"Mr. Culkin said Henderson residents supported the study because they contend the wind farm would pose a threat to the economy by tarnishing the natural beauty of Lake Ontario’s Henderson Bay...."

Henderson plans nearly $20,000 study to have ‘guns loaded’ against Galloo Island wind project

"My husband and I have a home on Whites Bay in Henderson Harbor. We pay substantial taxes for the water front property and oppose the industrial wind mills on Galloo Island. We enjoy swimming and fishing near the island and believe the wind mills will ruin the landscape. As taxpayers we are tired of the funding these projects that do not create jobs and drive up the cost of electricity. This is crony capitalism at it's best."

That was a recent comment submitted to the New York Publics Service Commission by a Jefferson County Citizen concerned about Hudson Energy's proposal to sacrifice Galloo Island to industrial Turbines which are puny producers of power in exchange for the horrific trade offs that would impact thousands of Jefferson County residents.


Local Ornithologist and Seaway Trail author Gerald A. Smith voices concerns about Galloo Island Industrial wind turbines.

-The PIP document is completely inadequate in addressing process involving impacts on ecological resources of importance to the public

-The failure of the project proponent to advertise locally that they had commenced the project is highly questionable. The over a month delay is suggestive of a lack of sincerity regarding public involvement on the part of the project proponent.

-The site is adjacent to the largest colonial water bird colony in Lake Ontario. Breeding species such as the threatened Common Tern and Caspian Tern regularly fly across Big Galloo at below turbine height thus the potential for mortality is obvious.

-Earlier studies associated with proposed wind projects at this site indicate raptor concentrations and state endangered wildlife present at the site. While these studies are out of date and need to be updated with at least two years of new studies the potential impacts of this project are of great concern.

-The Great Lakes have been well documented as flyways for migrating birds and bats. The concentration dynamics occurring in the Eastern Lake Ontario Basin are no exception and are a reason for great concern over any possible project in this area.

-Little information exists on late summer concentration of swallows at this site. Data from the Canadian project on nearby Wolfe Island indicate these species, including the greatly declining Purple Martin, are highly vulnerable to impacts from the proposed project.

-Little information exists on the effects of such large scale habitat alteration on raptors and other sensitive species but this is a matter of great concern.

Although my primary expertise involves birds I have great concern over potential bat impacts. Big Galloo Island may have suitable habitat for the federally endangered Indiana bat and federally threatened Northern Long-eared bat If either species is present any project at this site is highly problematic.

I trust that all agencies will carefully review potential impacts of the proposed project. In my opinion this is a highly questionable location for the proposed project for many reasons. I look forward to a careful review of the cost benefit of this proposed project that takes into account all impacts on wildlife humans and the environment. Thank you for considering my initial views on this matter.

Gerald A Smith Senior Ornithologist

You can view Mr. Smith's comment and add your own testimony to the New York State Public Service commission by visiting this link.

And, this comment from the Conservation Chair, Onondaga Audubon

I wish to make several comments with regard to the proposed wind energy project 15-F-0307 at Big Galloo Island, Jefferson County New York. There are several areas of concern that point toward the potentially negative impact that this project will have on wildlife. I am Conservation Chair of the Onondaga Audubon Society(OAS). Because the area covered by our chapter includes Jefferson County, I feel that it is necessary for the OAS to provide input.

First, the potential for bird mortality is great due to the location of Big Galoo Island. It is next to a very large colonial water bird colony and other birds, such as the Caspian tern, are present in the area. They fly below turbine height and are thus in danger. Also, there is a very large concentration of migratory bird species in this area at least twice a year. These realities need to be considered.

Second, mortality data from the Wolfe Island Ontario project support the liklihood that industrial wind on an island on Lake Ontario contributes to the decline of species that concentrate there. Several swallow species are known to gather in significant numbers during pre-migration periods in late summer and early fall.  The presence of large numbers of birds in staging areas needs to be assessed and considered.

Third, previous ecological assessments indicate the presence of raptors and state threatened avian species on Big Galoo Island.  There is a need for up-to-date bird and bat surveys there. These should be a pre-requisite before any consideration is given to the development of an industrial wind project of this magnitude.

Last, it should not be assumed that the public does not care about the natural resources of Big Galoo Island. What will be lost should a project like this be allowed to proceed will far exceed the meager output of electricity that will be gained. And if one were to consider this gain without the generous PILOT subsidy, it would be even smaller. 

In my opinion, the presence of 31 575-foot turbines with blades of up to 210 feet, miles of gravel road, and other infrastructure will turn the island into an industrial sacrifice zone. The agencies charged with the oversight of such a project need to make a very careful assessment of the situation before deciding whether or not it should be allowed to proceed. 

Thank you for considering my comments.
                                                                                                                        Sincerely: Maryanne Adams
                                                                                                                                        Conservation Chair, Onondaga Audubon
                                                                                                                                        10757 State Route 34, Cato, NY 13033


Jefferson County's Golden Crescent home owners launch vigorous opposition to Galloo Island industrial wind.

"We fear the financial impact on the valuation of these properties..... "

RE: Property owner near Galloo Island Wind Farm opposes project

Dear PSC team evaluating this proposed siting plan for "up to 31" six hundred foot tall wind towers directly in front of my property on Stony Point:

Thank you for your careful review of the initial proposal from GALLOO ISLAND WIND FARM, and in advance for your continuing efforts over the coming months to consider all inputs from local, impacted parties. Despite this island's address being technically in Hounsfield, I'm quite sure that Henderson, and especially Stony Point residents, will take the brunt of the viewshed and sound impacts of this project, with absolutely no gain to compensate.  

My family's owned a 15 acre multiple dwelling property on Stony point for nearly 100 years, and have used this pristine, scenic location for family living and gathering continuously through this time.  One interesting advantage of the property is that it looks directly out to the west, onto Stony Island, Calf Island and both Little Galloo and Galloo Islands, making for spectacular sunset viewing throughout the year.  In the peak of the summer, the sun sets behind these islands before it continues south along the horizon with progression towards winter.

 Though these islands are 4-6 miles away, we can clearly see structures, see lights in buildings or on shore, etc.  In fact,  Iwatching for the 7 lighthouse signals out front was an important and satisfying test for visitors when I was younger. Those lights can be noted on the charts, but they would include lights up to 40 miles away. 

At times when no wind is blowing, you can hear sounds from great distances next to the water, including conversations of fishermen in boats from very far away.  A combination of no vegetation to disrupt sound waves, and perhaps dense inversion layers above can keep sound travelling along the water for much further than expected.

These two aspects (of lights being visible from great distances and sound travelling much further than expected above water), make us VERY concerned about an industrial wind farm being placed directly in front of our Henderson homes.  Light and noise are common complaints by neighbors of wind development, and here we would be fully exposed to the light and sound even though this is several miles away.

Pulsing lamps on the towers will also be very disturbing, as mentioned.  They also would distract from our ability to notice boaters in nearby waters who might be needing assistance.   Has anyone studied "infrasound" transmission over inland water bodies?

This area has historically been a location for raptor breeding, including peregrine falcons, bald eagles and various hawks.  After DDT use had destroyed these populations, much effort was spent to restore these populations and we now enjoy Bald Eagle sightings on a routine basis.  It would be an astonishing shame to reverse this progress and waste that investment by allowing construction of a large wind farm nearby the nesting locations of these birds, and in a major flyway for geese migration as well.

As a resident of Jefferson County and the Town of Henderson, I am opposed to the destruction of our area's natural resources with industrial turbines.   We fear the impact on our enjoyment of these family estate properties that we've worked hard to invest in, and develop for our retirement homes and our future generations as well.  We fear the financial impact on the valuation of these properties as well if this project proceeds.

Having been through this review previously, we have a significant latent distrust for developer's lack of transparency, and suspect their proposal will evolve.  I hope that your process shines bright on these proposals and highlights change as it happens.

You can read more public comments to the New York State Public Service Commission matter at this link.


"because the visual impact of the turbines would be much greater than a five-mile radius"

Galloo Island wind developer submits proposal to start Article 10 review

Coalition representing the Jefferson County Towns that would be affected the most by a Galloo Island wind turbine sacrifice zone enters its initial comment into the record of the PSC matter.

I am a year round resident of Jefferson County, Town of Henderson. I am strongly opposing the wind energy project Hudson North Country Wind 1, LLC (Hudson Energy Development) has proposed for Galloo Island, PSC Case 15-F-0327.

I am also Co-Chairman of The Coalition for the Preservation of the Golden Crescent and 1000 Islands Region. Our Coalition strongly opposed the first attempt by Upstate NY Power to develop Galloo Island with an industrial wind energy facility, as well as this attempt by Hudson Energy Development.

Our Coalition is comprised of taxpayers throughout the southern/eastern shores of Lake Ontario and Lower 1000 Islands Region. We also have strong representation inland throughout the Finger Lakes region.
Galloo Island in the New York State waters of Lake Ontario and Main Duck Island in the Ontario Provincial waters of Lake Ontario are only a few miles apart. The government of the Province of Ontario has prohibited all wind power development on Main Duck Island and elsewhere in Great Lakes provincial waters. The State of New York should do no less.

These 575 foot tall turbines (over one-tenth of a mile) and are considerably taller than those on Wolfe Island, which are clearly visible over 15 miles away, in day or night. The vastly shorter turbines on Wolfe Island dominate the night sky over 15 miles away from most towns’ vistas. The map below shows a 15 mile buffer around Galloo Island.

The six Towns that would be most affected within the 15 mile view shed are Cape Vincent, Lyme, Brownville, Hounsfield, Henderson and Ellisburg. The vistas in these towns have created very high value property tax revenue as well as tourism economy based on those vistas.

It is a very conservative estimate that each town has 350 waterfront, or waterfront vista parcels appraised at an average value of US$150,000. This conservative estimate amounts to US$315 million of property value that will be most affected by the Galloo Island wind energy project. The attached McCann study completed in 2011 as part of the Town of Cape Vincent NY wind energy project proposed by BP Energy suggests 5-25% appraised value destruction. This study is very applicable to the this project as well. Using a mid-range of 15% property value depreciation amounts to nearly US$50 million property value loss. Also using a US$30 tax assessment per US$1000 property value assessment amounts to nearly US$1.5 million loss of taxes collected by the Towns.

The Towns of Orleans NY and Cape Vincent NY also produced Economic Impact Studies which suggest further economic destruction due to wind energy development.

The Great Lakes Seaway Trail recently submitted a cautionary statement opposing projects such as that proposed by Hudson Energy development on Galloo Island.

Lastly, the Thousand Islands Regional Assessment Program (TIRAP) provides the typical resources that exist along the Golden Crescent which would be affected by Hudson Energy Development’s proposed project. The TIRAP report can be downloaded through this url

This 102.3MW gross energy facility would consistently place less than 25MW delivered energy due to low efficiency factors associated with this form of energy production. The public need for this drastically small amount of energy would be further lessened through the high cost of the submarine cable, lines loses and then eventual distribution into the northern NY grid near Oswego.

It should be very apparent that National Grid’s rebuff to Hudson Energy development for use the Scriba substation strongly suggests the limited need for this small amount of energy. Additionally, in the same region, we have carbon free, non-polluting energy abundance with several Nuclear Energy Facilities and many Hydroelectric Facilities.

The public need for less than 25MW generated from Hudson Energy development’s proposed Galloo Island wind energy project , at a substantial social and environmental cost should alone prevent Hudson Energy Developments’ request for this project to succeed. When coupled with proven property value destruction and economic hardship to the surrounding towns, the social and environmental justice. Through the Article 10 process, we strongly ask the PSC to enforce the alternative generation strategy portion of the law, considering that a solar project will have less overall environmental impacts.

This project will forever change the landscape of the Golden Crescent and 1000 Islands Region, affecting an area from Mexico Bay to Tibbett’s Point with severe and drastic ecological and view shed changes. Below is an excerpt from a Resolution passed by the Jefferson County NY Board of Legislators;

There is serious and grave concern expressed by the Onondaga Audubon Society, which is drafting resolutions to strongly oppose this project. Galloo Island is a known habitat for Bald Eagles and many other species that will be in danger of direct mortality and significant habitat disruption. One of those species, the Northern Long-Eared Bat - present in the Lake Ontario Islands - was added to the endangered species list this past week - upgraded from threatened. In fact, the last developer asked for and received Kill Permits for Bald Eagles.

It has been studied and determined that this density of wind energy turbines can and will disrupt local and regional radar systems (Ft. Drum, Watertown Regional Airport and the National Weather Service).

This project is an environmental liability and involves the export of environmental impacts of New York City energy consumption to northern New York. It also is directly contrary to the current direction of NYS energy policy toward distributed generation located closer to the much greater energy demand in downstate NY. The Cuomo Administration’s New York Reforming Energy Vision at its core recognizes the benefit of distributed versus remotely located central generation. A giant wind project on Galloo would be contrary to that.
We respectfully ask that you oppose the wind energy project on Galloo Island proposed by Hudson Energy Development.

Robert E. Aliasso, Jr. 
8748 State Route 178 
Henderson, NY 13650

Attachment 1 – McCann Appraisal Study – Town of Cape Vincent NY (2011)
Attachment 2 – Town of Cape Vincent NY Economic Impact Study and Addendum 1 (2010) Attachment 3 – Town of Orleans NY Economic Impact Study (2010)
Attachment 4 – Great Lakes Seaway Trail Statement (2015)
Attachment 5 – TIRAP Final Report {embedded url link} (2015)


Great Lakes Seaway Trail with offices in Sackets Harbor, NY wrote a letter concluding that Galloo wind towers would be detrimental to tourism interests in Jefferson County.

June 4, 2015

NYS Board on Electric Generation Siting
3 Empire State Plaza
Albany, NY 12223-1350

Re:  Galloo Island Wind Farm Project
To Whom It May Concern:

I am writing this letter as the CEO of the Great Lakes Seaway Trail, to advise the Board of our concerns regarding the proposed wind farm project proposed for Galloo Island. The Great Lakes Seaway Trail is a federally designated National Scenic Byway. Our organization operates to leverage the Historical, Cultural and Natural features of the trail to benefit the region through tourism and education.

It is our position that the scale and environmental impacts of the towers would be detrimental to the tourism interests of the area through direct impacts to the view shed from many communities, as many as 7 New York State Parks as well as an array of designated historical sites. The most recently proposed scale of the turbines at 600 feet tall will make this project visible from Mexico Bay to Tibbet’s Point and well inland as well

The Eastern Lake Ontario Shoreline and lake plain are part of a well-documented avian migration flyway and year round bird habitat; the towers would represent a significant threat to bird populations well beyond the eastern basin of Lake Ontario. 

We also have an overarching concern regarding the vitality and livability of all of the communities along the trail. We are concerned that the industrial scale and environmental impacts of the wind turbines would be a significant negative impact to nearby communities. The legislation creating the Byways has been adopted by local municipalities and is embedded in their Zoning requirements.

The Great Lakes Seaway Trail is not opposed to development which is economically beneficial to the area; however, we seek to ensure that the historic, natural and scenic resources of the area are carefully addressed and protected by those empowered to approve such development. 


John P. Hall

CEO, Great Lakes Seaway Trail

If you love Jefferson County's Golden Crescent and Lake Ontario, you might want to comment to the New York State Public Service Commission regarding Hudson Energy's proposal to sacrifice Galloo Island to industrial wind.

Here is what one Jefferson Country resident has told the PSC:

I am vigorously opposed to the proposed Galloo industrial wind farm.

I come to this position with a 50 year history of knowing the region as one of the most naturally beautiful and scenic areas.  I first came to the thousand island region over 50 years ago when I was 7 years old.  My family camped along the shores of Lake Ontario and the St. Lawrence River many times in my youth.  Even as a young child I was able to recognize how special the area was, not only to people who were lucky enough to live here year round but especially as a family from downstate NY.  Years later I was drawn back to the area based on this history and we purchased property in the Town of Lyme on Point Peninsula.  We were fortunate to get a remote piece of land with over 1200' of shoreline and 20 acres.  What a special retreat it has been for our family to, at first, get away from the hustle and bustle of the urban NY area!  We have loved the calm serenity so much that we now live here year round and enjoy all the wonderful waterfront recreation the Lake affords.  We kayak, boat, fish and swim in the Lake and enjoy the peaceful natural beauty of our vista on a daily basis for the last 8 years.  We fall asleep to the gentle breeze blowing through the trees, the sound of the water lapping at our beach and we wake to the sound of summer song birds and geese in the fall.  We would never have come here had we thought for a moment that it would become an industrialized wind zone.

We have the complete fortune of sharing our paradise with a nesting pair of bald eagles that live on our property.  Every year the pair have a juvenile who plays on the sand bar off our property and we get to watch the clumsy young eagle learning how to walk and fly.  Most days in the summer around 9:30-10am we see at least one of the eagles leave to get their morning breakfast from the lake.  This is one of the things we live for.  We are aware that they are the eagles that were cited in the first project's proposed Environmental Impact Study that during the winter would go out to Galloo Island to find their meals.  I shutter at the thought that these huge wind turbines could one day chop our eagles into pieces.  I can't imagine that any sane person would sully the region and industrialize one of God's most magnificent wonders.  Everything that we came to the region to enjoy would be gone.  
There are so many areas that are not in either populated areas nor in the most scenic areas our State has to offer that it would be a travesty for a corporation to ruin this paradise.  How could we allow corporate greed to take away the spectacular beauty and the tourism that helps fuel the local economy.  

If we are trying to use renewable energy to protect our environment, it seems incredibly counterintuitive to do it in this region that would destroy the wildlife and natural beauty in one of the States most prized scenic environmental locations.
I respectfully urge the State to deny the application.


JAZZ on the river will benefit Wounded Warriors

The Coalition for the Preservation of the Golden Crescent and Thousand Island Region has been added to the Party List in PSC Matter 15-F-0327, regarding proposed 570 ft. industrial wind turbines on Galloo Island.

Coalition for the Preservation of the Golden Crescent and Thousand Island Represents concerned citizens from the six towns most affected by attempts to industrialize Galloo Island.

Robert E. Aliasso, Jr.

From: DMM@dps.ny.gov [mailto:DMM@dps.ny.gov]
Sent: Wednesday, July 22, 2015 9:44 PM
To: raliasso@twcny.rr.com
Subject: 15-F-0327: Robert E. Aliasso Jr. has been added to the Party List; Msg. Tracking No.: 74

Robert E. Aliasso Jr. has been added to the Party List of the case 15-F-0327
Case No.: 15-F-0327
Case Title: Application of Hudson North Country Wind 1, LLC for a Certificate of Environmental Compatibility and Public Need Pursuant to Article 10 to Construct a 103 MW Wind Energy Project.

Contact information: 8748 State Route 178 Henderson NY raliasso@twcny.rr.com 13650

Appearing on behalf of: The Coalition for the Preservation of the Golden Crescent and 1000 Islands Region

Nature of Interest in the case: As co-Chairman of the Coalition for the Preservation of the Golden Crescent and 1000 Islands Region, our group has various subject matter experts as well as a vast collection of data from the initial Upstate NY Power attempt to industrialize Galloo Island. We represent the six towns most affected by this project and our collective voice would ensure a balanced approach to collection of data, and presentation of further information

Party has consented to electronic service of Commission orders in this case : Yes

Party has consented to serve and be served by other parties by electronic means : Yes

Pursuant to the Commission's rules of procedure, parties have an opportunity to object to the granting of party status subject to deadlines and procedures set forth in said rules.

Visit our DMM Online Help page for information on various DMM processes.
If you have questions, please contact the DMM Help Desk at dmm@dps.ny.gov or 518-474-3204.

You can view the party list at this link.


Tall ship Fair Jeanne will spend the weekend on display at the Cape Vincent Village Dock.

Late Saturday morning, July 25th, 2015, the tall ship Fair Jeanne is expected to dock at the Village of Cape Vincent. Free deck tours will be available Saturday and Sunday until 5 PM.

RWiley Photo

Late Saturday morning, July 25th, 2015, the tall ship Fair Jeanne, seen about during Cape Vincent's 2015 Historical Days,  is expected to dock at the Village of Cape Vincent. Free deck tours will be available Saturday and Sunday until 5 PM.
RWiley Photo
Fair Jeanne in the Cape Vincent Harbor. 
RWiley Photo

Stop by the Village Dock this weekend for a free deck tour.

Public comments about a proposal to turn Galloo Island into an Industrial Wind Turbine Sacrifice Zone start to reach the New York State Public Service Commission.

The following comment from a Jefferson County citizen has been posted on the New York State Public Service Commission internet page regarding Hudson Energy's Galloo Island matter:

As a resident of the Town of Cape Vincent, NY, a long time member of the Town of Cape Vincent Planning Board, member of the Zoning Committee that wrote all of the Town of Cape Vincent Zoning Law Revisions, member of the committee that created the original Town of Cape Vincent Comprehensive Plan, a member of the committee that created and updated the Town of Cape Vincent study of the economic impacts of large scale wind development and a resident in direct view of the Wolfe Island Ontario wind development and a resident living within the viewshed of the proposed project, I have experienced everything that large scale wind development can impose on a community and individuals lives. The proposed Hudson North Country Wind 1 project will negatively impact the lives of everyone living in or passing through the viewshed of the site for the following reasons:

Wind development puts a community at extreme economic risk (loss of nearby property value, added costs to the taxpayers for legal services, added costs to the taxpayers to administer land use regulations, potential cost to decommission the site when the developer abandons the project, added responsibilities and training for emergency medical personnel/firefighters). 

Wind development does not provide long term jobs to the locality.

A wind turbine has a limited lifespan. When a municipality becomes dependent of the tax revenue from a wind farm it has no reasonable way of adjusting to the tax burden that will be shifted back to the taxpayers when the project is abandoned.

Wind development on Galloo Island will, without question, result in the death of thousands of birds. The Wolfe Island Ontario project kills thousands of birds of all types which is confirmed in that projects carcass inventory reports. A wind project anywhere near a major migratory bird flyway, especially a project involving towers and turbines considerably higher and larger in diameter than the Wolfe Island project, is totally inconsiderate of the impact on wildlife.

In spite of what developers and their advisers state, wind turbines do create harmful noise. While it is true that noise may not be always present, on many days the disturbance of air as it flows through the blades results in a dull, constant roar. I hear it from Wolfe Island on some days and I live nearly two miles from the nearest turbine.

The night sky will be filled with flashing red lights which will drive some residents from their homes.

I conclude that the proposed project would have considerable negative impacts on us, especially those living nearest to the site. The project certainly would not be compatible with the environment. 

Express to the New York State Public Service Commission your concerns about turning Galloo Island into an industrial wind turbine sacrifice zone.

The following is a comment I sent to the New York State Public Service Commission expressing a concern I have for Hudson Energy's proposal to turn Galloo Island into an industrial wind turbine sacrifice zone. You can make comments by visiting the PSC matter at this link.

Honorable Kathleen H. Burgess

Secretary of the Commission

New York State Public Service Commission 

Thank you to the members of the PSC for their recent letter to Hudson Energy pointing out serious inadequacies in their recently filed Public Involvement Program for the Galloo Island wind energy matter. 

As a resident of Jefferson County and the Lake Ontario town of Cape Vincent, I am opposed to decimating our valuable Lake Ontario resource with industrial turbines. 

I do appreciate that the PSC suggested that the Hudson visual study be expanded from an inadequate 5 mile limit to a 15 mile range which means that the study area will now include those towns and those Jefferson County residents who will suffer the more severe impacts. 570 ft. turbines on Galloo Island will be seen nearly 30 miles over the waters of Lake Ontario and many of those affected the most live closer to Galloo than those in the host community of Hounsfield.

According to a Jefferson County legislator, the extensive shoreline of the Golden Crescent of Jefferson County  is the home of a very large portion of the county tax base and each of the towns that would be impacted by Galloo claim that living on those shore lines means the properties are worth more. Consequenly those homeowners pay a very large premium on their town, school and country taxes.

As for the choice of Galloo Island for industrial wind; along with the creation of a visual disaster for thousands of county taxpayers, I do not believe that the project would be environmentally compatible nor is there a need to sacrifice one of Jefferson County's most valuable natural resources, the Golden Crescent of Lake Ontario.

Richard C. Wiley
Cape Vincent, New York

New York State Public Service Commission tells Hudson Energy to expand their Galloo Island impact study areas to include the Town of Cape Vincent.

"DPS Staff recommends that the Project Area should be expanded to include additional municipalities. At a minimum, the list of adjacent municipalities should include those noted in Section 3.5 (Towns of Cape Vincent, Lyme, and Henderson; and the Villages of Chaumont and Sackets Harbor) and the Towns of Brownville and Ellisburg."


PSC finds much of Hudson Energy's PIP to be inadequate, including their suggestion of five mile visual studies.

In a letter from Lorna Gillings to Neil Habig, Project Developer for Hudson Energy Development, the New York State Public Service Department found that the recently filed Public Information Plan for their Galloo Island project was inadequate in many respects. Lorna Gillings is the PSC Consumer Advocacy and Education Office of Consumer Services and her letter to Habig pointing out the inadequacies that they advised to be corrected can be read at this link.