January 2, 2010
To: Mr. Alexander “Pete” Grannis
Commissioner
NYS Department of Environmental Conservation
625 Broadway
Albany, NY 12223-1750
From: Robert Ashodian
Re: DEC - Please Preserve and Protect Our Environment
I am a member of the Coalition for the Preservation of the Golden Crescent and Chairperson of the Henderson Harbor Area Chamber of Commerce’s Economic Development Committee. My exposure to the world of NYS politics and the various agencies of our government has been, until very recently, minor.
It has always been my opinion that the DEC makes every effort to protect our unique environment. At times it seems overly zealous in enforcing the seemingly endless list of regulations that prevent people from doing what they want to do and in punishing transgressors of environmental regulations. Get caught washing paint brushes in the lake, spilling a few ounces of oil in the water, or moving any rocks below the lake’s high water mark and you are in considerable trouble. Disturb identified wetlands, endanger any manner of wildlife, and your project is stopped dead in its tracks. Our local newspaper just the other day reported a $200 fine for a property owner in Watertown who disturbed a creek embankment on his property; he also had to reach an agreement related to silt fences. While as an individual I may protest such zealous enforcement, I have to concede this is to our collective good.
I have read the Final Environmental Impact Statement for the Hounsfield Wind Farm Project, and the rules seem to be totally different. I have a home along the Lake Ontario shore and have sailed past beautiful Galloo Island many times and have anchored off its shores. Local fishermen have visited the island for decades. The island is a breeding ground, habitat, migratory route and home for many species of living things in the air, on the ground and in the water.
Like so much of the land along the shoreline, the foundation is rock with a thin layer of soil. The islands that make up the gateway into the St. Lawrence River are similarly rock with a thin layer of soil. The foliage clings to life yet manages to survive and be the habitat for many creatures. Even the most casual reading of the FEIS makes it obvious that the ecology of Galloo Island will be destroyed by blasting, rock crushing, cement making, clear-cutting of woodland areas, roads, and foundations for 84 wind towers. Virtually the entire island will be covered by towers, roads, equipment, living quarters, electrical components, a mulch pit, and initially a cement making facility.
In a previous letter (January 2, 2010) I raised the issue of acoustics – not just the impact of sound radiating in the air, but the vibration and the sounds likely to be transmitted by what I called the “tuning fork effect” – 84 wind turbines anchored into solid rock by poured concrete. Who has any idea of the effect that collective harmonics from such combined structures will have on the creatures that live not only on the island, but spawn and feed in the surrounding waters? As far as I am aware this critical issue has not been even looked at. It is possible that an entire fishery could be destroyed. Shouldn’t someone care?
It appears from the diagrams and simulation photos available with the FEIS that many of the wind turbines have minimal set back from the lake and from the wetlands that make up the interior of Galloo Island. Each wind turbine requires hundreds of gallons of synthetic oil for lubrication. If a tower collapses anywhere on the island it would likely cause an oil spill that would make its way into the lake. Obviously any tower that collapsed directly into a wetland area or into the lake would create an even worse situation. How would such a spill be contained?
A tower collapsed at Altona, and another recently at Fenner. Construction at Maple Ridge was plagued with incipient tower collapse due to faulty concrete in some foundations. So the possibility is not remote.
Now, I have to ask – if I operated a marina, would the DEC allow me to store oil suspended or supported by any structure over the water or on land adjacent to the water? Any fuel or lubricating products stored on land must be fully surrounded by a reservoir facility that would contain the entire amount of fluid that might possibly spill. If I spill fuel oil on my land, it must be reported immediately to the DEC and the entire contaminated area dug out and disposed of. How will this be done when a tower collapses with hundreds of gallons of synthetic lubricant that will spill across the thin soil, likely into the lake and into the rock base below on Galloo Island?
I cannot imagine the DEC ever approving any project on my private land that would do 5% of the environmental devastation that will certainly happen on Galloo Island.
I have to ask, is the DEC’s role in this project simply to identify the harm that will be done, and then allow the developer to propose his limited version of mitigating action? Does the DEC stand by and simply say – this is what you will destroy, so our collective conscience is now clear?
Is the DEC’s role to preserve and protect or is it simply another politically driven arm of the state government? Was it, is it, simply being asked to look the other way, while our unique natural resources are destroyed because there is money to be made by others?
The DEC felt strongly enough about Galloo Island to attempt to buy it a few years ago. The DEC still has a few acres that are under its control. Galloo Island was set aside as a resource worth preserving and protecting. Are we to believe that the DEC has simply caved in to political pressure?
Going back to my earlier points – as an individual my understanding is that if I spill any fuel, fail to have a proper silt fence, or move any rocks below the lake’s high water mark, I will be punished. I will also be prevented, and rightfully so, from destroying wetlands, putting wetlands at risk, or putting all manner of living things at risk. But, would I be permitted to destroy forever an entire island and decimate the habitat, feeding and breeding grounds, and migration path of many species of otherwise protected animal life? Absolutely not -- this would be absurd. Typically what most small property owners wish to do is insignificant in the total scheme of things. But, the rules are the rules and they are rigorously enforced. Now we have this huge project on Galloo Island, which will impact the entire northeastern end of the lake. Yet, the DEC appears to be looking the other away either by its own volition (which seems unlikely to me), but perhaps more likely because it is under considerable political pressure to look the other way. As an individual property owner I cannot possibly imagine being granted the right to destroy so much, nor would I personally, in good conscience, even conceive of doing so regardless of the potential profit.
We look to the DEC to protect us from the short-term financial greed of others; greed that now threatens an entire ecosystem. ANWR is a relatively tiny spot in a vast Alaskan wilderness; a barren, frozen, unvisited, unseen place. It is protected. The northeastern end of Lake Ontario is an international destination for hundreds of thousands of visitors, a year round habitat for birds, fish, and many others forms of life. If the DEC cannot prevent the impending disaster due to environmental disregard and devastation of our natural resources for profit, who will?
I urge you to pursue our concerns.
Sincerely,
Robert Ashodian
14537 Harbor Road
PO Box 544
Henderson Harbor NY
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