

In spite of the special status associated with Galloo and Little Galloo Islands, Apex plans to develop a large-scale, industrial wind project. With that development, however, comes a responsibility incumbent on all of us, not just the Siting Board, that we evaluate the risks of their project properly. Due diligence, in the case of
__________

1 Transcript July 28, 2016 Pre-Application Conference, p.38, line 9.

___________________________________________________________________________________________________________________________________
assessing Galloo’s special resources, requires a little more to examine risks and impacts, not less.
Apex’s application relies principally on old, now out-of-date avian studies conducted from 2007-2009 for the first wind development attempt on Galloo, the Hounsfield Wind Farm. The supplemental studies undertaken in 2015 provide no additional insight into the Galloo project’s risk to migratory birds and bats – none! For this reason alone Apex’s application at this time should be deemed incomplete.
Apex’s failure to properly assess impacts to migrating birds and bats relates to two specific issues, failure to consider that Galloo’s proposed turbine models are 176 ft taller than those that were the basis for the 2008-2009 studies. Secondly, the decade old, 2008 radar study should have included two full migratory seasons of baseline assessment, and it should also have included the use of recent improvements in radar technology.
Apex’s single 2008 radar study focused the potential impacts on a turbine rotor zone with a maximum height of 410 ft. The number of birds and bats that flew through this zone in spring 2008 was greater than 30 other radar studies Apex referenced for comparison – none were greater. With Apex’s 586 feet tall wind turbines, larger rotors and higher blade tip speeds, exposure of these high densities of avian migrants to potential turbine collision mortality will be far greater with Apex’s current proposal.
In addition, increased turbine height negates much of the assessed impacts of bat activity within the rotor zone reported in Apex’s 2008 Migrating Bat Study. In 2008, Apex placed microphones at various heights on meteorological towers in an effort to describe bat activity within the rotor zone. That may have been useful with 410 ft turbines, but with the 586 ft turbines now proposed by Apex those results would only be useful in describing bat activity BELOW the rotor zone. Consequently, using old, outdated surveys will provide no insight into the risks to bats from Apex’s proposed wind project and do not properly inform the record.
With respect to the 2008 radar study, Apex tried to rehash their 2008 data in its application to reflect this increase in rotor height, but

_____________________________


  2 See Section 5.0 Expanded Pre-Construction Surveys in Guidelines for Conducting Bird and Bat at Commercial Wind Energy Projects, NYSDEC , Div. Fish, Wildlife & Marine Resources, August 2009, 31pp.

_________________________________________________________________________________


by their own admission they concluded it was invalid: “Due to the challenges of comparing data using different radar technologies, the statistics resulting from the reanalysis are not considered valid measures of avian or bat activity and therefore should not be used as indices of risk.”. Furthermore, the USFWS in reviewing Apex’s 2008 radar study also concluded, “Given these and other factors, the Service believes the study does not adequately characterize wildlife movement and risk at this site.” A number of other conclusions from experts add to the concern that Apex’s radar study must be redone:  
                                          




Retired biologist claims Galloo Island Wind developer’s application is incomplete

Biologist argues Apex bid deficient Galloo island: Schneider claims wind application uses outdated, flawed studies

Galloo Island Wind Farm - How Important to NY's Energy Future?


Galloo Island Wind Farm - How Important to NY's Energy Future?

When the 100 MW Galloo Island Wind Farm gets plugged-in every electron it produces will be transmitted downstate. Future demand for electricity in New York is about meeting downstate needs, not upstate.

Any wind farm in New York is lucky if they average one-third of rated capacity. For the Galloo project it would mean producing 289,000 MWh each year.

How will this production help meet New York's downstate electric need? Better yet, what would downstate households have to do to reduce demand so that we would not have to despoil Galloo Island with 30, 500+ ft high wind turbines?

If each downstate household (4.8 million) replaced a single 60 watt incandescent light bulb with a 10 watt compact fluorescent for three hours of daily use, it would save more electricity than that produced by the proposed Galloo Island project.

Why ruin a unique Lake Ontario island habitat if it could be saved by having downstate households replace a single light bulb.



GALLOO ISLAND TURBINES CLEARED by FAA
DETERMINATION OF NO HAZARD TO AIR NAVIGATION

Today 9/05/2017 the FAA Issued a determination of no hazard to Apex Clean Energy for their Galloo Island Industrial wind project.

The FAA conducted an aeronautical study to determine the effect the proposed Galloo Island wind turbines would have on the safe and efficient use of navigable airspace by aircraft and on the operation of air navigation facilities.
Today the FAA issued a determination of no hazard for the proposed Galloo Island wind project.
This determination becomes final on October 15, 2017 unless a petition requesting additional review is filed on or before October 05,2017 information concerning filing a petition for review is included in the FAA Obstruction determination letter below.

Each turbine included in the proposed the Galloo Island Industrial Wind Project (T1 throughT30) received the same letter of determination.

Link here to FAA Website to view determined cases

 Galloo FAA Aproval Letter by pandorasboxofrocks on Scribd


Apex Galloo Project in the Path of Ft. Drum Aviation Training Route

Apex Clean Energy’s proposed Galloo Island Wind Farm is directly in the path of a Ft. Drum military aviation training corridor. Currently the project is under FAA review for an obstruction hazard and potential conflicts with aviation operations. In a July 28, 2017 public notice the FAA made a preliminary determination that the project would “have no effect on any airspace and routes used by the military.” However, no mention was made to a 10-mile wide Ft. Drum military aviation training route that encompasses all of Galloo Island.
Wikepedia (https://en.wikipedia.org/wiki/Military_training_route) provided the following information on Military Training Routes:


“Military training routes (MTRs) are aerial corridors (such as IR801 for Jefferson County) across the United States in which military aircraft can operate below 10,000 feet faster than the maximum safe speed of 250 knots that all other aircraft are restricted to while operating below 10,000 feet. The routes are the result of a joint venture between the Federal Aviation Administration and the Department of Defense to provide for high-speed, low-altitude military activities. Military Training Routes are divided into Instrument Routes (IR), and Visual Routes (VR). Each route is identified by either of these two letters, followed by either four digits for routes below 1,500 feet above ground level, or three digits for routes extending for at least one leg above 1,500 ft AGL. (Note - over Galloo aircraft could be just above the 600 foot  turbine height). The difference between the IR and VR routes is that IR routes are flown under Air Traffic Control, while VR routes are not.”


IR801 Military Route.jpg
IR801 is a circular military training route with a 10-mile wide corridor that encompasses all of Galloo, Little Galloo and Stony Islands.


“Each route is defined by a number of geographical coordinates and their respective navaid fixes. From this line the corridor is extended a specific number of miles, in the vast majority of cases this is five miles, making the corridor 10 miles wide. The Routes are individually operated through one of the local military air bases (Ft. Drum), which schedule and 'own' the route.”

The FAA notice leaves a number of unanswered questions. Why no mention of IR801, the Ft. Drum military training route? The training route is designed for low altitude, higher speed flight, the type of operation with obvious potential hazards and conflicts.  Why has there been no acknowledgement of the potential conflict between Apex’s  turbines and Ft. Drum training flights? If there has been some negotiation, mitigation or change to IR801, then why no acknowledgement or documentation? The FAA’s website has a provision for requesting all documentation associated with each case, but the only documentation currently available is the public notice itself.

Link here to the   FAA website

APEX’s GALLOO PROJECT HAZARDOUS to FORT DRUM AIR OPERATIONS ?

The Galloo Island Wind Farm is currently under FAA review for aviation conflicts. It’s current status is ‘circularized’, which entails a potential hazard to aircraft operation and is open for comments from the public. For many mariners on Lake Ontario, military aircraft flights over Galloo have been a frequent sight for years. Now we can understand why the FAA has been slow to make a final determination on Apex’s application and why Apex may be waiting for FAA’s final decision on the Galloo project’s impact on Ft. Drum flight operations.
Wikepedia (https://en.wikipedia.org/wiki/Military_training_route) provided the following information on Military Training Routes for military aircraft:

“Military training routes are aerial corridors (such as IR801 for Jefferson County) across the United States in which military aircraft can operate below 10,000 feet faster than the maximum safe speed of 250 knots that all other aircraft are restricted to while operating below 10,000 feet. The routes are the result of a joint venture between the Federal Aviation Administration and the Department of Defense to provide for high-speed, low-altitude military activities. Military Training Routes are divided into Instrument Routes (IR), and Visual Routes (VR). Each route is identified by either of these two letters, followed by either four digits for routes below 1,500 feet above ground level, or three digits for routes extending for at least one leg above 1,500 ft AGL. (Note - over Galloo aircraft could be just above the 600 foot  turbine height). The difference between the IR and VR routes is that IR routes are flown under Air Traffic Control, while VR routes are not.”

IR801 Military Route.jpg
                        Grey line (IR801) encompassing Galloo Island 
                        delineates Fort Drum Military Training Route 


“Each route is defined by a number of geographical coordinates and their respective navaid fixes. From this line the corridor is extended a specific number of miles, in the vast majority of cases this is five miles, making the corridor 10 miles wide. The Routes are individually operated through one of the local military air bases (Ft. Drum), which schedule and 'own' the route.”

Sources:
Wikepedia (https://en.wikipedia.org/wiki/Military_training_route)
  FAA website

GALLOO ISLAND PUBLIC NOTICE~OBSTRUCTION STANDARD EXCEEDED


GALLOO ISLAND PUBLIC NOTICE~OBSTRUCTION STANDARD EXCEEDED
 

July 28, 2017 the FAA released a public notice announcing that they are conducting an aeronautical study concerning the Galloo Island industrial wind project. Some of the proposed turbines in Apex Clean Energies project exceed obstruction standards, and the FAA will be determining their effect on the safe and efficient use of navigable airspace by aircraft and on the operation of air navigation facilities.



FAA Galloo by pandorasboxofrocks on Scribd

Apex clean Energy

Fish and wildlife officials want updated information for Galloo Island wind project review

By MARCUS WOLF
WATERTOWN DAILY TIMES
FRIDAY, JULY 21, 2017


Officials from the U.S. Fish and Wildlife Service argue that Apex Clean Energy must secure more updated information to assess the Galloo Island wind project’s potential wildlife impacts. Continue reading via this link to the Watertown Daily Times

Apex: Galloo Island Wind - USFWS Comments

US Fish and Wildlife Service - David A Stilwell - July 12, 2017

This letter by the US Fish and Wildlife Service, was submitted to the State of New York in reference to a pending proposal to build a wind turbine project in the very sensitive land area on and around Galloo Island. The letter can be accessed by clicking on the links included on this page. The letter was submitted by Clifford P. Schneider with an accompanying letter by Mr. Schneider explaining the federal agency's concerns with the project application.
________________________________________________________________
Ms. Ashley Moreno
Presiding Examiner
Three Empire State Plaza
Albany, New York 12223-1350 
RE: GALLOO ISLAND WIND, LLC. 15-F-0327 
Dear Secretary Burgess and Presiding Examiner Moreno: 
Please find attached a letter from David Stilwell, Field Supervisor for
 the Cortland Field Office of the United States Fish and Wildlife Service.
 Stil-well’s letter was also filed under Public Comments section
 of this case on July 14, 2017. I urge the parties to review the USFWS’s
 comments on Apex’s Final Stipulations for their Galloo project.
Although the USFWS comments were filed outside the posted 6-19-2017
dead-line for stipulation comments, the comments and recommendations
are important in that they describe serious deficiencies in Galloo’s
 study plan for avian impacts and suggest further studies to improve
understanding of potential adverse impacts associated with
Apex Clean Energy’s proposed development of Galloo Island.
What is more, the recommendations suggested by the USFWS
are more detailed and expansive points that I made in my comments
on Galloo’s stipulations, which I submitted within the 30-day comment period. 
Briefly, the USFWS concluded “…that the 2008 radar studies for Galloo
 Is-land are outdated,“ and that “additional radar surveys be conducted
 on the island to more accurately understand the potential risk of the project
to wildlife.” This supports my recommendation that Galloo should
 conduct two years of new radar studies. 
The USFWS also called for a far more expansive assessment of Cumulative
Impact Analysis on avian resources than Apex provided in their FinalStipulat-
ions. Apex offered to include three wind projects in their Cumulative Analysis:
Wolfe Island, Amherst Island and Horse Creek.Ideally, the USFWS,stated,
Apex’s cumulative analysis should include wind energy projects located
regionally, including more than a dozen operational and planned projects in
both U.S. and Canada. The analysis should consider all projects that could
affect the region’s migratory flyway. 
The USFWS comments also revealed that Apex undertookspecial Bald Eagle
studies on Galloo in 2016, but the Service has not received any communication
since a July 2016 meeting with Apex. USFWS noted, “We request that the DPS
consider incorporating measures in the final stipulations which account for the
ongoing  surveys being completed by Apex,and also the potential for additional
surveys, if warranted.”
I presume the Bald Eagle studies referenced by the USFWS are those studies associated with an application by Apex for a Programmatic Take Permit, which
amounts to a permit for Apex to Take (Kill) Bald Eagles on Galloo Island.
In an 8-2-2016 email obtained from a NYSDEC FOIL request, Apex indicated
that“…they are consulting with USFWS to develop a "take" permit for bald eagle
as a parallel process to NYS requirements. Larry Weintraub (NYSDEC General Counsel)indicated that the substance of Article 11 requirements will be folded
into the Article 10 process.”
We are due explanations by Apex and NYSDEC.
Is Apex intending to file for a Take (Kill) Permit? If so, then why was
it not mentioned in Apex’s PIP, PSS or Final Stipulations?
Why the covert studies? Why did Apex decide to keep a Bald Eagle
survey of Galloo a secret? Was the idea fostered by NYSDEC to quietly
issue a Take (Kill) Permit folded into the Article 10 process, an obfuscation
with the hope that no one would know and thereby no one would complain?
Again, the parties and public are due explanations by both Apex and NYSDEC.
Finally, if Apex chooses to ignore the reasonable and responsible
recommendations by USFWS, then the Siting Board should deem
Apex’s application incomplete. 
Sincerely yours, 
Clifford P. Schneider 
Pro Se
Wellesley Island, NY 13640



Usfws Comments Apex Galloo Island Wind Proposal
Download file (1.37 MB) pdf



Former biologist wants wind developer to conduct new avian studies

 By MARCUS WOLF

WATERTOWN DAILY TIMES
June 13,2017


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. Continue reading via this link to the Watertown Daily Times


Apex Clean Energy Cries ‘Uncle’ in Tennessee, but not in New York

The following was contributed by a reader
Apex Clean Energy, the wind developer behind Lighthouse and Galloo wind projects currently under New York’s Article 10 review, decided to pull the plug on their Crab Orchard Wind project proposal in Cumberland County, Tennessee.
Apex’s excuse was, “There are several important inflection points at which we determine whether the fundamental attributes of the project support a continuing investment in that project,” Apex noted. “We have come to such an inflection point on the Crab Orchard Wind project.”
Inflexion points seem to suggest market timing, financing, tax credits, subsidies, equipment costs and other developmental issues, but certainly not opposition and political pressure.
A reasonable person might wonder, if any of these factors affected Apex’s decision to abandon Crab Orchard, then they might be abandoning other projects, since these inflexion points would affect Apex’s projects no matter where they are located, since all projects are driven by the same fundamentals.
But alas, Apex has not suggested they are leaving any other projects, just Crab Orchard in Tennessee.
So, what’s special about Crab Orchard?
In a search for those inflexion points that might be responsible for Apex’s decision to leave Tennessee there is one that popped up and screamed – THAT’S IT!!
Please, please click on the You Tube video below and see the real reason why Apex called it quits – it’s because of the logic, eloquence and fortitude of Tennessee’s U.S. Senator, Lamar Alexander.
What Alexander argues before the Senate are the very same issues that influence Galloo, Lighthouse and any other wind project proposed for New York.
Alexander’s best line was ‘Choosing wind turbine electric generation when you have nuclear capability is like going to war in sailboats when you have a nuclear navy’.

Agreements regarding Galloo Island Wind project application open for comment


By MARCUS WOLF
WATERTOWN DAILY TIMES
MAY 23, 2017  


Proposed agreements between Apex Clean Energy and state agencies regarding what the developer will include in its Galloo Island Wind project application are available for public comment. Conrinue reading via this link to the Watertown Daily Times

Galloo Island Wind developer must provide more details for PILOT application


By MARCUS WOLF
WATERTOWN DAILY TIMES
WEDSDAY, MAY 17, 2017


WATERTOWN — The developer for the Galloo Island Wind project needs to clarify sections of its payment-in-lieu-of-taxes application before the committee charged with conducting the first step of the review process can deem it complete. Continue reading via this link to the Watertown Daily Times

JCIDA committee to discuss Apex Clean Energy’s PILOT application later this month


By MARCUS WOLF
WATERTOWN DAILY TIMES
THURSDAY, MAY 4, 2017
WATERTOWN — Donald C. Alexander decided that the payment-in-lieu-of tax agreement application from the developer of the Galloo Island Wind project was suitable and the Jefferson County Industrial Development Agency’s loan review committee will discuss it May 19. Continue reading via this link to the Watertown Daily Times

Retired biologist argues Jefferson County not suitable for wind turbines

By MARCUS WOLF
Watertown Daily Times
TUESDAY, APRIL 18, 2017

State agency guidelines and reports used to help review the Clean Energy Standard advise against wind energy development in Jefferson County, argues a retired biologist tasked with reviewing Apex Clean Energy’s Galloo Island Wind project. Continue reading via this link to the Watertown Daily Times

Lighthouse owners want more communication with town officials about wind project


By MARCUS WOLF
WATERTOWN DAILY TIMES
THURSDAY, FEBRUARY 23, 2017


The owners of the historic lighthouse on Galloo Island want to know what Hounsfield town officials will do to represent their interests in the review process for Apex Clean Energy’s Galloo Island Wind project Continue reading via this link to the Watertown Daily Times

2017 Avian Risk Assessment for Apex Clean Energy’s Galloo Island Wind Project

Submitted to the Public Service Commission January 30,2017

by Clifford P. Schneider
Lake Ontario Unit Leader - Retired
New York State Department of Environmental Conservation

 RE: Galloo Island Wind Project, Case No. 15‐F‐0327


Dear Secretary Burgess:

In accordance with Article 10 of the Public Service Law, please find
attached a 2017 Avian Risk Assessment for Apex Clean Energy’s Galloo
Island Wind Project.