By: Gary Abraham, resident of Great Valley and Environmental Attorney
First, the project is environmentally destructive. Evidentiary hearings were conducted at which scientists from DEC offered evidence, testified and were cross-examined on the evidence. Two administrative law judges concluded based on that evidence that the wind project would kill 41 bald eagles, thousands of bats, insects and other birds, require drilling under dozens of streams and wetlands, and clear-cut 1,500 acres of mature forests. New York policy is to preserve and grow our forests, as they are the only available method of removing carbon dioxide from atmosphere.
Second, the project threatens the public health. That’s what the New York State Department of Health said in its testimony. A DOH scientist testified that many people in Farmersville and Freedom will be exposed to shadow flicker for much more than 30 minutes per day, and time will suffer wind turbine noise over 40 decibels. Closing drapes does not eliminate flicker from turbine blades passing across the sun. The inside of a house strobes during shadow flicker. These thresholds—30 minutes of shadow flicker and 40 decibels of mostly low-frequency thumping noise—are the minimum needed to protect public health, according to DOH. The State approved a limit of 45 decibels, disregarding DOH. DEC has guidelines on assessing noise impacts. The guidelines say that a new noise source that increases the existing sound level 20 decibels is experienced as “very intrusive or intolerable”. The hearing record includes five studies of existing sound levels in rural communities in western NY. In each community the level was 25 decibels or lower. That’s 20 decibels less than the noise Alle-Catt is allowed to emit.
Third, Alle-Catt will not meaningfully reduce greenhouse gas concentrations in the atmosphere. It has been estimated that it takes about 10 years of operations for a wind farm to offset the carbon that went into mining raw materials and turning them into the machines and electrical lines needed to connect to the grid. Once connected to the grid, Alle-Catt is unable to meaningfully reduce carbon dioxide from other power sources. That’s because over 90% of electricity in upstate NY is already carbon-free, and there is no ability to send our electricity downstate, where electricity is only 10% carbon-free. Alle-Catt will not advance the goal of reducing greenhouse gas in the world’s atmosphere.
Fourth, Alle-Catt would already be heavily subsidized without IDA support. Federal tax credits and state renewable energy credits are so lucrative that they pay for most of the capital cost of putting up the wind farm. Once operating, nobody runs the facility.
Fifth, the IDA should weigh heavily the number of permanent jobs that would be created if it finances the project. Unlike IDA financial assistance to Holiday Valley, for example, which produces lots of permanent jobs, only a handful of part-time inspector jobs will be created by Alle-Catt. Construction jobs will be numerous, but only for about one or two years. And most of those jobs will be taken by workers from out of this region. But full-time permanent jobs? There will be none, or close to none. Financing a project that does not produce permanent jobs violates CCIDA’s guidelines.
Sixth, Alle-Catt is untrustworthy. New York has a “bad actor” policy encouraging agencies to look into the history of applicants for big projects, and encouraging permits and approvals be denied to bad actors. The idea behind the policy is that since compliance with the terms and conditions of agency approvals is largely a matter of self-policing, the trustworthiness of the applicant to comply with those terms is paramount. If reasonable conditions imposed on big projects are accepted but can be expected to be routinely violated, the agency should deny approval. In this case, Alle-Catt executed an agreement with the N.Y. Office of the Attorney General to instruct town board officials about the conflict of interest rules, and to avoid leasing land from local officials. Alle-Catt then violated the agreement and was fined by the AG. Alle-Catt was obligated to reach out to the local community with accurate information on its project proposal. Instead, Alle-Catt has held closed meetings with those who lease land to it, but has excluded and kept everyone else in the dark. Alle-Catt told the state Siting Board it could connect its project to National Grid’s electric system by 2025, but a few weeks after obtaining its 2020 permit, it asked for a five-year extension to 2030 because National Grid refused to connect the project without transmission upgrades. The IDA should not sponsor this company’s project because Alle-Catt is not a trustworthy contract partner.
There are practically no benefits and tons of harms associated with the Alle-Catt project. There is no rational basis for IDA to provide financial assistance to Alle-Catt.
