October 20, 2016
DOE Golden Field office
15013 Denver West Parkway
Golden, CO 80401
Dear Mr. Parker:
The American Bird Conservancy (ABC) and Black Swamp Bird Observatory (BSBO) appreciate the opportunity to comment on the public scoping process for the proposed Icebreaker Wind Energy Project in Lake Erie, Ohio.
ABC is a 501 (c) (3) not-for-profit membership organization whose mission is to conserve native birds and their habitats throughout the Americas (www.abcbirds.org). ABC acts by safeguarding the rarest species, conserving and restoring habitats and reducing threats, while building capacity in the bird conservation movement.
BSBO is a 501(c) (3) not-for-profit organization whose mission is to inspire the appreciation, enjoyment and conservation of birds and their habitats in Ohio through research, education, and outreach (http://www.bsbo.org/).
First, ABC and BSBO were specifically asked by paper on impacts to birds from the proposed project (LEEDCo 2014) and offer comments, which we did (see attached). We identified several problems with the LEEDCo assessment and were told that our comments would be given serious consideration and that modifications to the white paper would be made. Yet, two years later, none of that has happened.
Second, in the past year, Lake Erie was designated a “Globally Important Conservation International. This followed a formal petition submitted by BSBO and was based on the number and variety of avifauna using the lake or the airspace over it at various times of the year (see Diel et al. 2013, Bowden et al, 2015, Horton et al 2016, Rathbun et al. 2016).
Third, BSBO’s Biggest Week in American Birding northwestern Ohio and contributing some $40 million to the local economy, as well as building a powerful political constituency for nature (Kaufman 2016), all of which could be threatened by large-scale wind energy development in and around Lake Erie.
Last, but not least, the U.S. Fish and Wildlife Service (FWS) recently released their advanced radar study of the southern shore of Lake Erie, documenting that vast numbers of birds and bats migrate along the shoreline and travel over the lake, often flying within the rotor swept area of commercial wind turbines (Horton et. al. 2016). This study not only has verified the high risk to federally protected species in one of the world’s bats; it has also discredited confluences industry-funded risk assessments based largely on daytime, visual surveys. Such surveys, as well as conventional radar studies (including the ones cited in LEEDCo, 2014), fail to measure the altitude at which birds and bats are flying and most of these migrants are traveling at night. These studies, including those on Lake Michigan and Ontario (Bowden et al, 2015, Rathbun et al. 2016) have verified what ABC, BSBO and others have been saying for some time: that the Great Lakes are not a good place for large-scale, commercial wind energy development.
Michael Hutchins, Ph.D. ABC, Director, Bird Smart Energy Campaign
Kimberly Kaufman, Executive Director, BSBO, Bird Smart Wind Energy Campaign
See entire letter in link here.
(Please note that GLWT does not support “bird friendly” wind turbine siting: there is no such thing.)
At all sites, says the conservancy, the radar recorded high levels of bird and bat activity in or near the “rotor-swept zone” that wind turbines would occupy if built along the lakeshore. Activity was especially high at night – a finding that largely invalidates the use of daytime visual surveys often used by wind energy developers to assess risks to birds, ABC claims.
“This study is the smoking gun in the argument against installing wind energy so close to the lakeshore,” says Dr. Michael Hutchins, director of ABC’s Bird-Smart Wind Energy Program. “If risk to birds means anything to our elected leaders, this should be the death knell to projects like Lighthouse, which is currently under serious consideration by New York’s Public Service Commission.”
The FWS currently recommends that no wind turbines be built within three miles of the Great Lakes’ shorelines, and The Nature Conservancy recommends five miles. However, says ABC, this new radar study suggests that the minimum should be extended even farther – perhaps as far as 10 miles.
“I said, ‘can you tell a Canada warbler from a Kirtland’s warbler via radar?’” Hutchins said. “They said, ‘no, but we had people out there with binoculars during the day looking as well.’ These are nighttime migrants and a lot of times they’re flying at a couple of thousand feet. It depends on the weather conditions as to what height they fly and what routes they fly. During high wind or inclement weather they could be flying a very different route at different altitudes.”
However, the technology to record bat and bird deaths from wind energy facilities offshore is not well developed yet.
“We’re afraid that if they’re allowed to build it that we’ll never know what they’re killing and how many,” Hutchins said.
SEE ALSO MOTHERS AGAINST TURBINES and John Miner of London Free Press