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HomeMy WebLinkAboutMDGLightingPlan01/08/17 Lighting Plan Comments Pg. 1 of 2 Marcus Gingerich Comments on the Lighting Plan 1) Without knowing the exact location of each of the turbines and the substation, it is imprecise to try to develop a final lighting plan. The comments here pertain the allegedly approved configuration though there are serious questions as to the ability to construct this facility in compliance with the Enfield Town Wind Law. 2) Paragraph 2, “Radar-activated FAA marking light systems…do not have a proven track record.” What is this assessment based upon? Does the Project Sponsor have specific information/reports that this is indeed true? This type of technology would seem to hold great potential for minimizing the light pollution in a region which already has minimal light pollution and this would cause a large change to the local night sky. It seems this is being dismissed without good consideration. The town board should require more definitive reason as to why such technology should not be included in order to minimize the impact on its residents. If the reasons are not satisfactory, it should push toward requiring such technology on the wind turbines. 3) Paragraph 3, This paragraph is not very clear at all. What is actually being planned? “Substation lighting will be replaced with low-light video and/or camera surveillance monitoring or other security methods that do not require lighting whenever practicable.” Does this mean in lieu of or is there some point in time there will be a replacement of video for lighting? If so, when? 4) “The light intensity will be the lowest intensity required to accomplish its safety purpose…” Well, what is that? How many lumens? Who sets that level and when? Where will they be located? Will they affect neighbors? 5) There is no assessment of how the lighting might actually affect neighboring residents. Thus there is no plan to actually minimize the effect on neighbors while still maintaining safety of the facility. This would be difficult to do anyway since it is yet unclear where the substation will ultimately be placed. So, until that location is known this plan cannot be properly completed and assessed. 6) “Following certification of the facility, a lighting designer will be employed to design a lighting plan for the substation in order to avoid any redundant and ineffective lighting.” First, what is certification of the facility? Is that after its built and in operation? If so, that is too late to be developing a lighting plan. The lighting plan is what this is supposed to be. This plan is not supposed to wait until the facility is in operation. The town board should insist on an acceptable lighting plan on a legally buildable facility now. The town should not wait until later as there is no guarantee that plan will ever get done. How would the town enforce that requirement? 7) What are the consequences of not following this plan? What are the enforceable aspects of this plan? The town board will likely have to lay out reasonable consequences to any failures to comply as it is unlikely that the Project Sponsor will voluntarily impose useful and enforceable restrictions upon itself. 8) The section on substation lighting is too vague ("shall be kept to the minimum necessary for security and maintenance safety"). How many lights will be installed, where will they be located, how many lumens will they have? 9) The FAA recently changed its requirement from a fixed to a flashing red light on turbines to 01/08/17 Lighting Plan Comments Pg. 2 of 2 Marcus Gingerich save the lives of small migratory birds that are attracted to the solid lighting and using it as a point for navigation. All of the turbines except Turbines 2 and 7 are obligated to make this change. BOWF should be obligated under the Wind Energy Permit to conform Turbines 2 and 7 to this standard as well. 10) Finally, here are some comments out of the FEIS from USFWS regarding lighting that need to be addressed: • The USFWS recommended using motion detectors at substations, buildings and turbine doors to reduce the amount of excess stray lights that may attract night migrating birds during inclement weather. BOWF offered to "investigate the feasibility of installing motion detection lights at project facilities." Lights at other components other than project facilities (e.g., O&M facility) are anticipated to be standard lights. We believe BOWF should be required in the Wind Energy Permit to install motion activated sensors at the substation, buildings and turbine doors as recommended by USFWS. • The USFWS also recommended any lighting within the nacelle to be on a timer or motion activated sensor. BOWF responded that the lighting on the nacelle will go on at dusk and turn off at dawn. We believe the Wind Permit should require a motion activated sensor to minimize the disturbance to neighbors. • The USFWS also wants the lighting on the outside of the nacelle to follow FAA standards, using red flashed with minimum intensity and duration and the maximum allowable off time as possible to reduce avian attraction. BOWF responded that they intend to "operate in accordance with FAA requirements" without committing to the minimum necessary. The Wind Permit should require the minimum amount of lighting necessary.