Help with Public Comments

General Information

 

State your name and your full address at the beginning of your letter.

Say you are submitting your comments to the Black Oak Wind Farm (“BOWF”) draft Supplemental Environmental Impact Statement (“SEIS”) to the Town Board as lead agency under the State Environmental Quality Review Act (“SEQR”).

The Town Clerk, Alice Linton, prefers that you email your comments to her at townclerk@townofenfield.org.

Alternatively, you can mail them or drop them off to:

Town of Enfield Town Clerk

168 Enfield Main Road

Ithaca, NY 14850

 

If you mail or drop off comments, Alice would appreciate a copy on a thumb drive if possible as well since otherwise she must scan them.  But, it is fine if you can’t do this or don’t want to do this.  You can type your comments or write them out by hand.  Whatever works for you.

 

Do your best to link your comments to the changes being made in the SEIS.  Those changes include:

 

  • Turbines A, B and/or C
  • Turbine 5 that is moving 160 feet to accommodate the town setback requirements
  • Turbine 6 that is moving a short distance to accommodate the town setback requirements
  • The relocation of the substation
  • The addition of a permanent met tower just south of Turbine 4
  • Relocation of approximately 2,200 feet of collection line
  • Relocation of approximately another 6,200 feet of collection line

 

Just remember that comments are due by this coming Friday, April 22nd.  The town has not made clear whether just postmarking them by April 22nd is sufficient so please try to mail them in time to arrive by Friday in the mail.  Alternatively, you can email them to townclerk@townofenfield.org.

 

Areas to Comment Upon with Suggested Comments

 

Noise

  • Ambient sound/ audible noise
    • Using average sound readings is not a good measure – BOWF can simply average very quiet areas with loud areas to lower overall average
    • 8 dBa reading for ambient sound seems quite high; Rick James and others say ambient sound for quiet, rural areas such as ours should be closer to 25-30 dBa; why is BOWF’s reading so high?
    • Why hasn’t BOWF provided the underlying sound data that one of our residents has asked for? DSEIS is incomplete without the underlying sound data on measuring and monitoring that the residents requested
    • Why hasn’t BOWF shared with the town the sound specifications for the GE wind turbines?
    • What kind of ongoing monitoring is the town providing to make sure we can go to sleep at night in our bedrooms without being disturbed by the turbines?
    • What recourse will the residents have if the sounds are disrupting our lives and causing us to lose sleep and become ill?
  • Infrasound
    • Why hasn’t BOWF measured for infrasound?
    • What if they are wrong about infrasound and it disrupts our lives, causes us to lose sleep and become ill?
    • What recourse will we have?
    • Infrasound only affects some people; but affects children and older adults disproportionately
    • Since original sound tests (which were never updated for the larger turbines) the blades have increased by 7 meters (or 23 feet)
      • Larger blades increase infrasound
        • Need to slow down speed as blade increases in size which increases dBc levels instead; increases infrasound
      • But by designing blades to decrease audible sound by 1-2 dBa wind farms claim blades are quieter
      • Low frequency noises bounce off the atmosphere and can be unpredictable
      • Infrasound comes through roofs; weakest link of the house
      • Infrasound worse inside than outside the house
      • Natural infrasound doesn’t have tones or pulses, unlike wind turbines
      • Towers act as a tuning fork
      • Turbines on ridges are subject to more whooshing/bumping due to more turbulent air
    • Most intrusive time for turbines is when it is quiet on the ground but turbines are still spinning in wind above
    • Lower sounds of turbines are not masked by the higher frequencies of bugs, frogs, etc.
    • Studies don’t establish that there are no adverse health results; they just say there isn’t enough data to establish that the turbines cause adverse health effects; that is just because most of the studies only look at a very few locations; many studies say this issue need further studies
      • People all around the world are experiencing the same symptoms
      • People all around the world are boarding up their homes and moving away because they can no longer bear to live near the turbines due to health effects and they are unable to sell their homes; what is going to happen to us if that occurs in Enfield?
    • Town law is clearly inadequate as to sound levels; At an absolute minimum, the town needs to amend the wind law right now to retroactively limit the maximum audible sound that BOWF’s project can have at any one moment during its operations (not average) to 46 dBa (which they claim they will not exceed) so that residents have recourse under a nuisance suit if the noise exceeds what BOWF claims
    • Point out the amplifying effect of having so many turbines so close to one another
    • List of health impacts – go to http://www.windturbinesyndrome.com/wind-turbine-syndrome/what-is-wind-turbine-syndrome/
    • Europe’s setbacks are significantly greater; moratoria being put in place in several jurisdictions
    • Noise when turbine rotates looking for wind
    • You need to double the distances for safe setbacks where homes are on the leeward side of the ridge and the air is turbulent
    • Articles/ links of interest:

 

Ice throw/blade throw

  • Setbacks from roads and property lines are simply inadequate and unsafe
    • Reliance on GE’s setback of 1.1 times the blade radius for property line setbacks completely ignores the footnote to GE’s guidelines that state this setback only should be used in remote settings where land is unlikely to be used by the owners; at a minimum, BOWF should be using the icing setback of 1.5 times the height of the turbine
    • Vestas safety regulations require 400 meters (~1,300 feet)
    • Jonathan Rogers from GA Tech spoke at the Wind Advisory Committee meeting about his paper regarding ice throw and blade throw; he estimated that we need a setback of approximately 1,500 – 1,600 feet during that meeting to be safe; using the formulas in his paper as applied to the GE 2.3MW turbines BOWF is using results in almost a 2,000 setback recommendation
    • Include a copy of pages 13 – 15 of the Report on Wind Turbines prepared by the Town of Enfield Wind Farm Advisory Committee as support if you like. You can find it here:

http://townofenfield.org/wp-content/uploads/2016/04/Enfield-Wind-Farm-Advisory-Committee-Reports-2016-04-12.pdf

  • Turbines B and C are too close to Harvey Hill Road and Black Oak Road based on Mr. Rogers’ estimates; I drive those roads regularly
    • For people living close to these turbines, point out that they pose a threat to your home, yourselves, your pets and livestock, etc.
  • Allowing BOWF to set these turbines so close to my property line is basically granting them an involuntary, uncompensated safety zone easement
  • What are the measurements of each turbine from property lines and residences by each location? The residents have asked for this information through the Wind Farm Advisory Committee but have gotten no response.  Why won’t BOWF provide this information?
  • BOWF’s President, Peter Bardaglio, says turbines will automatically stop when icing occurs but the GE literature calls this mechanism “highly unreliable”
  • Blades rotate full 360 degrees so ice throw, blade throw can happen anywhere within the radius of the circle
  • Relevant articles/links of interest:
  • Point out that as turbines have increased in size, fatigue failure is a bigger issue causing gearboxes to catch fire and blade throw. Proper siting is the answer to this.  These turbines need to be further away from roads, residences and property lines.

 

Flicker

  • What is the standard BOWF is applying to determine that less than 30 hours per year of flicker is acceptable? Europe uses 30 hours per year but also generally restricts it to no more than 30 minutes per day
  • Why does the flicker study only concentrate on the effect on the residence? What about when I am in my yard?
  • Research shows that siting turbines at least 10 rotor diameters or more from a residence makes the potential for shadow flicker very low. That would be 3,500 feet for these GE 2.3MW-107 turbines but they are only ____ feet from my home.
  • Many well-known complaints of shadow flicker include headaches, tinnitus, nausea, dizziness, earaches, vertigo and seizures.
  • The Bureau of Land Management notes that flicker can cause annoyance. The World Health Organization links annoyance to various diseases, such as diabetes and cardiovascular disease.
  • There has been very little research to date around the effects of shadow flicker.
  • What if I begin to suffer from the ill effects of flicker? What remedy is available to me?  BOWF provides no mitigation whatsoever for flicker effects.
  • Can’t BOWF shut down the turbines causing shadow flicker for about an hour around the time the sun is rising and the time the sun is setting to minimize the flicker?
  • What about installing a program to control the direction of the blades so they are directly parallel to the sun to minimize flicker?

 

Mitigation proposals

  • Throughout the document, BOWF proposes a minimum number of mitigation actions.
  • One common mitigation solution they propose is to have a resident enter into the Good Neighbor Agreement. Proposing a mitigation solution that requires a resident to waive his or her legal rights to enforce health and safety concerns is unacceptable!
  • Another popular mitigation tool proposed by BOWF is the Community Outreach and Communication Plan contained in Appendix U of the original Draft Environmental Impact Statement. Not only is this plan ridiculously inadequate, it only applies during the construction period.
  • We need a robust post-construction plan to address residents’ concerns throughout the operation of this wind farm that has enforcement teeth.

 

Property value issues

  • People all around the world are boarding up their homes and moving away because they can no longer bear to live near the turbines due to health effects and they are unable to sell their homes; what is going to happen to us if that occurs in Enfield?
  • The one study BOWF references to support its argument that property values will not decline is not relevant to the people who will live close to these turbines; it looks at an urban area, not a rural area, and it covers too great a distance (up to 5 miles away which is too great a distance to be relevant to us); furthermore, the study does not distinguish between the perceptions of people who are directly benefiting financially from the wind turbines and those who are not
  • Most of the studies the wind industry points to are not limited to the immediate area surrounding a wind farm; they cover areas of 5 miles or more surrounding the wind farm which is too great a distance to be relevant

Fire

  • Fires generally occur because of lightning or mechanical failure. Point out that the newer, bigger turbines have more issues with bearing and fatigue failure that can lead to fires
  • What is the emergency plan in case of a fire?
    • Our fire chief says he has never spoken to BOWF despite the fact that Peter Bardaglio claims BOWF did speak with our town fire department
    • The one page plan in the DEIS is entirely inadequate
    • If you live near a turbine and that turbine is located near a woods, point out that the fire chief of Enfield has expressed concern about the ability to control forest fires if a turbine were to cause one
  • The DEIS says that part of the emergency plan is that turbines have fire suppression system but GE salesman told Wind Advisory Committee that they do not; it is unclear whether BOWF is installing a stand-alone fire suppression system
  • What, if any, toxic smoke issues exist?

 

Foundation

  • Foundation failures, leading to turbine collapse, are generally caused by design flaws, construction flaws and/or maintenance flaws
  • What are the plans for making sure that the turbines are properly designed and properly constructed? Are we simply relying on BOWF or is the town going to inspect these issues independently?  Will there be both a design/construction engineer and a soil engineer on site during construction? Who will pay for that?
  • I don’t see a clear maintenance plan laid out in the SEIS to make sure foundation issues don’t arise during the life of the project, especially as the turbines get older
  • Why haven’t they done any new core samples for the new turbine sites and the substation? BOWF’s engineers clearly state that they need review and verify any changes before the town can rely on their conclusions.

 

Stray voltage

  • The Final Findings Statement indicates that concerns around stray voltage are a legitimate concern.
  • While generally these concerns are preventable by proper grounding and electrical installation, fast deterioration of cables and cable accessories have been reported at wind farms.
  • What is BOWF’s maintenance plan to prevent the deterioration of these systems and the resulting stray voltage?

Other ideas/ comments

  • For additional information or ideas, refer to:
    • The Report on Wind Turbines prepared by the Town of Enfield Wind Farm Advisory Committee as support if you like. You can find it here:

http://townofenfield.org/wp-content/uploads/2016/04/Enfield-Wind-Farm-Advisory-Committee-Reports-2016-04-12.pdf

  • Information on the Trello site which can be found in the links sections at the bottom of the Town of Enfield Wind Farm Advisory Committee website which can be found here:

http://townofenfield.org/wind-farm-advisory-committee/