HomeMy WebLinkAboutMDGLandscapingPlanComments-v201/08/17 Landscaping Plan Comments
Pg. 1 of 2 Marcus Gingerich
Comments on the Landscaping Plan (changes in red)
Except for an additional paragraph at the end, this plan appears to be unchanged, thus all of the
previous comments are still quite relevant.
1) The plan does not mention how the existing vegetative state will be documented. It would be
reasonable that the vegetative state of the exact location of the turbines, substation and
collection lines would be documented prior to construction with photos and diagrams. Where
are diagrams to show what it will look like? At turbines 4 and 5, the town would see that the
vegetation has already been excavated. How will the existing vegetation be depicted in those
locations? There should at least be photos taken as a record.
2) There is no mention of how the project will deal with the turbine sites which have already been
excavated. Who will decide what the vegetation will look like since it has already been
removed? The town should be involved in making sure it will be acceptable.
3) Paragraph 3, “…invasive species will be prevented from establishing or spreading…” how will
this be accomplished? Is this different than the invasive species control plan? Which particular
species will be monitored for? There are several important species missing from the ISCP.
These should also be monitored for. The following priority species should be actively searched
for and controlled: Purple Loosestrife; Common Reed (Phragmites); Japanese Knotweed; and
Giant Hogweed.
4) Paragraph 4, how large an area will be maintained as low-growing vegetation. There are no
dimensions, diagrams, no definitive plans. Will the size of this are correlate to the size of the
area described in the invasive species control plan, a radius of 200’ around the turbine site. If
so, I do not see how this is acceptable as I believe in at least one case it would require extending
into non-participating property. In the case of several turbines, the 200’ radius mentioned in the
ISCP extends onto neighboring non-participating properties, is this the dimension of merit for
the landscaping plan as well? The dimensions of the sites really need to be clarified in order to
better understand these plans.
5) Paragraph 4, “The cleared lad around turbines located in forest will be seeded to perennial
native grasses…” How is this possible in the case of turbine #4? The statement to the DEC is
that this could not be reseeded as directed by the DEC due to the lack of top soil after
preconstruction excavation. In correspondence with the DEC, BOWF indicated that nothing
was likely to grow due to the rocky nature of the site. However, it is obvious from aerial
imagery from 2013 that the site was covered with vegetation. So, will the project sponsor haul
in topsoil to again cover the rock for seeding? Will they simply claim that nothing will grow
anyway because of the now rocky nature of the surface much like they claimed to the DEC?
6) Does this landscaping plan cover the decommissioning process? There really needs to be a
landscaping plan that covers decommissioning as well. Is there budget allowance in the
decommissioning bond in case the town has to effect the decommissioning process?
7) Does the landscaping plan cover catastrophic repair or reconstruction of wind farm
components? How will the landscaping be repaired after such an incident?
8) This is not the type of plan that a professional landscaper would put together. It is just a bunch
of words strung together to make it sound good. Where are the landscaping diagrams? If not
included, why not?
01/08/17 Landscaping Plan Comments
Pg. 2 of 2 Marcus Gingerich
9) This plan should not be approved unless it is reviewed by an expert. With BOWF failure to
keep their escrow account in compliance with the local law, this should not be done, thus this
plan should not even be worked on until the account is in compliance with the local wind
energy law. It appears that yet again, the escrow account is in the red by $8k. Unless this is
rectified, there should be no work done for the project.
10) Where are the enforceable aspects of this plan? Does the town have any means of verifying and
enforcing the details of this plan?