“… the scope of the threats, from leaking gear box oil, turbine failure and combustion, tower collapse, blade shears, to re-exposure of contaminants and toxins, physical displacement of currents and food flow, acoustic interference to life in the lake, siltation affects in immediate vicinity of turbines, interference to Homeland Security, death of wildlife, property value impacts, commercial and recreational fishing impacts, and more, for intermittent power at best, … I urge the EPA to permanently end such folly through a permanent moratorium on offshore wind farm development in Lake Erie, and all the Great Lakes.” (Richard Davenport to US EPA, September 3, 2019)
For decades, mainstream environmentalists have sought and received offshore moratoria for offshore hydrocarbon development. With wind turbines, the potential damage to the ecosystem is much more pronounced than with oil and gas projects in the Atlantic, Pacific, and Gulf of Mexico.
How will so-called environmentalists respond? Hypocritically? Or with consistency?
In a letter to EPA head Andrew Wheeler, copied to President Trump, Richard Davenport makes a case that Icebreaker–six massive turbines about 8 miles offshore in Lake Erie at Cleveland–should not proceed. But more than this, a holistic approach to preserving the Great Lakes should be applied. Davenport stresses the following points:
The free-market approach of ending all subsidies for wind power would kill offshore wind. But short of that, mainstream environmentalists have provided the playbook that surely applies in magnified form in regard to modern wind turbines.
Seven counties in New York State have lined up to oppose wind development in the Lakes: Niagara, Erie, Chautauqua, Monroe, Wayne, Cayuga, Oswego, Jefferson.
The town of Somerset NY, passed insurmountable wind turbine ordinances, literally making development impossible. Apex withdrew its application (for now).
The GLOW (Great Lakes Offshore Wind) project, NY, Lake Ontario, was defeated due to economics and public opposition.
Galloo Island had its application withdrawn due to incorrect information from the developer that there were no Bald Eagles at the island.
Ontario, Canada, has declared an offshore moratorium for ten years, but with the new PC government in 2018, riding into power on the wings of anti wind sentiment, is not going to lift that moratorium any time soon.
Icebreaker, then LEEDCo, withdrew its application in 2016. This has now morphed into a collaboration with Icebreaker, Fred Olsen Renewables Inc, a foreign billionaire having apparently bought the assets of LEEDCo. It seems to many that this prolonged battle to end this project’s application, in its various morphing states, may be shortly advancing to closure.
In short, every single effort to industrialize the Lakes is met with fierce opposition, some anti wind groups staying the course for over ten years.
Dear Administrator Wheeler:
Allow me to introduce myself; my name is Rich Davenport, recording secretary of the Erie County Federation of Sportsmen’s Clubs (ECFSC), secretary of the Western New York Environmental Federation (WNYEF) and I serve as an appointed member of the Erie County Fisheries Advisory Board (ECFAB), Erie County, NY.
I write this urgent letter to you concerning a matter of utmost importance and urge the EPA to step in to stop a folly that is under consideration in New York – installing Industrial Wind Turbines in the open waters of Lake Erie.
We all understand the current push for wind energy to replace fossil fuel powered electrical generation, carbon footprint and reducing carbon dioxide emissions, in the name of saving the planet.
Two undeniable truths, however, are being ignored: 1) You cannot save the planet by jeopardizing fresh water, and 2) there will never be a time that electrical energy outweighs the importance of healthy fresh water.
Indeed, the first undeniable truth is a direct reason the Environmental Protection Agency (EPA) was founded in 1970. Your intervention to assure the protections of the Great Lakes basin, fresh water bodies that account for 21% of the world’s surface fresh water resources, 90% of the North American continent’s surface fresh water resources, our waters of life, is therefore necessary.
Fresh water ecosystems, such as Lake Erie, carry a unique relationship; healthy life results in healthy waters, and vice versa. This inseparable symbiotic relationship affords the people healthy fresh water, which equates to healthier communities and surrounding wildlife and domesticated animals.
Approximately 11 million people across NYS, PA, OH and Ontario, Canada depend upon Lake Erie for their drinking and bathing water. We depend upon Lake Erie to make food and beverage products, we irrigate crops and water our livestock with the waters of life, and with modern transportation, food and beverage products shipped across the Nation expands the impact our healthy waters have upon many more lives. We all learned the painful lessons over decades of cavalier industrial pollution of the Great Lakes.
Increased illnesses due to toxic chemicals, histamine -related ailments due to unchecked insect infestations (remember, Lake Erie was declared dead in 1970.) The EPA, through the Clean Water Act of 1972, and its predecessor, the Great Lakes Protection Act of 1968, coupled with the natural uniqueness of Lake Erie, our precious waters of life experienced a very dramatic about-face.
Today, after decades of hard work, collaborative effort and billions of dollars of restoration and protection funds invested, Lake Erie has become the most important fresh water fishery in the United States, and perhaps ranks as the top fresh water fishery in the world. It is the world’s best managed fishery, and recent contaminant and health testing conducted by the NYS Department of Health revealed that the old industrial pollutants still on the lake bottom, but covered by sediment that has built up over the years, has cut off the remaining toxins from the food chain, resulting in uncontaminated fish that is safe for consumption once again.
The plagues of insects we suffered with for decades, most notably the caddis fly hatches, no longer resemble biblical plagues, as fish returned and once again keep these insects in a healthy balance. An allergist in Buffalo, NY discovered the female caddis fly emits a pheromone that causes extreme allergic reactions in humans, in 1932!
Fish displaced at the start of the industrial pollution began this phenomenon, and the return of fish decades later brought this under natural control today. We are familiar with the pockets and hot zones for diseases such as MS, Lupus and cancers. Instances have reduced, as we no longer play Russian roulette with every glass of water we drink, or freshwater fish we eat from Lake Erie.
It is a testament to the people, the conservationists and state and federal government agencies, such as the EPA, that Lake Erie and her sisters in the Great Lakes basin have recovered so well, but none more breathtaking that Lake Erie. All of this effort and incredible work for the kids not yet born is once again at risk.
Industrial Wind turbines bring many threats to the waters of life, in addition to other well known concerns as interference with RADAR detection systems, critical for Homeland Security to defend our northern border, concerns of property devaluation from residents along the lake shore, navigation safety concerns from recreational and commercial boating, maintenance challenges during inclement weather (Lake Erie is the most dangerous of all Great Lakes) not to mention thick ice cover during winter, and the resulting potential damage nature would cause, and the needless and senseless killing of many birds and bats that use Lake Erie for food and migration routes.
Although several questions and concerns exist, two very real threats from Industrial Turbines rise above the others; these two threats are re-exposure of buried industrial toxins through tower construction and transmission line trenching, and the acoustic pollution both during construction and operation.
Toxic Sediment threat
Lake Erie is the shallowest of the Great Lakes, with a mean depth of 62 feet and a maximum depth of 210 feet. These characteristics afford marine physics to cover the entirety of the lake bottom with sediment during runoff and storms. The other Great Lakes are not so physically favorable, and the toxins dumped in Lake Ontario, for example, will always remain exposed to the food chain, inflicting risk of health issues through consumption due to our own intentional polluting.
This curse has been eradicated by nature herself over time in Lake Erie, resulting in higher quality drinking water for over 11 million people in the US and Canada, and fish that are harvested both commercially and recreationally, consumed by many, now free from risk of contaminant presence, such as dioxins, heavy metals and PCBs. Turbine construction will mandate displacement of sediment to expose the bedrock for anchoring the turbine towers.
The trenching for transmission lines to make possible the use of the electrical energy generated by the turbines also requires displacement of the sand cap, only across long distance from every turbine installed. Our current dredging regulations in NYS would require identification of potential contaminants being re-exposed before any dredging permit is issued.
Not only would the re-exposure of toxins impact New Yorkers, its impact would be felt in Canada by our Canadian friends as well – water knows no borders. This activity, I believe, would violate the International Joint Commission’s Great Lakes Water Quality standards – standards which are internationally agreed to.
In 1956, a marine scientist named Jacques Yves Cousteau brought to the television viewing populace the first cinematic presentation of what would later become the weekly show called “The Undersea World of Jacques Cousteau” – a documentary called “The Silent World”. Focusing on fish, both bony and cartilaginous, Cousteau presented the idea and belief that fish lived in a world of silence.
This became an accepted part of marine biology, until very recently when scientists discovered fish have very complex and highly specialized inner ear structures, vital to their survival. Indeed, over time, we have discovered that noise and sound, especially low frequency sound that we produce, can impact the behavior of both fish and marine mammals, prompting research to better understand the noise pollution we generate and how marine life is impacted.
One of the leading researchers in this specialized area of marine science is Dr. Arthur Popper, a now retired professor at University of Maryland, Laboratory of Aquatic Bioacoustics. Research into the important role sound plays in aquatic life of every kind has generated many scientific papers and articles, with some chilling observations and warnings. Some information can be found at this link – https://asa.scitation.org/doi/pdf/10.1121/1.5021594.
In 2006, leveraging the work of Popper and his colleague Dr. Anthony Hawkins, a study on Offshore Wind Farms and their acoustic impacts was conducted by Thomsen, F., Lüdemann, K., Kafemann, R. and Piper, W. (2006). Effects of offshore wind farm noise on marine mammals and fish, biola, Hamburg, Germany on behalf of COWRIE Ltd.
Representative species of fish were selected based upon anatomy of the swim bladder, as well as species without swim bladders. The species experiencing the widest range of impact due to the noise generated by the wind facility studied appeared to be cod fish – a species of commercial importance that has a gas-filled swim bladder.
During construction of the industrial wind factory, the noise generated from pounding and blasting for the support towers created a radius of measurable impact of 81 km, or approximately 50 miles.
Impacts begin with a phenomenon known as masking – the interference from outside noise that hides, or masks, the noise made by both predators and prey. The specific frequencies measured and documented in this study effectively blinds gas-filled swim bladder fish to their surroundings, an impact that will stimulate behavioral changes, resulting in displacement to avoid these areas.
The closer these fish are to the turbine construction site, the greater the damage, including deafness, soft tissue damage, internal bleeding and death. Once the construction period is over, the operational noise from the turbines will create a displacement zone through effects of sound masking up to a 5 km radius, or approximately up to 3 miles from each turbine.
The commercially, recreationally and biologically important fish species in Lake Erie that have gas-filled swim bladders include: walleye (or yellow pike), yellow perch, black bass (largemouth and smallmouth), emerald shiners, rainbow smelt, crappie, sunfish, muskellunge and northern pike. These fish will be impacted, and displaced from their natural spawning grounds and migratory routes.
However, one critical difference must be understood, concerning relative size of the environment. Lake Erie, at its widest point, spans a mere 57 miles. This means no matter where the project initiates, the life in the waters will be negatively impacted in both US and Canadian waters. Once construction completes, migratory patterns and the ability to maintain their reproductive success will continue to suffer.
As more turbines are installed, more acoustic pollution will be ever-present in the Lake, with an ever-growing impact area based on each turbine’s individual impact radius. The noise will literally reverberate across the entire Lake, with no refuge to be found. Negative impacts to life in the lake have negative consequences for the health of the waters of life.
Detailed studies now exist, using modern telemetry technology shedding incredible insight into behavioral and migratory activities of such species as walleye, muskellunge and the threatened lake sturgeon, specific to Lake Erie. A simple overlay of impact radial diagrams around each proposed turbine’s installation site within the animated data currently available from the NYSDEC Lake Erie Fisheries Unit will illustrate the threat better than words can tell.
Ontario, Canada implemented a 10-year moratorium on offshore wind development across all Great Lakes, except Lake Michigan, in February 2011. The moratorium remains in place to this day, with no plans to lift it. Canada recognizes the existence of potentially profound threats not yet fully understood.
As additional information is learned, the scope of the threats, from leaking gear box oil, turbine failure and combustion, tower collapse, blade shears, to re-exposure of contaminants and toxins, physical displacement of currents and food flow, acoustic interference to life in the lake, siltation affects in immediate vicinity of turbines, interference to Homeland Security, death of wildlife, property value impacts, commercial and recreational fishing impacts, and more, for intermittent power at best, something we need a lot less than healthy fresh water, I urge the EPA to permanently end such folly through a permanent moratorium on offshore wind farm development in Lake Erie, and all the Great Lakes.
We should rather focus our efforts to address the growing threat of biological and pharmaceutical contamination in the waters of life through efforts to modernize our wastewater and storm water systems and treatment facilities. We do not need to add another threat to these Great Lakes, our waters of life, the world’s waters of life. We have learned that painful lesson already.
Sincerely Yours, Rich Davenport