Honorable Kathleen H. Burgess
Secretary to the Commissioner
Public Service Commission
90 Church Street
New York, NY 10007
Dear Ms. Burgess:
Several Western New York Boards of Health have been engaged
in wide public interest and general concern over the proposal by APEX to
construct industrial turbines in Western New York counties. These counties are members of the Western New
York Public Health Alliance (WNYPHA), and our members share that concern. These projects plan for the erection of
industrial turbines in the communities that we, under New York State Public
Health Law, are charged with protecting resident’s health.
Classifying wind turbine projects under Article 10 allows
them to be classified as Type II actions in the SEQRA regulations (6NYCRR Part
617). This classification allows
standard environmental reviews under the Environmental Conservation Law,
Article 8 to be waived. Under the
Article 10 legislation, our local boards of health home rule ability to take
steps to safeguard the health and wellness of our residents and protect the
environment within our counties has been put at risk. What is the State’s position and plan to
ensure that our residents’ health is protected and the impacts on our local environment
have been reviewed and vetted through the standard state assessments for
projects of this magnitude?
Our membership believes that any project of this nature and
magnitude only be considered following a complete and transparent process
including all the standard environmental and health impact studies and local
input. The WNYPHA, lacking both the
resource and expertise in this very broad matter, believe it is both reasonable
and prudent to require a full SEQRA environmental review prior to any further
consideration or action by the Article 10 Siting Board.
If you have further questions on our position or wish to
discuss further, we request that you contact Niagara County Public Health
Director Daniel Stapleton at (716) 439-7435 or Orleans County Public Health
Director Paul Pettit at (585) 589-3278.
The Western New York Public Health Alliance (WNYPHA) is a
not-for-profit organization comprised of the Health Commissioners/Public Health
Directors and other community public health leaders from the eight counties of
Western New York. Their mission is to support collaboration across WNY to
further public health initiatives and priorities. As part of this mission, the
WNYPHA works to provide health education and information to prevent disease and
improve population health. For more information on this article or the WNYPHA,
please contact Christine Schuyler, Public Health Director for Chautauqua County
at 716-753-4590 or Lori Ballengee, Public Health Director for Allegany County
at 585-268-9250.