As a 501c3 educational organization, CCAC has an obligation to broaden public understanding of the potential environmental and human health risks associated with industrial-scale wind development in our county, while also recognizing its potential benefits. Rather than taking a position for or against the AlleCatt project as a whole, we advocate for the preservation of Allegany County’s clean air, water, and soils so that all living things can remain healthy and thrive long into the future. The following document was submitted on to Kathleen H Burgess, Secretary of the New York State Board on Electric Generation Siting and the Environment on behalf of CCAC in regard to the Alle-Catt Wind Project:
6-11-2019
Secretary Burgess and Board:
As a 501c3 educational organization, CCAC has an obligation to broaden public understanding of the potential environmental and health risks associated with industrial-scale wind development in our County, while also recognizing its potential benefits. Rather than taking a position for or against the Alle-Catt project, we advocate for the preservation of Allegany County’s clean air, water, and soil so that all living things can remain healthy and thrive long into the future.
CCAC has spent over a year researching potential impacts of the Alle-Catt proposal and getting up to speed on the issues associated with large scale industrial development of wind energy. CCAC researchers have reviewed the final application, as far as possible, in the short timeframe allotted. Now that the final application has been accepted as complete, there are myriad serious issues identified by intervenors. The following issues are examples identified by CCAC where sufficient information and process of analysis is lacking in the application:
- In regard to the Environmental Justice Area located in the Town of Centerville. An EJA triggers enhanced impact assessment for a community and its cumulative vulnerabilities. It cannot be dismissed by drawing a small diameter footprint around each windmill site and concluding in the application that there are no EJA issues within that isolated bubble. This does not satisfy the spirit of and protections established within Environmental Justice legislation and regulation.
- Large scale generating facilities such as the Alle-Catt proposal have been shown to create discharges of current to ground (stray voltage) , dirty electricity, electromagnetic fields and dumping of current during times of grid overload. The effects of these conditions can accumulate into significant currents and affect living organisms as well as interfere with anode protections on existing gas lines. One such concern is a proposed pipeline such as the Northern Access. It will transport 442 million cubic feet of natural gas per day under very high pressure in a 24 inch pipe. it is proposed to be constructed just a short distance west of the proposed wind farm. Electrical discharges during normal operation of the mills and switch stations as well as during grid overload need quantification and analysis. The Alle-Catt application does not adequately address potential impacts nor proposed mitigation measures for impacts from this discharge.
- There are alternative wind turbine designs under development and testing that will soon render these large bladed windmills obsolete. New designs are significantly more efficient, operate in lower winds , utilize less footprint and eliminate most of the negative impacts characteristic of behemoth windmills. The sacrifice zones being approved hastily, now, may be looked back on as unnecessary in the not too distant future. The review and approval of such a major industrial development should include discussion and consideration of state of the art alternatives. Review of alternatives is required by regulation and should not be side stepped by the applicant nor ignored by the Review Board.
- Analysis of impact to property value should be prepared specifically for this locale, not using the trends of property impacts in vastly different settings especially when related to the Environmental Justice Zone in Centerville. Reduced property values could drive the Zone deeper into poverty.
- Is the proposed generating capacity of Alle-Catt compatible with transport of electricity to areas of need via existing grid lines? Will the load on the grid necessitate the dumping of our most efficient and sustainable electricity from Niagara Falls. Analysis of how the numerous windmill farms already in place and others proposed will interface with the grid and impact current sources, should be included in the review of the Alle-Cat windfarm. Will this trigger a need for new high tension transmission corridors?
These questions and comments are made in the hope of having the applicant provide more solid information on which the public and the Review Board may formulate truly informed decisions.
Respectfully,
Karen Ash, Chair, Concerned Citizens of Allegany County
POBox 113 Angelica, NY 14709 585 409 5918
CONCERNED CITIZENS OF ALLEGANY COUNTY 