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