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
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.
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.
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.
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.
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.”
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.”
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.
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
Wellesley Island, NY 13640
Source: http://documents.dps.ny.gov...
