FOR THIS IMPORTANT LETTER FROM Michael Hutchins of ABC and Kimberley Kaufman of BSBO, see the OPSB website for comments.
Please note that Great Lakes Wind Truth’s position is emphatic that there is zero threshold for the heinous idea of industrial wind in any shape in the Lakes. Zero. While it is useful to point out the deficiencies in the project’s surveys of all kinds, it is also useful to note that worldwide the stats are in: wind turbines are killers, birds and bats, and wildlife, and in this particularly sensitive migration bottleneck, the impacts are easily predicted to be catastrophic.
Here are important excerpts:
Comments regarding USFWS letter to OPSB dated March 3.2017.
On p. 4 of the letter USFWS states “We are currently working with Applicant (LEEDCo) and ODNR to recommend site-specific pre- and post construction waterfowl surveys fall through spring…” BSBO and ABC find this survey period to be insufficient, and we recommend the survey be extended over a period of three years in order to generate statistically significant data.
It is unfortunate that the prior surveys have not provided adequate, rigorous data; but that is not reason to truncate the amount of time given to perform such an adequate and rigorous study now. With regard to the previous studies the USFWS concluded on P. 5 that “the data obtained was not sufficient to Inform risk. The Service is now working the Applicant to design a radar project (both pre- and post-construction) to provide important site-specific information for assessing the potential impacts of offshore wind facilities on nocturnally migrating birds.”
LEEDCo’s response to this recommendation has been to reject – on the basis of cost – all of the proposed options and to propose an alternative that is more palatable to them. The fact remains that the sufficient risk assessment is missing, and therefore has not been performed to the satisfaction of USFWS. BSBO and ABC conclude that this unresolved matter with LEEDCo is reason enough to consider the application incomplete.
On p. 8 the USFWS states “We believe that the available information is insufficient to determine mortality risk.-.given the lack of site-specific data and the inconsistencies in pre- and post-construction data collected at land-based wind projects. We believe it is important to gather site specific data…” Based on this criticism BSBO believes the application should be considered incomplete. On P. 8, the USFWS states ” the Service requests that at a minimum, turbines should be curtailed (the blades should be oriented such that they do not catch the wind) until the manufacturer’s cut-in speed (3.0 m/s for the turbine model proposed in the application) is reached at night during bats’ active periods (generally April-October).” The basis of this thinking is that bats tend not to fly at high wind speeds; therefore, shutting down the turbines at low wind speeds will curtail mortality. However, a study done In 2010 in Pennsylvania^ showed that In order to curtail bat mortality the cut-in speed needs to be raised to 5.5 m/s. This reduces bat mortality by 70%, while a cut-in speed of 3.0 m/s has almost no effect. BSBO and ABC recommend that the cut-in speed of the turbines be 5.5 m/s during the time of high bat activity, April through October, as identified by USFWS.
While BSBO and ABC understand that USFWS, ODNR, and LEEDCo are working together to devise plans for obtaining valid and sufficient data to Inform a rigorous scientific risk assessment we recommend that the application be considered incomplete until an independent and scientifically valid risk assessment is in hand. (Our emphasis) Based on past performance, and considering the overall importance and significance of the project, BSBO and ABC suggest that the promise to provide a risk assessment at a future date is not sufficient to grant project approval.