River RATS Comments

Fort Drum JLUS Public Draft Review
Comment Form
November 2017
ORGANIZATION REPRESENTED:
RIVER RESIDENTS AGAINST TURBINES RIVER RATS
PO BOX 552 CLAYTON, NY 13624
COMMENTERS NAME: ROSS HOLBROOK WWW.RIVERRESIDENTSAGAINSTTURBINES.COM/
JLUS / Background
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n the document.
JLUS Report of
Background Report
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number
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1 Comments: Draft
Background
The top photo insert of Boldt Castle, the 2017 I Love NY #1 Warm Weather Tourist Attraction in New Report: Cover
York, is located in the Town of Alexandria, NY. Although the Town of Alexandria is located inside the 30 Page
mile study radius, it is not listed among the project stakeholders nor the local jurisdictions interviewed
(Draft Background Report: 1-8) This should be of great concern and is a notable absence given the
inclusion of Boldt Castle and, by default, the Thousand Islands, which is a source of great regional
importance due in part to tourism and world-famous Thousand Islands Region.
Link:
https://www.iloveny.com/blog/post/i-love-new-york-march-madness-and-the-winner-is/
Please provide your comments to Hartley Bonisteel Schweitzer with the Development Authority of the North Country at hschweitzer@danc.org by November 25, 2017 Page 1 of 61
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Recommendations:
1. Use of this photo should trigger a full expansion of the stakeholder partner listing to include all
municipalities within the 30-mile Study Area.
2 Comments: Draft
Background
The background photo is an image of Boldt Castle in the Town of Alexandria. As noted in Comment 1, Report:
the Town of Alexandria was unfortunately not among local jurisdictions that were interviewed. Second Cover
Nevertheless, the photo is included as a centerpiece. Page
Recommendations:
1. At the very least, a caption should be included on the page identifying the photo. For example: Boldt
Castle in the Town of Alexandria, in the Thousand Islands Region of the JLUS Study Area.
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3 Comments: Draft
Background
After listing the participants of the Steering Committee, Technical Working Group, Development Report: Page
Authority of the North Country and Matrix Design Group, under the Special Appreciation heading, the 7/256 of the
absence of a summary or description of the public participants that attended the four Public Workshop PDF
sessions makes this section incomplete and incongruous with the aforementioned participant listings.
Furthermore, failure to include a breakdown of public participants damages the credibility of the JLUS
by failing to sufficiently acknowledge those members of the public who invested time in the process.
Recommendations:
1. At a minimum, a listing of total number of public participants should be included, with further
breakdown into number of participants by county. This information was collected during the sign-in
process at the Public Workshops, and any missing information can be obtained by calling the phone
numbers or emailing participants, as this information was also collected during the sign-in process.
4 Comments: Draft
Background
Fort Drum is incorrectly listed as being located roughly 40 miles from the Canadian Border Report: 1-1,
second
This is clearly demonstrated by the 30-mile Study Area Circle in Figure 1-2 on page 1-5 of the Draft Background paragraph
Report. In actuality, Fort Drum is located roughly 25 miles from the Canadian Border.
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Recommendations:
1. Change the first sentence of the second paragraph to read Fort Drum is situated in northcentral New
York, seven miles northeast of downtown Watertown and roughly 25 miles from the Canadian border
(see Figure 11).
5 Comments: Draft
Background
The Background Draft Report contains a 30-mile Study Area (Figure 1-2) and a list of stakeholders that Report: 1-8,
were interviewed to participate. The list of interviewed stakeholders represents only 8 of the total 47 second
Towns that fall within the 30-mile Study Area. paragraph
directly under
Stakeholders
The local jurisdictional stakeholders list excludes 83% of Towns within the Study Area and raises subheading
important questions about how representative this minority is of the Study Area.
Furthermore, given that compatibility of industrial wind development and Fort Drum is a central issue
of the JLUS, it is of even greater concern that only one of the 13 Towns (Town of Rutland) wherein the
seven industrial wind development projects identified as potentially problematic for Fort Drum was
interviewed and included as a listed stakeholder.
The listed objective of Stakeholder and Public Outreach was the:
Informing or involving them early in the project is instrumental in the identification of their most important
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compatibility issues to address and resolve through the development of integrated strategies and measures.
(Page 1-8)
There exists reasonable potential to misrepresent the Study Area and/or fail to develop and integrate
strategies and measures for compatibility measures related industrial wind development near Fort Drum
and the KTYX Radar Station located in the Town of Montague.
Towns in the 30-mile Study Area that were, per the Draft Background Report listing, not interviewed as
stakeholders:
Adams, Alexandria, Boylston, Brownville, Cape Vincent, Champion, Clayton, Croghan, Denmark, Edwards,
Ellisburg, Fine, Hammond, Harrisburg, Henderson, Hermon, Hounsfield, Lorraine, Lowville, Lyme, Macomb,
Martinsburg, Montague, Morristown, New Bremen, Orleans, Osceola, Pinckney, Pitcairn, Redfield, Rodman,
Rossie, Sandy Creek, Theresa, Watertown, Watson, West Turin, Wilna and Worth.
Towns with ongoing industrial wind projects, per the Draft Background Report, not interviewed as
stakeholders:
Brownville, Clayton, Denmark, Harrisburg, Hounsfield, Lowville, Lyme, Martinsburg, Montague, Orleans,
Pinckney, Redfield and Worth.
Recommendations:
1. Consult directly with affected stakeholder local jurisdictions and incorporate especially those whose
jurisdictions have ongoing industrial wind development projects identified by the JLUS Study.
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2. Provide a written explanation in the document detailing the methodology and reasoning employed to
identify and interview the 8 Towns and not the other 39 Towns in the 30-mile Study Area.
3. Provide a written explanation in the document detailing why it was deemed unnecessary to actively
interview and consult with Towns involved in what is arguably the JLUSs most high-profile issue,
industrial wind turbine development around Fort Drum.
6 Comments: Draft
Background
Under the subheading TWG Meeting #4 / SC Meeting # 3 (October 12, 2017), there is no mention of Report: 1-11
incorporating comments from the October 10 and 11 Public Workshops held in Lowville and
Watertown.
This is concerning given that JLUS organizers have informed members of the public that every publically
submitted comment, whether in-person or online via the online commenting form, will be including in
full in the appendix to the JLUS.
Recommendations:
1. Clarify whether or not data (Compatibility Factor Exercise results and public comments) from the
October 10 and 11 Public Workshops were discussed and incorporated into the JLUS.
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2. Describe in detail how Public Workshop data was incorporated.
7 Comments: Draft
Background
Under the subheading SC Meeting #4 (December 18, 2017), it appears that the language is either part Report:1-11
of the JLUS Template and/or languages that indicates expected outcomes of a future event. Specifically:
During this meeting, all public comments that were received during the public comment period (November 6
25, 2017) were reviewed and final changes for the JLUS documents were agreed upon. The final JLUS and
Background Report were approved during this meeting. Lastly, the meeting included a discussion of the next
steps after the JLUS process and options for implementing the JLUS strategies.
Is it not presumptuous to assume that all public comment and changes will be reviewed, agreed upon
and amended in one day?
What is the procedure if certain recommendations and changes submitted during the Nov. 6-25 public
comment period cannot be agreed upon in one day?
8 Comments: Draft
Background
Under the subheading Public Workshops the Draft Background Document states that: Report: 1-11,
Public
Each workshop included a traditional presentation and a facilitated exercise providing a hands on, Workshops
interactive opportunity for the public to participate in the development of the study. Subheading
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At the October 11 Public Workshop at Watertown High School, there was no traditional presentation (i.e.
PowerPoint/Slide Show/Presenter). There was a series of poster stations on a wall for the Public to view.
In fact, there was a Compatibility Issues Exercise where stakeholders ranked compatibility factors in
terms of importance, with options ranging from Very Important to Take Action to Not Important to
Take Action.
If helpful, results from the October 11 meeting in Watertown recorded digitally public can be made
available to the JLUS.
Unfortunately, the results of this Compatibility Issues Exercise as well as results from the three
additional public input data-gathering exercises from the previous Public Workshops do not appear
anywhere in either the Draft Background Report nor the Draft Report.
Failure to include these data will undercut the credibility of the JLUS by damaging the perception of
public stakeholder involvement.
Members of the public made significant time investments to become active participants of the JLUS.
Not including data points they created is unacceptable and hurts credibility.
Recommendations:
1. Amend Draft Background Report to remove/or define traditional presentation.
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2. Include the Data Points gathered from public input. Without the inclusion of public data collected
during the clicker-ranking Interactive Audience Response System (March 28-29) and the sticker-ranking
Compatibility Issues Exercise (October 10-11), it is impossible to fully integrate public sentiment and
achieve credibility, given the high-profile nature of compatibility factors related to industrial wind
development.
9 Comments: Background
Draft Report:
Fort Drum related flights account for roughly 30% of operations at Watertown International Airport 2-24,
(WIA). As such, encroachment threats to WIA must also be considered threats to Fort Drum and be Watertown
included in the JLUS. International
Airport
Subheading
Most notably, the Horse Creek Wind Project proposed by Avangrid is less than 5 miles to WIA. This
project calls for up to 72 industrial wind turbines. If the Horse Creek Wind Project in any way negatively
affects approaches or operations at WIA, there exists the potential to compromise the needs of Fort
Drum that WIA currently services, as well as hurt a major community asset.
Recommendations:
1. Include language stating the importance of Watertown International Airport to Fort Drum, specifically
the amount of airport operations that are directly tied to Fort Drum.
2. Include language acknowledging the less than 5 miles proximity of the Horse Creek Wind Project area to
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WIA, and the need for special consideration to not compromise WIA in any way via wind turbine
encroachment.
The passage could read (new language in bold):
The Watertown International Airport (WIA) is a public airport located in and operated by Jefferson County,
New York. It is approximately 15 miles west of WheelerSack Army Airfield, and 14 miles south of Ritchie
Airfield. This airport has two paved runways. One is approximately 6,000 feet in length and the other is
approximately 5,000 feet in length. American Airlines is the primary airline that services this airport, and has
two daily trips to and from Philadelphia, Pennsylvania. Watertown International Airport is an important
resource for Fort Drum, with roughly 30% of flight operations directly related to Fort Drum. As such, the
currently proposed Horse Creek Wind Project, which would be located less than 5 miles from Watertown
International Airport, presents the possibility of compromising radar and flight operations, in effect
potentially compromising services requested by Fort Drum.
10 Comments: Draft
Background
The Methodology and Evaluation section is underdeveloped and does not adequately explain how Report: 5-2,
existing and future compatibility factors were prioritized by the Steering Committee, Technical Working Methodology
Group and Public Stakeholders. and
Evaluation
Subheading
How exactly were existing and future compatibility factors prioritized?
Why does the Methodology and Evaluation section not include data gathered during the four Public
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Workshops, specifically the results of the Compatibility Issues Exercises gathered during Public
Workshop #1 and Public Workshop #2?
Failure to thoroughly explain and address the methodology process, specifically compatibility factor
prioritization by the three aforementioned parties, would render final JLUS documents inadequate and
demonstrate a lack of transparency.
11 Comments: Draft
Background
It is extremely concerning and unusual that Frequency Spectrum Impedance / Interference is not Report: 5-3,
considered as an important Compatibility Factor for the Fort Drum JLUS, given the well-documented second bullet
relationship between industrial wind turbine development and spectrum interference. This includes point
interference for numerous important spectrum systems, including:
-S band Nexrad Doppler Radar at Montague
-Army Radar Approach Control (ARAC) at Fort Drum (1 of 6 in Continental United

States)
-Digital television reception for rural residents. This was an issue at the Maple
Ridge Project, more than 15 miles away from Watertown.
-Emergency radio transmissions. This is currently a major topic of discussion in

Jefferson County.
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As clearly stated on page 3-33 of the Draft Background report:
The equipment in each radar is very sophisticated and can experience operational interference by a variety of
objects including terrain, tall structures and towers, and wind turbines, all based on elevations and topography
differences between the location of the radar and the potential interference.
As such, Frequency Spectrum Impedance / Interference must be included and thoroughly

reviewed/discussed as a Compatibility Factor in order to provide a completed Joint Land Use Study.
Failure to adequately address this important Compatibility Factor within the context of 7 proposed
industrial wind facilities renders the Fort Drum JLUS incomplete.
12 Comments: Draft
Background
It is excellent to see that management of Native American cultural sites is listed as a primary Awareness Report: 5-8,
Issue. These cultural resources include important sites such as celestial alignments, Sacred and Awareness-4
Ceremonial Landscapes and at least one Ceremonial Stone Landscape (CSL).
Are there specific Compatibility Factors (such as industrial wind development and lighted 500-700 ft.
foot tall towers) that should be mentioned in this section as potentially linked to this Awareness
Factors?
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Were the three Native American governments (St. Regis Mohawk Tribe, Onondaga Nation and Oneida
Indian Nation) with ancestral ties to Fort Drum directly interviewed to participate in the JLUS? Is so,
what was the extent of their participation?
13 Comments: Draft
Background
Given the importance of emergency radio towers, is it possible that industrial wind development could Report: 5-18,
compromise transmission and cause interference. Given the strategic nature of Fort Drum as a military Awareness-11
installation, it is essential to prevent transmission interference of digital signals.
14 Comments: Draft
Background
The federally-endangered Indian Bat has been found on Fort Drum since 2006 (Draft Background Report: 5-22,
Report: 5-22). Issue BIO-1,
Compatibility
Fort Drum is to be commended for their work involving Indiana bat protection. In 2015, Chris Dobony, Assessment
who has studied bats of Fort Drum since 2003 was named a 2015 Recovery Champion for having paragraph
provided substantial research and monitoring of the Indiana bat and having led the efforts to identify
and understand long- and short-term impacts of white-nose syndrome in bat communities. This is a
credit to Fort Drum Natural Resources Branch Chief Jason Wagner, who is a member of the JLUS
Steering Committee.
Link: http://www.drum.army.mil/mountaineer/Article.aspx?ID=10035
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Fort Drum environmentalists, including the team of Public Works Environmental Division Chief Jim
Miller (also on the JLUS Steering Committee) should also be commended for winning the top Army
award for environmental conservation in 2011.
Link:
https://www.army.mil/article/51026/fort_drum_conservationists_win_top_army_environmental_awar
d
Furthermore, according to the 2014 New York State Energy Research and Development Authority Wind
Power and Biodiversity in New York: A Tool for Siting Assessment and Scenario Planning at the
Landscape Scale Report, produced by NYSERDA, the Nature Conservancy and others, including Fort
Drum JLUS Technical Working Group members the Tug Hill Commission and Avangrid
Renewables/Iberdrola Renewables, the Indian Bat is concentrated on and to the north of Fort Drum in
the Thousand Islands/Jefferson County Region.
In fact, as the 2014 Report indicates on page B-33, the Thousand Islands/Jefferson County Region is a
primary Indiana Bat locations and travel zones in the state.
Link:
https://www.nyserda.ny.gov/-/.../Wind-Power-and-Biodiversity-in-New-York.pdf
The Horse Creek Wind Project, about 8 miles north of Fort Drum, would be located within this
important Indiana Bat corridor. As Horse Creek would therefore reduce bat habitat and kill Indiana Bats
due to turbine collision and/or barotrauma (explosion of bat lungs due to turbine vibrations), it is
possible that existing Indiana Bat habitat on Fort Drum would be required for conservation, thus
limiting future the operational and development capacity of these areas on Fort Drum.
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This is best explained on page 5-22 of the Draft Background Report:
The existence of federally threatened or endangered species on any military installation could impact the
ability of the military to fully perform its mission activities depending on the location and range of the species.
The Endangered Species Act (ESA) requires federal agencies to ensure any actions will not jeopardize the
existence of any listed species, or impact any designated critical habitats of listed species. There are two
federally listed species located at Fort Drum and also within the region that are protected by the ESAthe
Indiana Bat and Northern LongEared Bat.
Recommendations:
1. Recommend that the Horse Creek Wind Project be denied planning permission in order to prevent
potential future Fort Drum base usage limitations in areas currently occupied by the federally-
endangered Indiana Bat.
2. Insert the following language after the fourth paragraph of Page 5-23:
Being located in scarce Indiana Bat habitat recognized by JLUS Technical Working Members the Tug Hill
Commission and Avangrid Renewables/Iberdrola Renewables, as well as many other distinguished state
agencies and organizations, the Horse Creek Wind Project has the potential to limit future Fort Drum base
needs and operations by creating conservation conditions that require habitat preservation for the federally-
endangered Indiana Bat on Fort Drum, compromising future base operations and development. As such, the
Horse Creek Wind Project must be denied planning permission in order to prevent potential future Fort Drum
base usage limitations in areas currently occupied by the federally-endangered Indiana Bat that would require
preservation if Horse Creek is constructed.
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15 Comments: Draft
Background
The Horse Creek Wind Farm is listed as located roughly 14 miles from Fort Drums DASR Radar. It Report: 5-46,
appears that this distance may be incorrect and actually closer to 12 miles. Horse Creek is roughly 8 Horse Creek
Wind Farm
miles from the border of Fort Drum.
Subsection
Recommendations:
1. Verify the distance between the Horse Creek Wind Farm and the DASR at Fort Drum and change as
needed.
16 Comment: Draft
Background
Bird strike risks could be substantially increased if large areas of the DASR are blanked out due to Report: 5-47,
additional wind turbine encroachment. In addition to the flight paths identified in the JLUS, this risk Wind Turbine
may also exist for any flights near the proposed Horse Creek Wind Project, which borders a nearly 8,000 Mitigation
acre Wildlife Management Area, the Perch River WMA, which is an important breeding and stopover Techniques
Subsection
sight for migrating birds.
Fort Drum is also located in portions of the Atlantic Flyway, a major East Coast Migratory Bird Pathway.
This locational reality heightens the risk for increased bird strikes, especially in the context of large
swaths of blanked out radar.
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Recommendations:
1. Add to the end of the first paragraph of the Wind Turbine Mitigation Techniques subsection:
Fort Drum is also located in portions of the Atlantic Flyway, a major East Coast Migratory Pathway.
This locational reality heightens the risk for increased bird strikes, especially in the context of large
swaths of radar Black Holes. Furthermore, various wildlife management areas, conservation areas and
breeding grounds exist on and around the St. Lawrence River and Eastern Basin of Lake Ontario. Wind
turbine development should be discouraged in such areas to prevent additional bird strike hazards to
Fort Drum.
17 Comments: Draft
Background
Fort Drum identified that as a worst case scenario, if all approved and proposed projects in the Study Report: 5-48,
Area (as of July 2017) are built, the total blind spot area would approach 300 square miles. 2nd sentence
before
Proposed
Not moving proactively to prevent such an increase in blind spot and request denial of the seven
New York
surrounding wind projects would hurt Fort Drum in future Base Realignment and Closure (BRAC) Legislation
processes. Addressing
Wind Energy
If there is a trend within the Fort Drum JLUS, clearly it is that industrial wind turbine development near Military
would cause an unacceptable amount of blind spots in radar systems. Installations
Subsection
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18 When sited appropriately and through coordination of stakeholders, renewable energy projects, such as Draft
industrial wind energy developments, can create benefits and economic development opportunities for Background
stakeholders, including increased tax revenues to local communities and school districts, and allowing Report: 5-48,
communities to continue agricultural activities by helping insulate farmers from changes in markets, loss of Finding
crops, or financial challenges associated with small farming. subheading,
first bullet
Comments: point.
It should be noted that while many local and regional stakeholders believe in responsible renewable
energy development, having carefully assessed the pros/cons and other siting considerations of such
development on a local and regional level over the last decade, many stakeholders are overwhelmingly
opposed industrial wind turbine development, especially in Jefferson County, which has a no-PILOT
Policy for such projects.
For example, as of November 16th 2017, 503 comments opposing the Horse Creek Wind Project, in part
due to concerns regarding the long-term viability of Fort Drum, have been submitted to the New York
Public Service Commission. This translates to 99.6% of commenting stakeholders opposing the Horse
Creek Wind Project.
If all 13 Towns currently engaged with the 7 industrial wind turbine projects noted in the JLUS had
been interviewed, this section of the JLUS would present a more nuanced and diverse opinion in
regards to the benefits and negatives of industrial-scale wind development. Unfortunately, only 1 of 13
Towns was reported as interviewed.
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In the absence of this information, the data gathered from participating members of public during the
Public Workshops is very important and must be included in the JLUS.
This Public Workshop data demonstrates public sentiment to industrial wind turbine development falls
strongly along county lines: Lewis County stakeholders are generally more receptive to industrial wind,
whereas Jefferson County stakeholders are opposed to industrial wind.
The final JLUS Report should acknowledge that Jefferson and Lewis County Stakeholders have different
opinions regarding siting industrial wind turbine arrays within their respective counties.
Recommendations:
1. Insert a bullet point after the first bullet point (reproduced above) to accurately describe regional
sentiment to industrial wind. This should include language, which could be empirically demonstrated by
data gathered during the Public Workshops, as well as a review of the PSC Case Files for these projects,
that Jefferson County stakeholders are generally opposed to industrial wind development, whereas
such development is more welcome in parts of Lewis County.
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19 Comments: Draft
Background
It is extremely concerning and unusual that Frequency Spectrum Impedance / Interference is not Report: 5-60,
considered as an important Compatibility Factor for the Fort Drum JLUS, given the well-documented Frequency
relationship between industrial wind turbine development and spectrum interference. This includes Spectrum
interference for numerous important spectrum systems, including: Impedance /
Interference
-S-band Nexrad Doppler Radar at Montague
-Army Radar Approach Control (ARAC) at Fort Drum (1 of 6 in Continental

United States.
-Digital television reception for rural residents and reception from

Transmission Towers in Watertown, including WWNY.
-Emergency radio transmissions, especially given recent plans to update

Emergency radio systems in Jefferson County.
Recommendations:
As clearly stated on page 3-33 of the Draft Background report:
The equipment in each radar is very sophisticated and can experience operational interference by a variety of
objects including terrain, tall structures and towers, and wind turbines, all based on elevations and topography
differences between the location of the radar and the potential interference.
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1. Frequency Spectrum Impedance / Interference must be included and thoroughly reviewed/discussed as

a Compatibility Factor in order to provide a completed Joint Land Use Study.
2. Failure to adequately address this important Compatibility Factor within the context of 7 proposed
industrial wind facilities is a major oversight that renders the Fort Drum JLUS incomplete.
20 Many local jurisdictions do not have zoning ordinances that directly address wind turbine siting and heights as Draft
it relates to military aircraft operations. Background
Report: 5-128,
Comments: Finding
subheading,
While this is true for many communities, it must be noted that some local jurisdictions where industrial 2nd bullet
wind developing is ongoing have developed general building height ordinances. As such, it should be point
noted that certain Towns currently engaged in industrial wind development do have regulatory
frameworks to address zoning issues, which include tall structures such as wind turbines.
21 Comments: Draft Public

Report: Cover
1. The top photo insert of Boldt Castle, the 2017 I Love NY #1 Warm Weather Tourist Attraction in New Page
York, is located in the Town of Alexandria, NY. Although the Town of Alexandria is located inside the 30
mile study radius, it is not listed among the project stakeholders nor the local jurisdictions interviewed
(Draft Background Report: 1-8) This should be of great concern and is a notable absence given the
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inclusion of Boldt Castle and, by default, the Thousand Islands, which is a source of great regional
importance due in part to tourism and world-famous Thousand Islands Region.
Link:
Recommendations:
2. Use of this photo should trigger a full expansion of the stakeholder partner listing to include all
municipalities within the 30-mile Study Area.

Report:
The background photo is an image of Boldt Castle in the Town of Alexandria. As noted in Comment 1, Second Cover
the Town of Alexandria was unfortunately not among local jurisdictions that were interviewed. Page
Nevertheless, the photo is included as a centerpiece.
If resources in Thousand Islands Region Towns (Clayton, Orleans, Alexandria, etc.) were important
enough to make the cover page, why were they not asked to participate as interviewed members of the
JLUS?
Recommendations:
1. At the very least, a caption should be included on the page identifying the photo. For example: Boldt
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Castle in the Town of Alexandria, in the Thousand Islands Region of the JLUS Study Area

Report: Page
After listing the participants of the Steering Committee, Technical Working Group, Development 5/118 in PDF
Authority of the North Country and Matrix Design Group, under the Special Appreciation heading, the
absence of a summary or description of the public participants that attended the four Public Workshop
sessions makes this section incomplete and incongruous with the aforementioned participant listings.
Furthermore, failure to include a breakdown of public participants damages the credibility of the JLUS
by failing to sufficiently acknowledge those members of the public who invested time in the process.
Recommendations:
1. At a minimum, a listing of total number of public participants should be included, with further
breakdown into number of participants by county. This information was either collected during the
sign-in process at the Public Workshops, and any missing information can be obtained by calling the
phone numbers or emailing participants, as this information was also collected during the sign-in
process.
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Report: Page
Fort Drum is incorrectly listed as being located: 1
roughly 40 miles from the Canadian Border
This is clearly demonstrated by the 30-mile Study Area Circle in Figure 1 on page 3 of the Draft Report.
In actuality, Fort Drum is located roughly 25 miles from the Canadian Border.
Recommendations:
1. Change the first sentence of the second paragraph to read Fort Drum is situated in northcentral New
York, seven miles northeast of downtown Watertown and roughly 25 miles from the Canadian border
(see Figure 1).

Report: Page
The Draft Report contains a 30-mile Study Area (Figure 1) and a list of stakeholders that were 2
interviewed to participate. The list of interviewed stakeholders represents only 8 of the total 47 Towns
that fall within the 30-mile Study Area.
The local jurisdictional stakeholders list excludes 83% of Towns within the Study Area and raises
important questions about how representative this minority is of the Study Area.
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Furthermore, given that compatibility of industrial wind development and Fort Drum is a central issue
of the JLUS, it is of even greater concern that only one of the 13 Towns (Town of Rutland) wherein the
seven industrial wind development projects identified as potentially problematic for Fort Drum was
interviewed and included as a listed stakeholder.
The listed objective of Stakeholder and Public Outreach was the:
Informing or involving them early in the project is instrumental in the identification of their most important
compatibility issues to address and resolve through the development of integrated strategies and measures.
(Page 1-8 of Draft Background Report)
There exists reasonable potential to misrepresent the Study Area and/or fail to develop and integrate
strategies and measures for compatibility measures related industrial wind development near Fort Drum
and the KTYX Radar Station located in the Town of Montague.
Towns in the 30-mile Study Area that were, per the Draft Background Report listing, not interviewed as
stakeholders:
Adams, Alexandria, Boylston, Brownville, Cape Vincent, Champion, Clayton, Croghan, Denmark, Edwards,
Ellisburg, Fine, Hammond, Harrisburg, Henderson, Hermon, Hounsfield, Lorraine, Lowville, Lyme, Macomb,
Martinsburg, Montague, Morristown, New Bremen, Orleans, Osceola, Pinckney, Pitcairn, Redfield, Rodman,
Rossie, Sandy Creek, Theresa, Watertown, Watson, West Turin, Wilna and Worth.
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Towns with ongoing industrial wind projects, per the Draft Background Report, not interviewed as
stakeholders:
Brownville, Clayton, Denmark, Harrisburg, Hounsfield, Lowville, Lyme, Martinsburg, Montague, Orleans,
Pinckney, Redfield and Worth.
Recommendations:
1. Consult directly with affected stakeholder local jurisdictions and incorporate especially those whose
jurisdictions have ongoing industrial wind development projects identified by the JLUS Study.
2. Provide a written explanation in the document detailing the methodology and reasoning employed to
identify and interview the 8 Towns and not the other 39 Towns in the 30-mile Study Area.
3. Provide a written explanation in the document detailing why it was deemed unnecessary to actively
interview and consult with Towns involved in what is arguably the JLUSs most high-profile issue,
industrial wind turbine development around Fort Drum.
Comment Form
November 2017
JLUS / Background
Document Location

Report: Page
The JLUS and consistently articulated the need for more participation and communication between 6
affected communities, such as with industrial wind development. Were communities affected by
industrial wind development projects communities asked to participate, and if not, have they been
approached since the Public Draft was published?
27 Comment: Draft Public

Report: Page
According to the 30-mile Study Area as seen in Figure 1 (Page 3 of Draft Public Report), 3 Oswego 6, Table 3
County Towns fall within the 30-mile Study Area. However, Oswego County is not listed as a Participant
as a member of the Technical Working Group.
Why was Oswego County not included as a member of the Technical Working Group? Would not the
inclusion of Oswego County be of even greater importance given that the Town of Redfield is currently
engaged in an industrial wind development project, Avangrids Mad River Project, which is partially
located within the Mitigation and Consultation Zones for the KTYX Weather Radar at Montague?
Recommendations:
1. Provide written explanation in the Draft Background Report as to the circumstances why Oswego
County was not included as a member of the Technical Working Group despite falling within the 30-mile
Study Area.
Comment Form
November 2017
JLUS / Background
Document Location
2. Reach out to Oswego County directly and invite them to participate in the December work session.
28 Comments: Public Draft

Report: Page
Under the subheading Public Workshops it states that: 7, Public
Workshops
Each workshop included a traditional presentation and a facilitated exercise providing a hands on, Subheading
interactive opportunity for the public to participate in the development of the study.
At the October 11 Public Workshop at Watertown High School, there was no traditional presentation (i.e.
PowerPoint/Slide Show/Presenter). There was a series of poster stations on a wall for the Public to view.
In fact, there was a Compatibility Issues Exercise where stakeholders ranked compatibility factors in
terms of importance, with options ranging from Very Important to Take Action to Not Important to
Take Action.
If helpful, results from the October 11 meeting in Watertown recorded by members of the public can be
made available to the JLUS in the form of photographs and/or Excel spreadsheet.
Unfortunately, the results of this Compatibility Issues Exercise as well as results from the three
additional public input data-gathering exercises from the previous Public Workshops do not appear
anywhere in either the Draft Background Report nor the Draft Report.
Comment Form
November 2017
JLUS / Background
Document Location
Failure to include these data will undercut the credibility of the report by damaging the perception of
public stakeholder involvement.
Members of the public made significant time investments to become active participants of the JLUS.
Not including data points they created is unacceptable and hurts credibility.
Recommendations:
1. Amend Draft Background Report to remove/or define traditional presentation.

2. Include the Data Points gathered from public input. Without the inclusion of public data collected
during the clicker-ranking Interactive Audience Response System (March 28-29) and the sticker-
ranking Compatibility Issues Exercise (October 10-11), it is impossible to fully integrate public
sentiment and achieve credibility, given the high-profile nature of compatibility factors related to
industrial wind development.
Failure to include the data gathered from these Public Workshops will severely damage the credibility
of the JLUS process and findings.
Comment Form
November 2017
JLUS / Background
Document Location

Report: Page
The JLUS website was not fully operational during the entire duration of the project. In fact, the day 8, Project
of the Public Workshop in Watertown in October, the Comment Submission Feature was not Webpage
operational. This was brought to the attention of DANC personnel, and who kindly and professionally Subheading
explained that a change in website providers during the middle of the JLUS was the reason for the error.

Report: Page
The majority of Fort Drum is classified as a Continental-Level Priority Important Bird Area by the 23, Bird /
Audubon Society, and supports grassland and shrub breeding bird populations of significant Wildlife
importance. Aircraft Strike
Hazard
Reference: http://www.audubon.org/important-bird-areas/fort-drum Relevancy
Area (BASH)
Recommendations: Subheading
1. Add the above sentence to the end of the second paragraph of the subheading, to read as follows:
These natural areas surrounding WSAAF offer potential habitats for a variety of Wildlife. Of important note is
that the majority of Fort Drum is also classified as a Continental-Level Priority Important Bird Area by the
Audubon Society, and supports grassland and shrub breeding bird populations of significant importance.
Comment Form
November 2017
JLUS / Background
Document Location

Report: Page
Wind and solar projects have the ability to produce height and glare issues respectively. This an encroachment 30,
concern since there are projects currently proposed within the Fort Drum JLUS Study Area. Department
of Energy
Why were 12 of the 13 Towns within the 30-mile Study Area with development stage industrial wind Office of
projects not interviewed to participate as members of the Technical Working Group? Energy
Efficiency and
Renewable
Many of the 13 Towns, such as the Town of Clayton (Horse Creek Wind Project) are formally opposed to
Energy
industrial wind development, specifically in order to prevent radar black holes, prevent interference Subheading,
on flight training and ensure future Fort Drum readiness and capabilities. last sentence.
Reference: https://townofclayton.com/2017/11/resolution-77-opposing-wind-farm-development-in-
proximity-to-fort-drum/
Given the regulatory framework of Article 10 and the inability of Towns to unilaterally deny electrical
generation projects of 25MW and above, it is essential that the JLUS clearly recognizes that local
jurisdictions are formally opposed to wind projects due to Fort Drum concerns.
Recommendations:
Address in writing why 12 of 13 Towns with active industrial wind projects were not interviewed to
participate as members of the Technical Working Group.
Comment Form
November 2017
JLUS / Background
Document Location
Include in the Background Report and Final JLUS Report the Town of Claytons Resolution #77,
Opposing Wind Farm Development in Proximity to Fort Drum
Link: https://townofclayton.com/2017/11/resolution-77-opposing-wind-farm-development-in-proximity-to-
fort-drum/
Resolution #77:
WHEREAS protecting the North Countrys airspace is vital to Fort Drums future as the Army is continually
evaluating the effectiveness of its training installations; and
WHEREAS wind farm development can be an important initiative to pursue as it offers an alternative green
source of energy that is pollution free and generated at the source, and while we recognize the benefits of
wind farm development, we simply do not want the strategic location of Fort Drum and their mission readiness
capability to be diminished; and
WHEREAS as the major economic engine of the North Country and largest single site employer, the economic
vitality of the region and thousands of jobs depend on its continued relevance to the Army mission; and
WHEREAS protecting and enhancing Fort Drum, home to the 10th Mountain Division, is of utmost priority to
the Town of Clayton;
NOW THEREFORE BE IT RESOLVED that the Town Board of the Town of Clayton opposes the industrial wind
projects being evaluated by New York States Article 10 Siting Board and the Public Service Commission in the
immediate proximity to Fort Drum to ensure the national security and continued readiness for future training
missions.
Comment Form
November 2017
JLUS / Background
Document Location

Report: Page
Have the St. Regis Mohawk Tribe, Oneida Indian Nation and Onondaga Nation been made aware of the 33
JLUS?

Report: Page
As with the Methodology and Evaluation section in the Draft Background Report, this section in the 41,
Draft Public Report is also underdeveloped and does not adequately explain how existing and future Methodology
compatibility factors were prioritized by the Steering Committee, Technical Working Group and Public and
Evaluation
Stakeholders.
Subheading
How exactly were existing and future compatibility factors prioritized?
Why does the Methodology and Evaluation section not include data gathered during the four Public
Workshops, specifically the results of the Compatibility Issues Exercises gathered during Public
Workshop #1 and Public Workshop #2?
Failure to thoroughly explain address the methodology process, specifically compatibility factor
prioritization by the three aforementioned parties, would render and final JLUS documents inadequate
and demonstrate a lack of transparency.
Comment Form
November 2017
JLUS / Background
Document Location
34 The development of strategies to address compatibility is directly and indirectly affected by the evaluation of Draft Public
issues. Issues were prioritized into four different categories with an associated timeframe and presented to the Report: Page
SC and TWG for review. Since the SC and TWG accepted the priorities as is, the priorities will be used to 41,
determine the timeframe for initiating strategies by the primary and partner organizations. Methodology
and
Comments: Evaluation
Subheading
The methodology used to identify which compatibility factors were deemed important to stakeholders,
specifically as "the public examined and prioritized the extent of existing and potential future
compatibility issues" is unclear, especially given the non-inclusion of data collected during the Public
Workshops.
Without more description of the methodology employed, specifically the inclusion of the data sets
gathered during four total Public Workshops, it is impossible for the JLUS to fulfill the "Understanding"
Objective of the JLUS.
Without more information, the lack of detail undercuts the validity of the Compatibility Assessment.
Recommendations:
1. Thoroughly describe the methodology employed in order to sufficiently explain how the SC, TWG,
and the public examined and prioritized the extent of existing and potential future compatibility issues
that could impact land within or near the JLUS Study Area.
Comment Form
November 2017
JLUS / Background
Document Location
2. Include in both the Final Public Report and the Final Background Report the full results/data sets of the
Public Workshops, specifically the results of the Compatibility Assessment Exercises held in Evans Mills
Fire Hall (March 28, 2017), Lowville Academy (March 29, 2017), Lowville Academy (October 10, 2017)
and Watertown High School (October 11, 2017).

Report: Page
Should this bullet point be expanded to address specific Compatibility Factors that would affect and 43, 4th Bullet
disturb this Awareness Factor? Point (Light
Encroachmen
t on Native
Is industrial wind development/lighted 500-700 ft. towers potential disruptors?
American
Ceremonies)
Have the St. Regis Mohawk Tribe, Oneida Indian Nation and Onondaga Nation reviewed the language
included in this section that directly addresses this Awareness Issue?

Report: Page
Restricting certain land uses around Fort Drum could just as easily positively impact economic 47, Land Use
development and residential character for neighboring communities. Subheading,
2nd Bullet
Point
The original language is too restrictive and incorrectly implies that land use restrictions can only
generate negative economic consequences.
Comment Form
November 2017
JLUS / Background
Document Location
Recommendations:
1. Amend the sentence in question as follows:
Restricting certain land uses around Fort Drum could negatively or positively impact economic development
and residential character for neighboring communities.
37 The key to the implementation of strategies is the establishment of a Fort Drum Compatibility Committee (see Draft Public
Strategy COM1F) to oversee the execution of the JLUS. Through this committee, local jurisdictions, Fort Drum, Report: Page
developers, and other stakeholder parties can continue their collaboration to establish procedures, recommend 51, paragraph
or refine specific actions, and make adjustments to strategies over time to ensure the JLUS continues to resolve 4
key compatibility issues into the future through realistic strategies and implementation.
Comments:
Compatibility Committee membership must be as inclusive and diverse as possible.
Local jurisdictions that are engaged with Compatibility Issues must have full voice and participatory
powers.
Example: If the issue of Energy Development (ED) is being discussed, it is logically requisite that local
jurisdictions that have ongoing, planned or proposed solar, industrial wind or biofuel projects be
included in the Compatibility Committee.
The Horse Creek Wind Project is a proposed industrial wind facility within the 30-mile Study Area. The
Comment Form
November 2017
JLUS / Background
Document Location
Towns of Clayton, Orleans, Brownville and Lyme must be allowed to fully participate on the
Compatibility Committee, long with any other local stakeholder group.
Recommendations:
1. Amend the fourth paragraph to fully recognize the inclusion of affected local jurisdictions and
stakeholder groups as full participatory members of any Compatibility Committee:
Through this committee, local jurisdictions, Fort Drum, developers, and other stakeholder parties with
can continue their collaboration to establish procedures, recommend or refine specific actions, and
make adjustments to strategies over time to ensure the JLUS continues to resolve key compatibility
issues into the future through realistic strategies and implementation. Local jurisdictions and local
stakeholder groups, especially those engaged in a compatibility issue at the local level, will be
formally invited to participate as committee members to ensure local input and social inclusion.

Report: Page
The list of primary partners is incomplete and does not include a number of important stakeholders 63, BIO-1C
who possess specialized knowledge of regional conservation issues.
Incorporating additional specialized stakeholders and their recommendations, as well as other

documentation will make it easier to prevent regional habitat fragmentation that would result in Fort
Drum becoming a wildlife refuge island (Page 63, Bio-1C).
Comment Form
November 2017
JLUS / Background
Document Location
Recommendations:
1. In some instances, documentation already exists and should be immediately incorporated into the JLUS
and all future recommendations.
2. Incorporate the recommendations of an already-listed Primary Partner, the Thousand Islands Land
Trust, which clearly states that development of industrial wind turbines within the Thousand Islands
Region (Horse Creek Wind Project) and the Eastern end of Lake Ontario (Galloo Island Wind Project)
would cause:
habitat fragmentation and edge encroachment, these projects threaten the rare natural alvar
communities, which are critical for the survival of threatened plant and animal species.
Also:
Three federally endangered and threatened bat species, also listed in New York, occur in these regions.
Utility-scale wind energy generation facilities cause significant mortality for many bat species. Already
experiencing great stress and decline due to "white nose syndrome", increased bat kills from turbine
impacts will decimate remaining bat populations.
Link:
http://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId={85668E3B-B528-43C1-BC35-
975B694B7225}
Comment Form
November 2017
JLUS / Background
Document Location
3. Include written opposition to the Horse Creek Wind Project due to the presence of federally-
endangered bat species in the project area. The project would create habitat fragmentation and
population loss that would potentially force Fort Drum to serve as a wildlife refuge island,
limiting base operations.
4. Invite Ontario Bays Initiative, Inc., a local land trust in 30-mile Study Area, to serve as a Partner and
incorporate their findings in regards to industrial wind turbine-caused habitat fragmentation and Fort
Drum.
Link: http://www.obilandtrust.org/obi-wind-power-statement-and-horse-creek-statement.html
Note: The Ontario Bays Initiative, Inc. service area includes 8 Towns within the 30-mile Study Area,
including 4 Towns with active industrial wind energy projects (Lyme, Brownville, Henderson and
Hounsfield).
The service area also includes the Towns of Pamelia and LeRay, directly adjacent to Fort Drum. Ontario
Bays Initiative, Inc. is thoroughly aware of risks to federally-endangered bat species and is familiar on
regional bat conservation, being the owner of the Alex C. Veto Bat Conservation Area in the Town of
LeRay. This group could compliment the excellent environmental conservation teams on base.
Link: http://www.obilandtrust.org/alex-c-velto-bat-conservation-area.html
Comment Form
November 2017
JLUS / Background
Document Location
4. Invite Audubon New York to become a Partner and incorporate their findings regarding habitat
fragmentation due to industrial wind energy development, including:
Audubon New York does not support the construction of the proposed Horse Creek Wind Energy
Project as currently proposed. We recognize the importance of establishing alternative sources of
energy, but we cannot support a project with the potential to jeopardize the at-risk species supported
at this site.
Link: http://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId={38ACA503-82F2-4F16-
A02E-092226373D17}

Report: Page
The Partner list for BIO-1D is incomplete and should be amended to incorporate additional stakeholders 63, BIO-1D
and organizations with critical regional experience and insight.
Some local jurisdictions within the 30-Mile Study Area have recently updated Comprehensive Plans that
address habitat protection policies.
Recommendations:
1. Add TILT, Audubon New York, Ontario Bays Initiative Inc., and Onondaga Audubon Society as
Partners.
2. Review the 2017 Town of Clayton Comprehensive Plan, specifically chapter 12, to draw inspiration
Comment Form
November 2017
JLUS / Background
Document Location
for findings and develop a template for planning issues in other local jurisdictions.
Link: https://townofclayton.com/wp-content/uploads/2017/03/JOINT-TOWN-VILLAGE-OF-CLAYTON-
COMPREHENSIVE-PLAN-V2017-1.pdf

Report: Page
The Partner List suggested lacks full public involvement and should be open to additional stakeholder 66, COM-1F
groups.
Recommendations:
1. Invite other stakeholders in the 30-mile Study Area to fully participate as partners of the Fort Drum
Compatibility Commission. Partnership invitations should be extended to any local jurisdiction
within the 30-mile Study Area, as well as other relevant local and regional stakeholder groups,
especially those engaged in Compatibility Issues.

Report: Page
The Partner List suggested lacks full public involvement and should be open to additional stakeholder 67, COM-1G
groups.
Recommendations:
Comment Form
November 2017
JLUS / Background
Document Location


Report: Page
In order to create the best GIS web-based portal, it is essential to include the full participation of 67, COM-1H
relevant local organizations, jurisdictions, local stakeholder groups, as well as relevant research and
documentation.
Fortunately, a remarkable amount of research and information exists to help develop this important
Compatibility Factor, including documentation co-created by conservation and industrial wind
developers pursuing projects within the 30-mile Study Area.
Recommendations:
1. Incorporate the 2014 NYSERDA / Industry Biodiversity and Mapping Tool.
This remarkable document and mapping tool was created by the New York State Energy and
Research Development Authority (NYSERDA), the New York Natural Heritage Program (NYNHP) and
the Nature Conservancy (TNC). Furthermore, the Project Advisory Committee Members include
Iberdrola/Avangrid and the Tug Hill Commission, two Technical Working Group members of the
JLUS. As such, this document and mapping tool should be incorporated into the GIS web-based
Comment Form
November 2017
JLUS / Background
Document Location
portal without any problem.
The document and mapping tool co-generated by the wind industry clearly demonstrates that
the vast majority of Jefferson County, especially including the current Horse Creek Project area, is
the worst possible location for industrial wind development.
Link: https://www.nyserda.ny.gov/-/.../Wind-Power-and-Biodiversity-in-New-York.pdf
Link to Online Mapper Tool: http://www.ebd.mapny.info/
2. Note in the GIS web-based portal that the Horse Creek Wind Project, along with the vast majority
of Jefferson County, is incompatible with biodiversity concerns and should be rejected, in part to
protect Fort Drum from becoming a wildlife refuge island.
Comment Form
November 2017
JLUS / Background
Document Location

Report: Page
In order to thoroughly assess how ...industrial wind energy development should be discouraged to 72, ED-1A
avoid incompatibility with Fort Drums operations, it is vital to incorporate the knowledge of other
stakeholders, organizations, local jurisdictions and experts who are familiar with Compatibility Factors,
such as conservation issues and other matters, which could impact Fort Drum.
Recommendations:
1. Invite other stakeholders in the 30-mile Study Area to fully participate as partners in addressing ED-
1A. Partnership invitations should be extended to local jurisdictions within the 30-mile Study Area,
as well as other relevant local and regional stakeholder groups, especially those engaged in
Compatibility Issues, such as conservation and biodiversity.

Report: Page
Jefferson County has passed a strict policy of no PILOT agreements for industrial wind projects. 73, ED-1B
Furthermore, under the current Uniform Tax Exemption Policy (UTEP) of the Jefferson County Industrial
Development Authority, all renewable energy projects are treated as deviations. As such, developers
should recognize this clear position and not pursue such wind projects, so as to respect the wished of
the local community.
Lewis County has indicated that it will offer PILOT agreements for industrial wind projects. As such,
Comment Form
November 2017
JLUS / Background
Document Location
developers would be better served pursuing projects in Lewis County and not in Jefferson County.
Developers can and should substantially reduce ongoing regional tensions regarding industrial wind
development by pursuing projects in areas where they have a social license from the community and
avoiding areas where they do not. As Public Service Commission General Council Paul Agresta recently
stated at the Alliance for Clean Energy New York Annual Conference in Albany in October:
We want developers to go to a town where they're wanted and work it out."
Link:
https://orleanshub.com/community-cant-rest-in-opposing-wind-turbine-project-in-yates-somerset/

Report: Page
73, ED-1C
Establishing a Regional Wind Energy Policy Steering Group is a good step, but must be open to all
affected stakeholders, organizations, local jurisdictions engaged with industrial wind development in
order to earn full validity and increase the opportunities for projects to earn a social license. This will
also allow for decisions to be made on a tailored, project-by-project basis.
Recommendations:
1. Amend the Issue/Strategy as follows:
Fort Drum, in partnership with county and city / town /village leadership (including jurisdictions engaged
Comment Form
November 2017
JLUS / Background
Document Location
with an industrial wind development project), local organizations and stakeholders, local and regional
conservation groups and industrial development agencies within the North Country, should create a Regional
Wind Energy Policy Steering Group that will advise on actions that should be taken to raise awareness of
proposed projects and their associated impacts to Fort Drum.
2. Other Supporting Partners should include Jefferson County, The Town of Clayton, the Town of
Orleans, Ontario Bays Initiative, Inc., and other parties the meet the changes in bold made in
Recommendation 1.

Report: Page
It should be noted that the Town of Clayton, a local jurisdiction both within the 30-mile Study Area and 74, ED-1E
currently engaged with industrial wind energy development, recently fulfilled this Issue/Strategy by
completing a new comprehensive plan that addresses renewable energy development.
Specific mention should be made of Chapters 9 and 12, which potentially serve as a template for other
local jurisdictions interested in updating their comprehensive planning documents.
Link:
https://townofclayton.com/wp-content/uploads/2017/03/JOINT-TOWN-VILLAGE-OF-CLAYTON-
Comment Form
November 2017
JLUS / Background
Document Location

Report: Page
In the case of the Horse Creek Wind Project, which is proposed for a location less than 10 miles 74, ED-1F
northwest of Fort Drum in the 30-mile Study Area local jurisdictions of Clayton, Lyme, Brownville and
Orleans, the primary project town, the Town of Clayton, has recently adopted a new comprehensive
plan that clearly defines the Towns incompatibility with industrial wind development.
Additionally, the Town of Clayton has formally opposed Horse Creek and accused the project developer,
Avangrid Renewables, via the Article 10 Project Case File, of presenting public outreach documents that
are a :
"knowingly fraudulent misrepresentation regarding the true level of public opposition to the Horse Creek
Project"
Link:
http://documents.dps.ny.gov/public/Common/ViewDoc.aspx?DocRefId=%7BBFE5782B-8832-410D-
A9F4-C10F148332A3%7D
Link:
https://townofclayton.com/2017/11/resolution-77-opposing-wind-farm-development-in-proximity-to-fort-drum/
Comment Form
November 2017
JLUS / Background
Document Location
Unfortunately, Avangrid Renewables decision to pursue the Horse Creek Wind Project despite
widespread, documented public opposition appears to have created an environment of hostility against
many industrial wind projects, even those that are potentially more compatible, sited for friendly
jurisdictions and could otherwise contribute to New Yorks admirable renewable energy generation goal
of 50% renewable energy by 2030.
Recommendations:
1. Avangrid Renewables should discontinue the unwanted and incompatible Horse Creek Wind
Project to reduce regional opposition to industrial wind development.

Report: Page
Local support is essential to achieve conditions and a social license where wind energy development 74, ED-1H
projects can be successful. It is essential for industrial wind developers to directly coordinate with local
stakeholder groups and understand the absolute necessity to earn a social license from affected
jurisdictions.
Developers should respect the wishes of local jurisdictions that have publically stated that additional
economic benefits for developers, like a PILOT agreement, will not be entertained for industrial-scale
renewable energy projects.
Example: Jefferson County
Comment Form
November 2017
JLUS / Background
Document Location
Recommendations:
1. Invite other stakeholders in the 30-mile Study Area to fully participate as partners in addressing ED-
1H. Partnership invitations should be extended to local jurisdictions within the 30-mile Study Area,
as well as other relevant local and regional stakeholder groups, especially those engaged in
industrial-scale renewable energy development.

Report: Page
It is excellent to see that the local jurisdictions of Jefferson County and Oswego County have been 75, ED-1I
referenced in regards to the creation of a uniformed tax exemption policy.
Due to the importance of Ft. Drum to Jefferson County, the Jefferson County Legislature has also passed
a resolution consistent with other States, and the NY State Senate's Energy Committee, to nullify Wind
Energy projects within 40 miles of Military Aviation and Weather radar installations required for the
success of Ft. Drums mission.
Recommendations:
1. Consider detailing the policies of the different jurisdictions. For example, in Jefferson County, the
County has passed a strict policy of no PILOT agreements for industrial wind projects. Furthermore,
under the current Uniform Tax Exemption Policy (UTEP) of the Jefferson County Industrial
Development Authority, all renewable energy projects are treated as deviations.
Comment Form
November 2017
JLUS / Background
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50 Recommendations: Draft Public

Report: Page
1. Please review and consider the linked article, Impact analysis of wind farms on telecommunication 76, ED-2B
services, published in the peer-reviewed scientific journal Renewable and Sustainable Energy
Reviews in 2014. This article, in which the authors thank the partners from Iberdrola Renovables
for their continuous support and involvement in the study discusses how the World Meteorological
Organization:
Propose[s] to prohibit any installation of wind farms in a radius ofapproximately10km for S band
radars. (Page 87)
Link:
http://www.sciencedirect.com/science/article/pii/S1364032114000100

Report: Page
The easiest way to preserve high-quality Indiana Bat habitat is to deny the Horse Creek Wind Project. 82, LAS-2C
Located less than 10 miles to the north/northwest of Fort Drum, this project is proposed for some of
the best Indian Bat habitat in New York State. If this habitat is compromised and fragmented, it will
increase the dangerous potential of Fort Drum becoming a wildlife refuge island, thus compromising
future base operations and training.
Comment Form
November 2017
JLUS / Background
Document Location
In addition to the Tug Hill Tomorrow Land Trust (Lewis County), is essential to include as Partners other
conservation organizations and Land Trusts whose service areas include Jefferson County.
Recommendations:
1. Preserve important Indiana bat habitat by formally opposing the Horse Creek Wind Project. It is a
regional threat to this federally endangered species.
2. Include the Thousand Islands Land Trust, Ontario Bays Initiative, Inc., and other local and regional
conservation organizations as Partners.
3. Review and incorporate Figure B-17, A map of Indiana Bat locations and travel zones, found on
Page B-33 of the 2014 NYSERDA Wind Power and Biodiversity in New York: A Tool for Siting
Assessment and Scenario Planning at the Landscape Scale Report into all future issues related to
the Indiana Bat.
Link:
https://www.nyserda.ny.gov/-/.../Wind-Power-and-Biodiversity-in-New-York.pdf

Report: Page
Some local jurisdictions within the 30-mile Study Area, such as the Town of Clayton, have proactively 83, LU-1B
considered Fort Drum compatibility and encroachment issues. This information can be found in chapter
12 of Claytons Comprehensive Plan.
Comment Form
November 2017
JLUS / Background
Document Location
Link:
https://townofclayton.com/wp-content/uploads/2017/03/JOINT-TOWN-VILLAGE-OF-CLAYTON-

Report: Page
Restricting certain land uses around Fort Drum could just as easily generate positive economic 88, LU-2
development and residential character for neighboring communities.
The original language is too restrictive and incorrectly implies that land use restrictions can only
generate negative economic consequences.
Recommendations:
2. Amend the sentence in question as follows:
Restricting certain land uses around Fort Drum could negatively or positively impact economic development
and residential character for neighboring communities.
Comment Form
November 2017
JLUS / Background
Document Location

Report: Page
It is well established that tourism is a leading industry in the Thousand Islands Region portion of the 88, LU-2A
JLUS Study Area.
Tourism, responsible for 10.3% of Thousand Islands Regional employment in 2014 should be included
as a leading industry that is compatible with Fort Drum. (Slide 38 of linked Oxford Economics Report)
Jefferson County and specifically the Thousand Islands Region is a key tourism industry driver. This
regions viewshed and natural beauty which drive tourism must be protected from inappropriate
development, including the threat of industrial wind development (Horse Creek Wind Project) which
would also negatively impact Fort Drum via radar interference, rare habitat fragmentation and
destruction and reduction of regional airspace.
Additional Partners for LU-2A must include the 1000 Islands International Tourism Council, which serves
the region.
According to a report conducted by respected firm Oxford Economics, in 2014, tourism in the Greater
Thousand Islands Region (Jefferson, Oswego and St. Lawrence Counties) was a $498 million industry,
responsible for 8,842 jobs. (Slide 30 of linked report)
Link:
http://slideplayer.com/slide/6664005/
Comment Form
November 2017
JLUS / Background
Document Location
In Jefferson County alone, travelers spent $248 million in 2014. Clearly, tourism is a central economic
driver for the region, especially for areas of the 30-mile Study Area with tremendous areas of natural
beauty, especially in the Thousand Islands Region/St. Lawrence River Towns Corridor, which consists of
Alexandria, Orleans, Clayton, Cape Vincent and Hammond.
As a clear case in point, Boldt Castle, located in the Study Area Town of Alexandria (Thousand Islands
Region) and the image that was chosen as the cover photo of the JLUS, was recently voted the # 1
Warm Weather Travel Destination in New York State.
Link:
Furthermore, the Town of Clayton was recently named the Best Small Town in the Entire Great Lakes
by Coastal Living magazine, and was voted the Third Coolest Small Town in the United States by a
NBS News.
Links:
https://www.coastalliving.com/travel/other-coasts/thousand-islands-new-york-canada-travel-guide
http://www.nbcnews.com/id/44259681/ns/travel-destination_travel/t/coolest-small-towns-america/
Comment Form
November 2017
JLUS / Background
Document Location
Recommendations:
Invite the 1000 Islands International Tourism Board and other local chambers (ex. Clayton, Alexandria
Bay, etc.) to fully participate in the development of economic development marketing guidelines.
Articulate that tourism has already been identified as a leading regional industry and is compatible with
Fort Drum.
Articulate that industrial wind development within Jefferson County and the Thousand Islands Region
compromises the regional viewshed and therefore this $500 million annual industry.

Report: LEG-
Numerous local, state and federal legislators have voiced concern and even outright opposition to 1A
industrial wind development around Fort Drum.
10/4/17: NY Governor Andrew Cuomo expressed concern about wind turbine projects (including Horse
Creek) near Fort Drum during a visit to Watertown. Gov. Cuomo: "I see the potential danger" and "The
opinion of Fort Drum and the people of Watertown matters most".
Link:
Comment Form
November 2017
JLUS / Background
Document Location
https://www.youtube.com/watch?v=VbTZro_TcAU&feature=youtu.be
10/3/17: The Jefferson County Board of Legislators overwhelming passed a resolution opposing the
current wind projects near Fort Drum, including Horse Creek.
Link:
http://www.watertowndailytimes.com/news03/jefferson-county-board-passes-resolution-opposing-
wind-projects-near-fort-drum-20171004
10/2/17: Watertown City Council unanimously passed a resolution opposing the eight wind projects
around Fort Drum, supporting Governor Cuomo's initiatives on renewable energy, but opposes wind
proposals around Fort Drum that would damage the base's airspace and training requirements.
Link:
http://www.wwnytv.com/story/36506604/watertown-lawmakers-vote-to-oppose-area-wind-farms
9/12/17: The Fort Drum Regional Liaison Organization (FDRLO) strongly opposes eight industrial wind
projects near Fort Drum, including Horse Creek, concerned that they will greatly reduce the
installations training capability.
Link:
https://www.facebook.com/drum2025/posts/733347473519273
Comment Form
November 2017
JLUS / Background
Document Location
9/12/17: US Rep. Elise Stefanik (R-NY-21) sends letter of concern to U.S. Army Chief of Staff about
industrial wind development near Fort Drum
Link:
https://www.facebook.com/notes/river-residents-against-turbines-river-rats/us-rep-elise-stefanik-
sends-letter-of-concern-to-us-army-chief-of-staff-about-in/276759392838604/
9/8/17: NY Assemblywoman Addie Jenne (D-NY-116), after visiting Fort Drum and learning about
potential risks due to turbine encroachment, is exploring legislation that would prevent wind projects
around Fort Drum, such as Horse Creek, from receiving state subsidies
Links:
http://www.wwnytv.com/story/36320929/jenne-plans-legislation-to-prevent-state-subsidies-for-wind-
projects
https://assemblywomanjenne.blogspot.com/2017/09/assemblywoman-jenne-exploring-ways-to.html
11/9/17: the Town of Clayton formally opposes wind turbine development in proximity to Fort Drum,
citing the need to ensure the national security and continued readiness for future training missions.
Link:
Comment Form
November 2017
JLUS / Background
Document Location
https://townofclayton.com/2017/11/resolution-77-opposing-wind-farm-development-in-proximity-to-
fort-drum/

Report: Page
Given that the Fort Drum Compatibility Committee is considered the lead agency for execution of LEG- 90, LEG-1B
1B, it should be noted that the creation of unbiasedinformation will be difficult if not impossible,
as wind developers with a vested interest in developing projects are to serve as members of the
Compatibility Committee.
Recommendations:
Any information pertaining to the Article 10 Process should be generated and provided independently
by the Public Service Commission.
Furthermore, any changes proposed by the Fort Drum Compatibility Committee should be recirculated
to Public Service Commission staff and counsel to ensure impartiality.
Comment Form
November 2017
JLUS / Background
Document Location

Report: Page
This information will help these jurisdictions can make informed decisions about zoning regulations and future 98, SA-3B
development within the No-Build Zone to help ensure land uses that are compatible within the zone.
This statement suggests that the JLUS understands local zoning laws and regulations to be the ultimate
authority on allowed land use, including within the context of industrial-scale industrial wind
development projects that are submitted under the Article 10 process.
It is essential for jurisdictions, including those outside of the 30-mile Study Area that rely upon the
Montague S-band weather radar to be included as Partners for SA-3B, such as Oswego County, and
Jefferson County
It appears there is a grammatical error with the inclusion of can make.
Recommendations:
Formally ask Jefferson County and Oswego County to participate in SA-3B, and actively identify other
impacted jurisdictions that should be included.
Eliminate the word can so the passage reads: will help these jurisdictions make.
Comment Form
November 2017
JLUS / Background
Document Location

Report: Page
Local communities, especially towns and counties with industrial wind projects within their 100, VO-3B
jurisdictions, should solicit such input. Under current circumstances, this would include the 13
aforementioned Towns with the 30-mile Study area with ongoing industrial wind development projects.
In addition to aviation mission and training operations, it is highly valuable to deliberately note the
importance of protecting Fort Drum from becoming a wildlife refuge island that could impact
operations and capabilities. This should be noted in VO-3B.
The word citing is incorrectly used and should be amended to the appropriate homonym.
The word installations is used when it appears the intended meaning is meant to be possessive.
Recommendations:
Add a clause after local communities to incorporate the jurisdictions with active industrial wind
energy development projects.
Add a clause after training operations that recognizes the importance of preventing habitat
fragmentation to Fort Drums overall objectives.
Change citing to siting.
Comment Form
November 2017
JLUS / Background
Document Location
Change installations to installations
The revised VO-3B would read as follows:
Local communities, specifically those jurisdictions with ongoing industrial wind development projects, should
solicit Fort Drums input when siting tall structures to ensure they are compatible with the installations
aviation mission and training operations, as well as not contribute to Fort Drum becoming a wildlife refuge
island.
58

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Fort Drum JLUS Public Draft Review

The listed objective of Stakeholder and Public Outreach was the:

2. Describe in detail how Public Workshop data was incorporated.

1. Amend Draft Background Report to remove/or define traditional presentation.

The passage could read (new language in bold):

-S band Nexrad Doppler Radar at Montague

-Army Radar Approach Control (ARAC) at Fort Drum (1 of 6 in Continental United

-Emergency radio transmissions. This is currently a major topic of discussion in

As clearly stated on page 3-33 of the Draft Background report:

As such, Frequency Spectrum Impedance / Interference must be included and thoroughly

This is best explained on page 5-22 of the Draft Background Report:

-Army Radar Approach Control (ARAC) at Fort Drum (1 of 6 in Continental

-Digital television reception for rural residents and reception from

-Emergency radio transmissions, especially given recent plans to update

As clearly stated on page 3-33 of the Draft Background report:

1. Frequency Spectrum Impedance / Interference must be included and thoroughly reviewed/discussed as

21 Comments: Draft Public

22 Comments: Draft Public

23 Comments: Draft Public

24 Comments: Draft Public

roughly 40 miles from the Canadian Border

25 Comments: Draft Public

The listed objective of Stakeholder and Public Outreach was the:

26 Comments: Draft Public

27 Comment: Draft Public

28 Comments: Public Draft

1. Amend Draft Background Report to remove/or define traditional presentation.

29 Comments: Draft Public

30 Comments: Draft Public

31 Comments: Public Draft

32 Comments: Draft Public

33 Comments: Draft Public

How exactly were existing and future compatibility factors prioritized?

35 Comments: Public Draft

36 Comments: Draft Public

1. Amend the sentence in question as follows:

Compatibility Committee membership must be as inclusive and diverse as possible.

38 Comments: Draft Public

Incorporating additional specialized stakeholders and their recommendations, as well as other

39 Comments: Draft Public

40 Comments: Draft Public

41 Comments: Draft Public

Compatibility Commission. Partnership invitations should be extended to any local jurisdiction

42 Comments: Public Draft

1. Incorporate the 2014 NYSERDA / Industry Biodiversity and Mapping Tool.

portal without any problem.

Link to Online Mapper Tool: http://www.ebd.mapny.info/

43 Comments: Draft Public

44 Comments: Draft Public

We want developers to go to a town where they're wanted and work it out."

45 Comments: Draft Public

1. Amend the Issue/Strategy as follows:

46 Comments: Draft Public

47 Comments: Draft Public

48 Comments: Draft Public

49 Comments: Draft Public

50 Recommendations: Draft Public

51 Comments: Draft Public

52 Comments: Draft Public

53 Comments: Draft Public

2. Amend the sentence in question as follows:

54 Comments: Draft Public

55 Comments: Draft Public