E.21 29 March 2019 Kathleen H. Burgess Secretary to the Commission New York State Public Service Commission Three Empire. State Plaza Albany, NY 12223-1350 Sean Mullany Presiding Examiner York State Public Service Commission Three Empire State Plaza Albany, NY 12223-1350 Daniel P. O'Connell Associate Examiner 625 Broadway, First Floor Albany, NY 12233-1550 New York State Department of Environmental Conservation RE: Case No. 16-F-0559 Application of Bluestone Wind, LLC for a Certificate of] Environmental Compatibility and Public Need Pursuant to Article 10 oft the New York State Public Service Law to Construct the Bluestone Wind Energy Facility in the Towns of Sanford and Windsor, Broome County, New York Dear Secretary Burgess and Examiners Mullany and O'Connell: Please find attached a note outlining my concerns with the proposed project's potential impact on local birds, particularly--but: not only-on bald and golden eagles, (All concerns are based on materials available on the DMM site.). As the note makes clear, it is my view that outstanding issues with regard to risk to local raptor populations cannot be resolved on the basis of existing research materials. Sincerely, Wonhbelbnr Heather DeHaan 24 Davis Avenue Johnson City NY 13790 hezyonka@gmail.com 29 March 2019 Kathleen H. Burgess Secretary to the Commission New York State Public Service Commission Three Empire State Plaza Albany,NY 12223-1350 Sean Mullany Presiding Examiner York State Public Service Commission Three Empire State Plaza Albany, NY 12223-1350 Daniel P. O'Connell Associate Examiner 625 Broadway, First Floor Albany, NY 12233-1550 New York State Department of Environmental Conservation RE: Case No. 16-F-0559 Application of Bluestone Wind, LLC for a Certificate of Environmental Compatibility and Public Need Pursuant to Article 10 of the New York State Public Service Law: to Construct the Bluestone Wind Energy Facility in the Towns of Sanford and Windsor, Broome County, New York: Dear Secretary Burgess and Examiners Mullany and O'Connell: Iwrite to voice my deep concerns with the proposed project's potential impact on local birds, particularly- but not only on bald and golden eagles. It strikes me that this project has moved forward with excessive haste, taking too little time to fund the research required to ensure proper protections for local birds, many ofwhich are endangered or threatened and, to the extent that they are present in this region, should be considered a critical element of local wealth-its attraction to homeowners and tourists (hikers, fisherman, etc.), as well as distinct part of local Iask that space be made for further research, particularly into wintering and seasonal bald and golden eagle populations. In reading through the reports, it strikes me that raptor surveys were conducted in only a few locations, due to limits of time and funding (though the time restrictions could have been lift - and should be). This matters not only for golden and bald eagles, both of which can be found in surprisingly high numbers in this area, but also for the peregrine falcon (also endangered), as well as for threatened species such as the northern harrier (documented in raptor surveys conducted by Bluestone, as limited as these were). Other endangered and threatened species (not listed here) would likely also benefit from such work. culture and heritage. Iti is also clear that the mitigation and: avian assessment materials submitted by the applicant failed to grapple in any serious way with the project's impact on wintering golden eagle populations. Though Dr. Miller's report on micro-siting provided some concrete ideas for how losses to eagle populations might be reduçed, she appeared to deploy data related to golden eagle migration, not wintering populations- -in the case ofour golden eagles, a group ofat-risk birds entirely overlooked in the WEST materials and Bluestone's Avian Risk Assessment. Ini my view, Dr. Trish Miller's evaluations of proposed turbine location highlighted the problems that haste produces. First, in her assessment, she was reduced to making suggestions with regard to turbine micrositing, simply because her expertise was not brought to bear on this project sooner. (I am puzzled that Calpine and WEST neither knew ofr nor incorporated her research.) Second, her findings seemed to indicate that Calpine needs to support further study oflocal wind patterns: after all, Dr. Miller identified several turbines currently slated for placement in areas of high risk to eagles, but of low value for wind generation. If such locations were chosen because: of challenges of which I, as a member of the public, am unaware (e.g. the locations of buildings on these properties, challenging topography), then Ir nonetheless wish to ask why such turbines In sum, I am asking that all parties involved set aside funds and/or time for further raptor surveys are in the project at all. They seem a bit too costly and too ineffective. and seriously consider a: return to rethinking the macro-siting of these turbines. Sincerely, Kahlbeler Heather DeHaan 24 Davis Avenue Johnson City NY 13790 hezyonka@gmai.com