Assessor

Supervisor
THOMAS K RIENIlECK TOWN OF CAPE VINCENT
ROBERTVR. BARNARD
JEFFERSON COUNTY, NEW YORK 13618
Historian
Town C1erk/Tex Collector
JERI A MASON PETER J MARGREY

Planning Board Chairman

Councilmen
MARTYT MASON RICHARD J EDSALL
JOSEPH H. WOOD
Boord of Appeals Chairmen
DONALD J MASON
EDWARD p. BENDER
MICKEY W. ORVIS

Superintendent of Highways Zoning Enforcement Officer

DANNY p. HUBBARD ALAN N. WOOD

FAX (315) 654-3366

10/30/09

Re: Visual Mitigation for Cape Vincent

To: Whom It May Concern

I have been involved in the process of collaborating with St. Lawrence Windpower on
mitigation for unavoidable visual impacts caused by the St. Lawrence Wind Farm. I have
also been involved in brainstorming and ultimately proposing projects that the Town can
support. In doing so, we would be amenable to the following projects:

• Restoration/painting of buildings at the Tibbett's Point Lighthouse

• Burying the electric lines and transformer at Tibbett's Point
• Restoring the tower/clock at the Fire Hall
• Fixing the fence at the Market Street Cemetery, and
• Setting up a fund for screening of historically significant buildings and homes

I look forward to working with the St. Lawrence Team in finalizing these plans in the
near future. Thank you.

Sincerely,

Thomas K. Rienbeck
Town Supervisor
Town of Cape Vincent
03/23/2813 15:2~ 9413070274 PAGE 02

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March 24, 2010

Bryan Stumpt

St La\VT.ence Windpower

122 South Point Street

Cape Vincent, New York~ 13636

DearBryan~

W'e appreciate and accept the invitation for the balance of the Wind Committe~ to attend
the presentation by Hessler Associates t.o the Plannitlg Board on Apri114 at 7:00PM.

It is important that the Committee has an opportlUlity to learn how Hessler nlt~asures
sound as compared to the Town's consultant and detemline for thenlselves what is
appropriate for Cape Vincent. That bessler has been the sOl..llld consultant for 54 wind
projects is indeed iInpresslve. To that extent it would be nl0st helpful to have the names
and loc.ations of those projects so as to compare them witb the demographics and other
characteristics of our proposed project.

Please send this infonnalion to the Wind Committee to mv attention. Additionally where
the sound studies where part of a public document such ~ a DEIS we would appreCiate
that information as welL

We look forward to receiving this information. and meeting the officiaJs from Hessler and
Associates on April 14.

Urban Hirschey /

("'-~~ it ~O-~
Supervisor Cape Vincent~ NY
 Sound Level Survey
and
Noise Impact Assessment
Acciona St. Lawrence Wind Project
 Study Overview
„ Establish existing conditions through field
surveys of natural environmental sound levels
„ Model and map the expected sound emissions
of the project
„ Evaluate project sound levels relative to existing
levels to gauge potential impact
 Background Sound Surveys
„ Necessary to evaluate NYSDEC guidelines,
which suggest a maximum increase of no more
than 6 dBA over the existing background level
due to a new source.
„ Summertime Conditions:

17 Day Survey - Aug. 22 to Sep. 8, 2007

„ Wintertime Conditions:

20 Day Survey – Dec. 14, 2007 to Jan. 4, 2008

 Survey Objectives
„ Conservatively determine the existing site-wide
background sound level as a function of wind
speed.
„ Evaluate any seasonal variation.
„ Evaluate any variation in level within the site area.
„ Specifically evaluate sound levels at the River’s
edge.
„ Establish baseline levels from which a 6 dBA
increase could be calculated.
Measurement Positions
 Position 1 – Co. Rd. 9
Setting: Edge of wooded area remote from all roads and
farm activity, 1025 ft. from Co. Rd. 9
 Position 2 – Millen Bay Rd.
Setting: Open field, 330 ft. from road
 Position 3 – River Bank
Setting: Within 10 ft. of the River shore. At the bottom of an
embankment shielding the location from Rt. 12E
 Position 4 – Branche Road
Setting: Open field adjacent to typical farm
 Position 5 – Rt. 12 E
Setting: Side yard of farmhouse located directly on Rt. 12E
 Position 6 – Hell St.
Setting: Open fields, outside farm buildings
 Measurement Quantities
„ Principal Measure: the L90 statistical level
„ Secondary Measure: the Average (Leq) Level
90
PARTICULARLY LOUD
VEHICLE PASSING TRAFFIC, TYPICAL
80 Leq ,TRUE AVERAGE

L10
Sound Pressure Level, dBA

70

60

50

40 1/2-MINUTE
L90, RESIDUAL LEVEL
LULL IN
TRAFFIC
30 1-MINUTE LULL IN TRAFFIC

20
3:05 PM

3:10 PM

3:15 PM

3:20 PM
Time (min), 15 minute Sample
 Sound Pressure Level, dBA

0
10
20
30
40
50
60
70
80
12/14/07 12:00
12/15/07 0:00
12/15/07 12:00
12/16/07 0:00
12/16/07 12:00
12/17/07 0:00
12/17/07 12:00
12/18/07 0:00
12/18/07 12:00
12/19/07 0:00
12/19/07 12:00
12/20/07 0:00
12/20/07 12:00
12/21/07 0:00
12/21/07 12:00
12/22/07 0:00
12/22/07 12:00
12/23/07 0:00
12/23/07 12:00
12/24/07 0:00
12/24/07 12:00
12/25/07 0:00
12/25/07 12:00
12/26/07 0:00

Date and Time

12/26/07 12:00
Wintertime Conditions

12/27/07 0:00
12/27/07 12:00
12/28/07 0:00
12/28/07 12:00
12/29/07 0:00
12/29/07 12:00
12/30/07 0:00
12/30/07 12:00
12/31/07 0:00
12/31/07 12:00
Residual, L90(10 min) Sound Levels vs Time at All Positions (Except 6)

1/1/08 0:00
1/1/08 12:00
1/2/08 0:00
Pos. 5 Rt. 12E

1/2/08 12:00
Pos. 1 Co. Rd. 9

Pos. 3 River Bank

1/3/08 0:00
Pos. 4 Branche Rd.
Pos. 2 Millen Bay Rd.

1/3/08 12:00
1/4/08 0:00
1/4/08 12:00
Overall L90 Survey Results - Winter
 Sound Pressure Level, dBA

0
10
20
30
40
50
60
70
80
12/14/07 12:00
12/15/07 0:00
12/15/07 12:00
12/16/07 0:00
12/16/07 12:00
12/17/07 0:00
12/17/07 12:00
12/18/07 0:00
12/18/07 12:00
12/19/07 0:00
12/19/07 12:00
12/20/07 0:00
12/20/07 12:00
12/21/07 0:00
12/21/07 12:00
12/22/07 0:00
12/22/07 12:00
12/23/07 0:00
12/23/07 12:00
12/24/07 0:00
12/24/07 12:00
12/25/07 0:00
12/25/07 12:00
12/26/07 0:00

Date and Time

12/26/07 12:00
Wintertime Conditions

12/27/07 0:00
12/27/07 12:00
12/28/07 0:00
12/28/07 12:00
12/29/07 0:00
12/29/07 12:00
12/30/07 0:00
12/30/07 12:00
12/31/07 0:00
12/31/07 12:00
1/1/08 0:00
Residual, L90(10 min) Sound Levels vs Time at the Principal Design Positions

1/1/08 12:00
Pos. 5 Rt. 12E

1/2/08 0:00
Pos. 1 Co. Rd. 9

Pos. 3 River Bank

1/2/08 12:00
Pos. 2 Millen Bay Rd.

1/3/08 0:00
L90 Results Omitting Position 4

1/3/08 12:00
1/4/08 0:00
1/4/08 12:00
 Sound Pressure Level, dBA

0
10
20
30
40
50
60
70
80
12/14/07 12:00
12/15/07 0:00
12/15/07 12:00
12/16/07 0:00
12/16/07 12:00
12/17/07 0:00
12/17/07 12:00
12/18/07 0:00
12/18/07 12:00
12/19/07 0:00
12/19/07 12:00
12/20/07 0:00
12/20/07 12:00
12/21/07 0:00
12/21/07 12:00
12/22/07 0:00
12/22/07 12:00
12/23/07 0:00
12/23/07 12:00
12/24/07 0:00
12/24/07 12:00
12/25/07 0:00
12/25/07 12:00
12/26/07 0:00

Date and Time

12/26/07 12:00
12/27/07 0:00
12/27/07 12:00
12/28/07 0:00
12/28/07 12:00
12/29/07 0:00
12/29/07 12:00
12/30/07 0:00
12/30/07 12:00
Design Site-wide L90

12/31/07 0:00
12/31/07 12:00
Site-wide Residual (L90) Sound Level vs Time - Wintertime Conditions
Design L90 Background Level (Average of Principal Design Positions)

1/1/08 0:00
1/1/08 12:00
1/2/08 0:00
1/2/08 12:00
1/3/08 0:00
1/3/08 12:00
1/4/08 0:00
1/4/08 12:00
 Wind Speed at 10 m agl., m/s

10
12
14
16
18
20

0
2
4
6
8
12/14/07 12:00
12/15/07 0:00
12/15/07 12:00
12/16/07 0:00
12/16/07 12:00
12/17/07 0:00
12/17/07 12:00
12/18/07 0:00
12/18/07 12:00
12/19/07 0:00
12/19/07 12:00
12/20/07 0:00
12/20/07 12:00
12/21/07 0:00
12/21/07 12:00
12/22/07 0:00
12/22/07 12:00
12/23/07 0:00
12/23/07 12:00
12/24/07 0:00
12/24/07 12:00
12/25/07 0:00
12/25/07 12:00
12/26/07 0:00

Date and Time

12/26/07 12:00
12/27/07 0:00
Wintertime Conditions

12/27/07 12:00
12/28/07 0:00
12/28/07 12:00
12/29/07 0:00
12/29/07 12:00
12/30/07 0:00
12/30/07 12:00
12/31/07 0:00
Wind Speed at 10 m

12/31/07 12:00
Design L90 Sound Level

1/1/08 0:00
1/1/08 12:00
Design L90 Background Sound Level vs. Normalized Wind Speed

1/2/08 0:00
1/2/08 12:00
1/3/08 0:00
Sound Level vs. Wind Speed

1/3/08 12:00
1/4/08 0:00
1/4/08 12:00
0
10
20
30
40
50
60

Sound Pressure Level, dBA

 Wind Speed Normalization
„ Wind speed measured at
elevation of turbine rotor by
met mast anemometers (40 –
80 m)
„ Wind speed converted to a
standard elevation of 10 m in
accordance with IEC 61400-
11
„ Wind that the turbines will
experience is correlated to
the sound level measured
at ground level
 Sound Level as a
Function of Wind Speed - Winter
Regression Analysis of Site-wide L90 Sound Level vs. Normalized Wind Speed
Wintertime Conditions

60

55

50

45
Sound Pressure Level, dBA

40

35
y = 2.6355x + 20.776
30 R2 = 0.6451

25

20

15

10

0
0 1 2 3 4 5 6 7 8 9 10 11 12
Wind Speed at 10 m above Ground Level, m/s
 Sound Level as a
Function of Wind Speed - Summer
Regression Analysis of Site-wide L90 Sound Level vs. Normalized Wind Speed
Summertime Conditions

60

55

50

45
Sound Pressure Level, dBA

40

35

30
y = 0.7185x + 40.085
25
R2 = 0.0647

20

15

10

0
0 1 2 3 4 5 6 7 8 9 10 11 12
Wind Speed at 10 m above Ground Level, m/s
 Overall Results
Sound Levels by Wind Speed
60
50
Summer Leq
40
Sound
Summer L90
Pressure 30
Level, dBA
20 Winter Leq

10 Winter L90
0
3 4 5 6 7 8 9 10
Wind Speed at 10 m, m/s
 Critical Design Conditions
„ Determine the wind speed where the background level is
lowest relative to the turbine sound power level

Wind Speed, m/s 6 7 8 9 10

Winter L90, dBA 37 39 42 44 47
Turbine Sound
Power Level, 101.7 102.5 102.2 101.8 101.5
dBA re 1 pW
Differential, dB 65 63 60 58 54
 NYSDEC 6 dBA Threshold
„ Design Background Level: L90 Wintertime during
6 m/s wind conditions: 37 dBA
„ Assume 6 dBA increase is cumulative
„ Design threshold then 5 dBA above background at
42 dBA
„ 37 dBA background + 42 dBA Project = 43 dBA,
or 6 dBA above the original level
 Project Sound Modeling
„ Predicts the mean or most common project sound
level at any point
„ Plotted as sound contour maps over the project
area
„ Calculations based on ISO standard 9613-11
„ Turbine sound power level based on field tests per
IEC 61400
„ Downwind conditions assumed in all directions
„ Moderately absorptive ground assumed (Ag=0.5)
Model Verification – Example 1
„ Typical comparison between modeled sound levels at various
wind speeds and actual measured project sound levels
„ New York Project, General Electric Turbines
Regression Analysis of Measured Project-Only Sound Level vs. Normalized Wind Speed
Position 9

65

60

55
L90(10 min) Sound Pressure Level, dBA

50

45

40

35

30
3 2
y = -0.1481x + 2.012x - 5.4756x + 35.702
25 2
R = 0.4643
20

15
Turbine Not Operating Below 2.5 m/s Model Prediction at Key Wind Speeds
10

0
2 3 4 5 6 7 8
Wind Speed at 10 m above Ground Level, m/s
Model Verification - Example 2
„ Typical comparison between modeled sound levels at various
wind speeds and actual measured project sound levels
„ Wisconsin Project, Vestas Turbines
Regression Analysis of Measured Project-Only Sound Level vs. Normalized Wind Speed
Position 6

70

65

60

55
L90(10 min) Sound Pressure Level, dBA

50

45

40

35
y = 0.0541x 2 + 1.2993x + 36.287
30
R2 = 0.5292
25
Model Prediction at Key Wind Speeds
20

15

10

0
2 3 4 5 6 7 8 9 10 11
Wind Speed at 10 m above Ground Level, m/s
Model Verification - Example 3
„ Comparison between modeled sound level at 7 m/s and actual
measured project sound levels at all wind speeds
„ Texas Project, Gamesa Turbines
Regression Analysis of L90(10 min) Sound Level at Newman Ranch
vs. Normalized Wind Speed at 10 m

70
Approximate Turbine Cut-in Point
65

60

55
L90(10 min) Sound Pressure Level, dBA

Typical Project Sound Level Approx. 43 dBA

50

45

40

35

30

25 Model Prediction for 7 m/s

Wind Conditions: 43.9 dBA
20 Natural Environmental Sound
Level during Calm Conditions Sound Levels with Project Operating
15

10

0
0 1 2 3 4 5 6 7 8 9 10 11 12
Wind Speed at 10 m above Ground Level, m/s
 Model Results for St. Lawrence –
Critical Design Conditions (6 m/s Wind)
 Model Results for St. Lawrence –
At Maximum Turbine Sound Level (7 m/s Wind)
 Model Results
„ Mean project sound level below NYSDEC 6
dBA increase threshold at all residences

„ Note, however, that the project will not be

inaudible beyond the 6 dBA increase threshold
„ Audibility likely much of the time out to roughly
2000 ft.
„ Sound level and character will vary with wind
and weather conditions
 Actual Reaction to Operating Projects
„ Operational sound surveys
conducted at 8 recently
completed projects
„ 5 are similar in nature to St.
Lawrence
„ Sound levels measured for 2
weeks at all residences where
concerns or complaints about
noise have been received and
at a number of other homes
where modeling predicts
relatively high sound levels
 Observed Complaints at
Recently Tested Projects
Number of Complaints as a
Total Function of Project Total Number Percentage
Households Sound Level, dBA (1)
Project of Relative
in the Site Area
< 40 40 - 44 ≥ 45 Complaints to Total
(within 2000’)

Site A 107 0 2 1 3 3%
Site B 147 0 3 3 6 4%
Site C 151 0 3 0 3 2%
Site D 268 0 2 4 6 (2) 2%
Site E 91 1 1 4 6 7%
(3)

Overall Average: 4%
(1) As-measured long-term, mean sound levels
(2) There were only 3 reported complaints at this site but others may have existed that we were not
made aware of; hence a total number of 6 were assumed
(3) Most noise issues related to mechanical nacelle noise unique to the turbine model at this site
 Low Frequency Noise
„ Wind turbine sound levels below about 100 Hz
inconsequential and similar to the sound levels
naturally present in a rural area
„ Mistaken belief that wind turbines produce high
levels of low frequency noise apparently stems
primarily from measurement error
„ Wind-induced false signal noise is recorded
whenever a measurement is taken under windy
conditions
 Wind-Induced Measurement Error
„ Wind blowing over a microphone creates false
signal noise in the low end of the frequency
spectrum that is often mistaken for actual
turbine noise
„ Low frequency sound levels in a windy
environment will be high whether a turbine is
present – or not
Low Frequency Microphone Distortion Example
Low Frequency Microphone Distortion Example
Low Frequency Microphone Distortion Example
Wind Tunnel Testing of Windscreen
Performance and Wind-induced
Measurement Error
 Windscreens
as Installed in the Wind Tunnel
On-Off Measurements of a Typical
Turbine at Maple Ridge
 Frequency Spectra 1200 ft. from Vestas V82 Turbine with Unit On and Off
Compared to Sound Level Inside Typical Car

100 Unit Off

Unit Off
90 Unit Off
Unit On
80 Unit On
Unit On
70 Unit On
Sound Pressure Level, dB

Inside Car at 60 mph

60

50

40

30

20

10

0
12.5 Hz
16 Hz
20 Hz
25 Hz
31.5 Hz
40 Hz
50 Hz
63 Hz
80 Hz
100 Hz
125 Hz
160 Hz
200 Hz
250 Hz
315 Hz
400 Hz
500 Hz
630 Hz
800 Hz
1 kHz
1.25 kHz
1.6 kHz
2 kHz
2.5 kHz
3.15 kHz
4 kHz
5 kHz
6.3 kHz
8 kHz
10 kHz
12.5 kHz

dBA

dBC
1/3 Octave Band Center Frequency, Hz
 Health Effects
„ The issue of possible
health impacts from wind
turbines was recently
reviewed by a panel of
independent doctors
 Health Study Conclusions
„ “There is nothing unique about the sounds and
vibrations emitted by wind turbines”
„ “The Body of accumulated knowledge about
sound and health is substantial”
„ “The body of accumulated knowledge provides
no evidence that the audible or subaudible
sounds emitted by wind turbines have any direct
adverse physiological effects”
 Health Study Conclusions
„ “Sound from wind turbines does not pose a risk
of hearing loss or any other adverse health
effects on humans”
„ “Subaudible, low frequency sound and
infrasound from wind turbines do not present a
risk to human health”
„ “Some people may be annoyed at the presence
of sound from wind turbines. Annoyance is not
a pathological entity”
 Health Study Conclusions
„ “A major cause of concern about wind turbine
sound is its fluctuating nature. Some may find
this annoying, a reaction that depends primarily
on personal characteristics as opposed to the
intensity of the sound”
 General Summary
„ The noise assessment study for St. Lawrence was
based on the near-minimum (L90) background
sound level conservatively measured under
wintertime conditions
„ Sound levels measured at ground level correlated
to wind speed measured by met mast at turbine
rotor elevation
„ Modeling indicates that the project will comply
with the NYSDEC guidelines, which recommend
that a new project not increase the overall sound
level by more than 6 dBA
 General Summary
„ In absolute terms the mean sound levels from
the project are expected to be 42 dBA or, in
most cases, less at all homes in the project area
„ Most other completed projects in NY and
elsewhere have significantly higher mean sound
levels, often in the 45 to 50 dBA range
 General Summary
„ Although the impact is expected to be relatively
low, the project will not be inaudible
„ There is no reason for any concerns about low
frequency or infrasonic noise
„ There is no reason to believe that any significant
adverse health impact will result from the
project
 St. Lawrence Windpower, LLC
P. O. Box 660 • 122 South Point Street
Cape Vincent, New York 13618
[email protected]
(315) 654-2210

June 28, 2010

Mr. Kris D. Dimmick

Bernier, Carr & Associates, P.C.
327 Mullin Street
Watertown, NY 13601

Dear Mr. Dimmick:

St. Lawrence Windpower, LLC (SLW) is in receipt of your letter dated May 20, 2010
containing comments on the Engineering Concept Report for the St. Lawrence Wind
Farm 115 kV transmission line dated March 18, 2010. We offer the following response
to the comments:

1. The Engineering Concept Report represents a preliminary design for the

transmission line. The scope and format of the report was created in
collaboration with the Development Authority of the North Country (DANC), the
owner and operator of the Western Jefferson County Regional Waterline. The
purpose of the Engineering Concept Report was to address, preliminarily, safety
and operational concerns regarding the compatibility of the proposed
transmission line with the existing waterline. The enclosed letter from DANC
dated June 21, 2010 indicates that the proposed conceptual design meets the
minimum requirements specified by DANC. The letter outlines DANC’s
additional requirements that will need to be met by SLW prior to commencement
of construction. Prior to commencing construction, SLW will obtain DANC’s
approval of the final design and construction plan for the transmission line and
ensure that all applicable design and safety standards are met.
2. Comment about using stationing that corresponds to the stationing used along
the waterline - If SLW is provided the appropriate station reference information, it
will include it in the final engineering drawings. Cross street names will be added
to the final engineering drawings.
3. Comments about the location of the waterline relative to the embankment and
the horizontal separation between the waterline and transmission pole locations
– See 1 above. Prior to commencing construction, SLW will obtain DANC’s
approval of the final design and construction plan for the transmission line,
including the horizontal separation to be used between the waterline and
transmission line components.
 4. Comment on soil overloading from heavy equipment – See 1 above. SLW’s
engineer created a construction mitigation summary but DANC said that it was
not necessary to include it in the Engineering Concept Report. Prior to
commencement of construction, SLW will create a response plan that is
approved by DANC and will be utilized in the unlikely event that there is a
disturbance to the waterline during construction or maintenance of the
transmission line.
5. Comment about transmission system being outside of the original railroad right of
way - Required easements outside of the DANC easement area are being
obtained and will be in place prior to the commencement of construction.

We trust the above responses are sufficient to satisfy the requirements of SEQR review.
If you have questions or require additional information, please let me know.

Sincerely,

St. Lawrence Windpower, LLC

Tim Conboy
Project Development Manager

Enclosure: Letter from DANC dated June 21, 2010

Copy to: Mr. Rich Edsall, Planning Board Chairman, Town of Cape Vincent
Mr. Todd Mathes – Town of Cape Vincent Planning Board Attorney
Blayne Gunderman and Jason Donajkowski - SLW
Rich Cogen – Attorney for SLW
 St. Lawrence Windpower, LLC
P.O. Box 660 • 122 South Point Street
Cape Vincent, New York 13618
Tel: 315.654.2210
[email protected]

July 7, 2010

Mr. Kris D. Dimmick

Bernier, Carr & Associates, P.C.
327 Mullin Street
Watertown, NY 13601

Dear Mr. Dimmick:

St. Lawrence Windpower, LLC (SLW) is in receipt of your letter dated June 28, 2010
containing comments on the Route Evaluation Study for the St. Lawrence Wind Farm.
We offer the following response to the comments:

1. Unless the landowner and responsible transportation agency prefers

otherwise, intersections will be restored to their original condition upon
completion of construction. This has been specified in Section 2.2.7 of the
FEIS.
2. Existing conditions of pavement systems for areas which are required to be
modified have been addressed in the Transportation/Traffic section. In
addition, an in depth analysis of existing road conditions and an assessment
of impacts to roads are provided in the Route Evaluation Study (Appendix C-5
of the FEIS). This study also includes a photographic inventory of existing
road conditions which is presented in Appendices A and C of the report.
During the site plan review process, road use agreements with the
responsible transportation agencies will be developed. These agreements
will address the existing condition of public roads and restoration following
any damages that occur during construction and operation of the Project.

We trust that these responses are sufficient to satisfy requirements of SEQR review. If
you have questions or require additional information, please let me know.

Sincerely,

St. Lawrence Windpower, LLC

Tim Conboy
Project Development Manager

Copy to: Mr. Rich Edsall, Planning Board Chairman, Town of Cape Vincent
Mr. Todd Mathes – Town of Cape Vincent Planning Board Attorney
Blayne Gunderman - SLW
Rich Cogen – Attorney for SLW
File
 St. Lawrence Windpower, LLC
P.O. Box 660 • 122 South Point Street
Cape Vincent, New York 13618
Tel: 315.654.2210
[email protected]

July 8, 2010

Mr. Kris D. Dimmick

Bernier, Carr & Associates, P.C.
327 Mullin Street
Watertown, NY 13601

Dear Mr. Dimmick:

St. Lawrence Windpower, LLC (SLW) is in receipt of your letter dated June 28, 2010
containing comments on the Construction Environmental Monitoring (CEM) Outline for
the St. Lawrence Wind Farm. We offer the following response to the comments:

1. The CEM Plan will be utilized specifically for the construction phase (and brief
period prior to, and after, construction.) A site-specific Site Management Plan
will be developed for use during long-term operations.
2. The construction management organizational chart was added to the revised
outline. It will be in Section 2.4.
3. We agree – clear definition of responsibilities and the chain of command is
essential to meet the high expectations SLW has for the Project. We have added
reference to this in the revised outline. It will also be in Section 2.4.
4. As part of the chain of command, this will be defined and described in Section
2.4, as stated above.
5. Environmental monitoring locations and types will be determined by the
construction schedule. SLW will require a well laid out construction schedule
prior to commencement of construction. Environmental monitors will be brought
in for specific tasks (i.e. avian experts during construction in sensitive areas
during the breeding season.)
6. Diesel emissions compliance was added to the outline. It will be in Section 5.5.1.
7. Staffing levels will be determined once permits are issued and SLW has a better
idea of what will be required. SLW will hire a sufficient number of, and relevant
expertise level of, staff in order to fulfill its commitments.
8. SLW does not expect to use blasting as a method of construction. If, for some
reason, blasting is required SLW will include monitoring of blast locations to
ensure environmental and safety compliance.
9. Reporting was included in Section 9.5 of the outline; however, we have revised
that section to better illustrate our intentions. In addition, Enforcement and Non-
compliance Penalties now has its own section; Section 9.8.

We trust that these responses are sufficient to satisfy requirements of SEQR review. If
you have questions or require additional information, please let me know.
Sincerely,

St. Lawrence Windpower, LLC

Tim Conboy
Project Development Manager

Enclosure: Revised Construction Environmental Monitoring Implementation Plan

Table of Contents (“outline”)

Copy to: Mr. Rich Edsall, Planning Board Chairman, Town of Cape Vincent
Mr. Todd Mathes – Town of Cape Vincent Planning Board Attorney
Blayne Gunderman - SLW
Rich Cogen – Attorney for SLW
File
 CONSTRUCTION ENVIRONMENTAL MONITORING
IMPLEMENTATION PLAN
TABLE OF CONTENTS

1.0 INTRODUCTION
1.1 Regulatory Framework and Applicable Permits
1.1.1 Township and County Permits
1.1.2 New York State Environmental Quality Review Act (SEQRA) Review and
Findings
1.1.3 Wetlands Permits
1.1.3.1 State
1.1.3.2 U.S. Army Corps of Engineers
1.1.3.2.1 Indiana Bat Incidental Take
1.1.4 State Pollutant Discharge Elimination System (SPDES) General Permit
1.1.5 New York State Department of Transportation Highway Work Permits
1.1.6 NYSDEC Article 11 Permit – Incidental Take

2.0 ROLES AND RESPONSIBILITIES DURING CONSTRUCTION

2.1 St. Lawrence Windpower Project
2.1.1 St. Lawrence Wind Project Management
2.1.2 St. Lawrence Wind Environmental Compliance Team
2.2 Contractors
2.3 Agency Monitors
2.4 Construction Organizational Chart and Chain of Command
2.5 Daily Communication and Briefings

3.0 CONTACT LIST

4.0 PRE-CONSTRUCTION COORDINATION

4.1 Environmental Training
4.2 Identification of Construction Work Sites
4.3 Pre-construction Walkover
4.4 Permits, Programs and Plans
4.5 Sediment and Erosion Control
4.6 Survey of Wetland Contours
4.7 Flagging, Fencing, and Signage
4.8 Vehicular Access & Public Road Considerations
4.9 Construction Vehicles and Equipment

5.0 CONSTRUCTION OPERATIONS

5.1 Site Preparation
5.1.1 Sediment and Erosion Control Measures
5.1.2 Clearing and Grading
5.1.3 Construction in Agricultural Areas
5.2 Construction of Project Facilities (without stream crossings)
5.2.1 Staging Areas
5.2.2 Access Roads
5.2.3 Turbine Foundations and Erection
5.2.4 Buried Interconnect
5.2.5 Overhead Electric
5.2.6 Metrological Towers
5.3 Construction in Wetland Areas and Streams
5.4 Wetland Mitigation
5.5 Discharge of Pollutants
5.5.1 Diesel Emissions
 5.6 Dust Control
5.7 Archaeological Resources
5.7.1 Unanticipated Discoveries
5.8 Invasive Species Management
5.9 Wildlife
5.9.1 Blanding’s Turtle
5.9.2 Grassland Birds – Breeding Birds
5.9.3 Short-eared Owl
5.9.4 Indiana bat
5.10 Rare Plants

6.0 POST-CONSTRUCTION ACTIVITIES

6.1 General
6.2 Restoration Punch List
6.3 Transition to Operations – Site Management Plan

7.0 PROJECT SAFETY

7.1 Contractor Safety Plans
7.2 Acciona Policy on Safety
7.3 Public Road Safety

8.0 INDUSTRIAL WASTES AND TOXIC SUBSTANCES

8.1 Human Sanitation
8.2 Industrial Sanitation
8.3 Toxic and Hazardous Substances

9.0 ENVIRONMENTAL COMPLIANCE AND PROJECT CHANGES

9.1 Compliance Levels and Field Protocols
9.1.1 Monitoring Criteria
9.1.2 Compliance Approach
9.1.3 Compliance Levels
9.2 Permits, Programs and Plans
9.3 Training
9.4 Communications
9.5 Reporting
9.5.1 Daily Reporting
9.5.2 Weekly Reporting
9.5.2.1 SWPPP Reporting
9.5.3 Monthly Compliance Reports
9.5.4 Emergency Reporting
9.6 Stop Work Orders
9.7 Changes to the Project Plan
9.8 Enforcement and Non-Compliance Penalties
 St. Lawrence Windpower, LLC
P.O. Box 660 • 122 South Point Street
Cape Vincent, New York 13618
Tel: 315.654.2210
[email protected]

July 14, 2010

Mr. Kris D. Dimmick

Bernier, Carr & Associates, P.C.
327 Mullin Street
Watertown, NY 13601

Dear Mr. Dimmick:

St. Lawrence Windpower, LLC (SLW) is in receipt of your letter dated June 29, 2010
containing comments on the Residential Well Study and Mitigation Plan for the St.
Lawrence Wind Farm. We offer the following response to the comments:

1. The plan has been revised to indicate that SLW will pay mitigation expenses for
Cape Vincent Fire Department providing potable water and a water storage tank,
until the conclusion of all studies. However, the mitigation option of construction
of a connection to a municipal water line has been deleted, because if SLW is
ultimately proven innocent of well damage, the landowner would have to pay
what would most likely be a prohibitive cost. The revised plan is enclosed herein.
2. Comment noted.
3. We agree. Testing will be performed by an impartial third party laboratory.

We trust that these responses are sufficient to satisfy requirements of SEQR review. If
you have questions or require additional information, please let me know.

Sincerely,

St. Lawrence Windpower, LLC

Tim Conboy
Project Development Manager

Enclosure

Copy to: Mr. Rich Edsall, Planning Board Chairman, Town of Cape Vincent
Mr. Todd Mathes – Town of Cape Vincent Planning Board Attorney
Blayne Gunderman - SLW
Rich Cogen – Attorney for SLW
File
 ST. LAWRENCE WINDPOWER, LLC
RESIDENTIAL WELL STUDIES AND MITIGATION
July 2010

BACKGROUND
Construction activities can generate ground-transmitted vibration forces that may result in
ground disturbance and can potentially affect existing features proximal to the activity.
These generated vibrations attenuate over distance from the source. The magnitude of
the vibration and the attenuation rate are related to the construction method used for
excavation (e.g., mechanical, blasting), type of construction equipment (e.g., hydraulic
excavators, front end loaders), and conductivity of the surface and subsurface substrates
(e.g., sands, clays, frozen soils, bedrock). In determining the distance from turbines for
pre-construction surveys of private water supply wells, it was assumed that standard
excavation equipment would be used and no blasting would be required. Using such
equipment and techniques, vibration effects typically are below levels of perception at
distances of 500 feet from the source1. Even considering the use of controlled blasting,
construction vibrations should be well below the threshold for residential damage.

PURPOSE
In recent years, new municipal water lines have been constructed in the Town of Cape
Vincent which make water from the Village and Town of Cape Vincent available to
residents in some parts of the Town, Construction of these new supply lines has reduced
reliance on old residential water supply wells; however, many residential wells still exist.
In response to public concerns with respect to potential damage to residential water
supply wells during the construction phase of the St. Lawrence Wind Project, SLW
performed a study to identify existing private residential water supply wells near the site
of its proposed wind energy project. SLW mailed well surveys were to all project
landowners. On the well surveys, the project landowners were asked to declare
knowledge of any wells within 500 feet of proposed turbine locations. All surveys were

1
Hal Amick and Michael Gendreau, 2000, Construction Vibrations and Their Impact on Vibration-
Sensitive Facilities, ASCE Construction Congress 6.

1
collected, and the GPS coordinates were recorded for all wells described in the survey as
existing within 500 feet of proposed turbine locations. (See Appendix A).

PRE-CONTRUCTION STUDY
Prior to commencing construction of its wind energy project, SLW will conduct a
pre-construction study to characterize existing conditions of residential potable water
wells within approximately 500 feet of the final proposed turbine locations.. The pre-
construction survey will document well depth, flow rates, water quality, and connectivity
through karst features.

CONSTRUCTION MITIGATION AND POST-CONSTRUCTION STUDIES

In the event that the owner of a residential potable water well located within 500 feet of a
turbine location believes that his or her well has been adversely affected by construction
of the SLW project:

1. The well owner must contact a representative of St. Lawrence Windpower (SLW)
to document the location of the well and verify its inoperability. SLW phone
contact: 315-654-2210.
2. Upon verification of the well’s inoperability and its proximity within 500 feet of a
turbine location, as interim mitigation, a SLW representative will assist the well
owner in one of the following ways:
„ Request the Cape Vincent Fire Department to provide potable water within a
reasonable time frame, with SLW paying all expenses;
„ Provide water storage tank that accommodates the well owner, within a
reasonable time frame. McCabes Supply, Inc. (20707 State Route 232,
Watertown, New York; Phone: 315-788-5587) can deliver water storage tanks
up to 2,500 gallons, with SLW paying all expenses;; and/or
3 Following the provision of interim mitigation, the following post-construction
study process shall be implemented for each well that is the subject of interim
mitigation.

2
SLW will conduct an initial post-construction well study for each such well. Each post-
construction study will initially be a desktop study assessing distance of the well to the
turbine(s) location, depth of well in relationship to the turbine foundation(s), the pre-
construction condition of the well, and causative factors leading to reported damage.

If, based upon the initial post-construction study, SLW determines that project
construction activities may have had an impact on the potable well that is the subject of
the study, a third-party certified laboratory will conduct a subsequent post-construction
study to address, as appropriate, :
a) Flow rate or yield from the well;
b) Water quality of the water produced by the well. Water quality testing may
include, as appropriate, data collected from a hand held water quality meter (e.g.,
pH, dissolved oxygen, conductivity, salinity, total dissolved solids (TDS), specific
gravity, temperature, turbidity, siltation); and chemical anlayses for total hardness
or concentration of calcium and magnesium.

Based upon a comparision of pre- and post-construction conditions, SLW will assess
whether its construction activities caused any adverse impacts to the subject potable
water well.

Where the post-construction study indicates that a well’s characteristics have been
adversely affected, SLW will conduct subsequent studies to determine the cause for the
change. Subsequent studies may include an evaluation of potential karst conduits (i.e.,
fractures) underlying a specific turbine, or other project component, and their
connectivity to a potable well using groundwater tracers (commonly fluorescent dyes).
Dye tracer tests can be either qualitative or quantitative. Qualitative tests are the simplest,
most common, but are less informative. They are designed to answer the basic question
of connection. Quantiative studies are more complex and labor intensive, but provide a
more accurate groundwater velocity. For SLW’s purposes, initially a qualitative study
would be performed.

3
Should the subsequent studies determine that the Project construction did not adversely
affect a residential potable water well, the impacted landowner will reimburse SLW for
all expenses. Should the subsequent studies determine that Project construction did
indisputably adversely affect a residential potable water well, SLW will provide
mitigation in one of the following ways:
„ A new well will be provided at no expense to the property owner; or
„ If a new well cannot be provided, a connection with municipal water will be
provided; this installation will be funded by SLW.

4
 APPENDIX A

Landowner Wells within 500 ft GPS GPS POSITION

SYSTEM
Darrel and Margaret Aubertine No Known Wells
Terry and Linda Aubertine No Known Wells
Wesley Bourcy No Known Wells
Rockne and Beverly Burns No Known Wells
Dennis Docteur No Known Wells
Donald and Wava Docteur NAD83 X: 0401838
Y: 4890951

David Fralick NAD83 X: 0393802

Y: 4884208

X: 0393821
Y: 4884218

X: 0393835
Y: 4884193

X: 0393999
Y: 4884258

Frank Giaquinto NAD83 X: 0399431

Y: 4889323

X: 0399386
Y: 4888944

X: 0399210
Y: 4889017

Chris Henchy No Known Wells

Ron Jacobs No Known Wells
Michael and Melinda Kieff NAD83 X: 0394173
Y: 4886547
Richard and Sheila Lawrence NAD83 X: 0400275
Y: 4889238

X: 0399595
Y: 4888894
Maloneys No Known Wells
Donald Mason NAD83 X: 0398248
Y: 4886942

5
Landowner Wells within 500 ft GPS GPS POSITION
SYSTEM
Ennis and Marilyn Mason NAD83 X: 0400951
Y: 4889190

X: 0402464
Y: 4889305
Marty Mason No Known Wells
Paul and Elaine Mason NAD83 X: 0402785.
Y: 4893502

X: 0402531
Y: 4893260
Pat Meaney and Traci Mason NAD83 X: 0400522
Y: 4890623

Wallace McDowell NAD83 X: 0404142

Y: 4889464
Jarrod & Jarvis Radley No Known Wells
Jim and Patti Radley NAD83 X: 0399468
Y: 4889940
Andrew VanVliet NAD83 X: 0400531
Y: 4890199
Don Votra NAD83 X: 0395499
Y: 4886547
White Farms No Known Wells
Alan Wood NAD83 X: 0405072
Y: 4893074
Wood Farms No Known Wells

6
 St. Lawrence Windpower, LLC
P.O. Box 660 • 122 South Point Street
Cape Vincent, New York 13618
Tel: 315.654.2210
[email protected]

July 21, 2010

Mr. Kris D. Dimmick

Bernier, Carr & Associates, P.C.
327 Mullin Street
Watertown, NY 13601

Dear Mr. Dimmick:

St. Lawrence Windpower, LLC (SLW) is in receipt of your letter dated July 7, 2010
containing comments on Section 2.0 of the St. Lawrence Windpower Project Final
Environmental Impact Statement (FEIS). We offer the following response to the
comments:

2.1 Wording will be changed from “required setbacks” to indicate

compliance with the Planning Board’s setback criteria stipulated in their
June 11, 2007 letter to SLW.

2.2.1.1 The text will be changed to indicate that SLW has conducted a pre-
construction survey of residential wells, and that SLW will conduct
additional pre and post construction studies of identified wells to
determine individual well characteristics.

2.2.1.2 SLW will develop a Project Blasting Plan prior to construction. This
plan will include the use of controlled blasting to assure that
construction vibrations would be maintained below the threshold for
well and residential damage. Since site-specific geologic and
hydrogeologic investigation has not been completed in the Project
Area, SLW has committed to revisit distances for the well survey radius
as part of these studies, and the distance may be adjusted either
nearer or further from the potential source. This plan will also include
conventional seismic monitoring at wells or homes within the identified
potential impact zone to mitigate potential seismic impacts associated
with blasting.

2.2.3 In a letter dated June 21, 2010, SLW responded to the comments
regarding potential noise impacts referred to in this comment.
Subsequent to receipt of your July 7, 2010 letter, SLW also received a
copy of a July 15, 2010 letter from Cavanaugh, Tocci Associates which
responds to SLW’s June 21, 2010 letter. That letter suggests that the
Planning Board consider a complaint response process to address
 potential noise issues. SLW has committed to such a process. The
complaint resolution plan is included as Appendix C 11.0 of the FEIS.

2.2.5.3 The last bullet will be revised to indicate that reasonable efforts will be
made to repair a breach in the waterline within 8-12 hours of notice to
SLW. An additional bullet will be added indicating the a plan to provide
water in the event of a water main breach will be developed and
approved by DANC and the New York State Department of Health
prior to start of construction. This plan will also indentify a contractor
responsible for implementing the approved plan.

2.2.7.3 Road use agreements will be developed with the transportation

departments responsible for public roads during the site plan review
process. These agreements will include adequate detail for evaluating
the pre-construction condition of existing roads, standards for required
improvements and restoration, and a mechanism for establishing that
restoration has been satisfactorily completed to the agreed upon
standards.

We trust that these responses are sufficient to satisfy the requirements of SEQR review
and enable prompt acceptance of the FEIS. If you have questions or require additional
information, please let me know.

Sincerely,

St. Lawrence Windpower, LLC

Tim Conboy
Project Development Manager

Copy to: Mr. Rich Edsall, Planning Board Chairman, Town of Cape Vincent
Mr. Todd Mathes – Town of Cape Vincent Planning Board Attorney
Blayne Gunderman - SLW
Rich Cogen – Attorney for SLW
File
CAVANAUGH TOCCI ASSOCIATES, INCORPORATED
327 F BOSTON POST ROAD, SUDBURY, MA 01776-3027 • TEL: (978) 443-7871 • FAX: (978) 443-7873 • E-MAIL: [email protected]

SENIOR PRINCIPALS SENIOR AND STAFF CONSULTANTS

WILLIAM J. CAVANAUGH, FASA, Emeritus ALEXANDER G. BAGNALL
GREGORY C. TOCCI, PE, FASA, PRESIDENT ANDREW C. CARBALLEIRA
WILLIAM J. ELLIOT, LEED AP
PRINCIPALS AARON M. FARBO, LEED AP
DOUGLAS H. BELL JOHN T. FOULKES
LINCOLN B. BERRY MARK V. GIGLIO
TIMOTHY J. FOULKES, FASA, INCE, Bd. Cert. BRION G. KONING
MATTHEW J. MOORE, CTS MICHAEL D. MAYNARD, CTS
CHRISTOPHER A. STORCH
ADMINISTRATOR
DONNA L. RAFUS MARKETING MANAGER
PATRICIA A. CASASANTO

ASSOCIATED CONSULTANTS
NICHOLAS BROWSE, SMPTE
STEWART RANDALL, CTS-D
MARTIN CALVERLEY, CTS

July 15, 2010

Mr. Kris D. Dimmick, P.E.

Bernier Carr & Associates, P.C
327 Mullin Street
Watertown, NY 13601

Subject: Review of Reponses to Cavanaugh Tocci/Bernier Carr Comments Letter, issued June 21, 2010
St. Lawrence Wind Farm Project

Dear Kris,

This letter summarizes our review of the Reponses to Cavanaugh Tocci/Bernier Carr Comments letter,
issued June 21, 1010 for the St. Lawrence Wind Farm Project in the Town of Cape Vincent, Jefferson
County, New York.

The following are comments regarding the June 21, 2010 letter issued by Hessler Associates. The
numbers in parentheses refer to the specific items in the June 21, 2010 letter.

(3) Using a linear regression to associate wintertime background sound with wind speed
underestimates wind turbine noise impact at some receptors. Linear regression analysis has, in
essence, been used to determine the average L90 sound level for integer wind speeds. It is to this
average L90 that Hessler Associates adds the NYSDEC recommended margin of 6 dBA to
determine sound level impacts for each integer wind speed.

Cavanaugh Tocci Associates, Inc. recommends that the 90th percentile of the measured
wintertime L90 sound levels in each integer wind speed bracket be used as the background, to
which the NYSDEC recommended margin of 6 dBA be added to evaluate sound impacts at each
wind speed. The CTA method leads to an impact threshold based on the NYSDEC policy that is
approximately 5 dBA lower than the impact threshold estimated by Hessler for a 6 m/s wind
speed. It is at this wind speed that Hessler indicates the greatest potential noise impact may
occur.

MEMBER FIRM, NATIONAL COUNCIL OF ACOUSTICAL CONSULTANTS

Mr. Kris D. Dimmick, Bernier Carr & Associates, P.C Page 2
July 15, 2010
Response to Hessler 6-21-2010 Letter

In comment (7) of the June 21, 2010 Hessler Associates Letter, the following is stated:

The objective of the field survey was to establish for design and assessment purposes a set of
near-minimum background sound levels that reasonably represent ambient levels within the site
area as a function of wind speed.

Using the 90th percentile of the Wintertime L90 data (bracketed by wind speed) does exactly this.
This method reflects an approach that recognizes low community background sound levels above
which the NYSDEC impact threshold of 6 dBA is assessed.

L90 Sound Levels, Bracketed by Wind Speed (in dBA)

Wind Speed (at 10 m) 0 to 1 1 to 2 2 to 3 3 to 4 4 to 5 5 to 6 6 to 7 7 to 8 8 to 9

m/s m/s m/s m/s m/s m/s m/s m/s m/s
CTA Recommended
backgrounds:
Winter, 90th percentile of 21.9 22.7 22.6 23.9 27.6 29.4 33.6 37.4 41.4
L90 sound levels1 (27.9) (28.7) (28.6) (29.9) (33.6) (35.4) (39.6) (43.4) (47.7)
(Corresponding NYSDEC
impact threshold)
Hessler Recommended
Background:
22.1 24.7 27.4 30.0 32.6 35.3 37.9 40.5 43.2
Winter, Hessler Regression1
(28.1) (30.7) (33.4) (36.0) (38.6) (41.3) (43.9) (46.5) (49.2)
(Corresponding NYSDEC
impact threshold)
Amount by which Hessler
winter background exceeds
CTA recommended
0.2 2.0 4.8 6.1 5.0 5.9 4.3 3.1 1.8
background and the
corresponding NYSDEC
impact threshold

1
Data collected December 14, 2007 through December 30, 2007

(4) The L90 is defined as the sound level exceeded 90 percent of a monitoring period. Comment 4 of
Cavanaugh Tocci Associates May 14, 2010 letter (Review of Report No. 1829-082108-C)
specifically states that the L90 is the “lowest level typically occurring,” not the sound level that
“typically occurs” as mentioned in the June 21, 2010 Hessler Associates letter.

(7) There is no conclusive relationship between the L90 sound level and wind speed, as discussed in
our May 14, 2010 letter. Even when site-wide sound data are averaged and plotted, only 65% of
the variation in the L90 sound levels may be attributed to wind speed; this attribution occurs at
even lower percentages when the regression lines for individual sound measurement positions are
analyzed. For individual sound measurement positions, approximately 50% of the time a change
in the level may be attributed to a wind-induced event at a given wind speed.

We agree with Hessler Associates that the evaluation of wind turbine noise impacts should be on the basis
of measured wintertime background sound levels. However, use of the 90th percentile of the measured
wintertime L90 sound levels at each integer wind speed is more appropriate than the regression used by
Hessler because of the wide scatter in sound level data at each integer wind speed. In addition, Hessler’s
Mr. Kris D. Dimmick, Bernier Carr & Associates, P.C Page 3
July 15, 2010
Response to Hessler 6-21-2010 Letter

area-wide averaging of sound level underestimates background sound levels in quieter areas, leading to an
underestimate of wind turbine noise impact in those areas. Our recommended method for determining
background sound level leads to sound level criteria lower than those determined by Hessler Associates.

The Planning Board may wish to consider instituting a resolution process to address complaints if any
should occur during operation of the completed facility. This process would likely involve evaluating
wind turbine sound levels and methods of noise abatement as appropriate.

We hope that this assists the Town in responding in their best interest. Let me know if you or the Town
of Cape Vincent wishes to discuss it.

Yours sincerely,
CAVANAUGH TOCCI ASSOCIATES, INC.

Gregory C. Tocci William J. Elliot

F:\Users\WJE\Projects\2007\07362 - Cape Vincent Wind Farm\Review (Phase II)\Response to Hessler 6-21-10 Letter
(WJE)(GCT)f.doc
 St. Lawrence Windpower, LLC
P.O. Box 660 • 122 South Point Street
Cape Vincent, New York 13618
Tel: 315.654.2210
[email protected]

July 23, 2010

Mr. Kris D. Dimmick

Bernier, Carr & Associates, P.C.
327 Mullin Street
Watertown, NY 13601

Dear Mr. Dimmick:

St. Lawrence Windpower, LLC (SLW) is in receipt of the July 15, 2010 letter from
Cavanaugh Tocci Associates, Incorporated (CTA) to you summarizing the results of
CTA’s review of SLW’s June 21, 2010 letter responding to comments on sound issues
pertaining to the St. Lawrence Wind Farm Project. This letter sets forth SLW’s
understanding of the resolution of the issues addressed in the CTA letter.

In light of the CTA letter, SLW proposes that the appropriate resolution of the difference
of opinion between SLW’s sound consultant and CTA with respect to the determination
of background noise levels would be a requirement to adopt and implement a noise
complaint resolution procedure with respect to the project. SLW has proposed a noise
complaint resolution plan as Appendix C 11.0 of the proposed FEIS. Based upon the
CTA letter, and the prior comments and responses with respect to these issues, SLW
believes that inclusion of the complaint resolution plan fully resolves the comments that
have been made by CTA.

For purposes of completeness of the record with respect to sound issues, however, it is
important to provide an additional response to the issues addressed in numbered
sections (3) and (7), and the third to last paragraph of the CTA letter. To the knowledge
of SLW and its sound consultant (Hessler Associates, Inc.), the method suggested by
CTA for determining background sound levels has not been utilized in any other
environmental impact statements prepared for wind energy projects in New York. In
contrast, the method utilized by Hessler Associates has been utilized for the noise
assessment in approximately 19 environmental impact statements prepared with
respect to wind energy projects in New York (among many others in other states) and
has been accepted by the lead agencies, and their consultants, in all of the those cases.
Some example New York projects where this assessment methodology was used and
where the environmental impact assessment is now in the public domain include the
Chateaugay, Marble River, Ripley-Westfield, Roaring Brook, Wethersfield and
Centreville wind projects. Given that, the methodology suggested by CTA must be
considered a minority opinion, which has not been accepted as normal or standard
practice with respect to noise impact assessment in New York (or, to the knowledge of
Hessler Associates, anywhere else in the country).
We trust that this letter further clarifies the record, and will enable prompt acceptance of
the FEIS by the Planning Board. If you have questions or require additional information,
please let us know.

Sincerely,

St. Lawrence Windpower, LLC

Tim Conboy
Project Development Manager

Copy to: Mr. Rich Edsall - Planning Board Chairman, Town of Cape Vincent
Todd Mathes, Esq. – Town of Cape Vincent Planning Board Attorney
Blayne Gunderman - SLW
Rich Cogen, Esq. – Attorney for SLW
File