Site Specific Wildlife Evaluation

It has been stated by certain members of the public that the U.S. Fish and Wildlife Service (USFWS) has made the recommendation that all wind projects be placed three miles away from the shoreline of the Great Lakes. This is based on dated information associated with a wind project developed in Huron County, Michigan, that distorts the current reality as it relates to wind project development.

In 2007, Craig Czarnecki, Field Supervisor of the USFWS East Lansing, Michigan Field Office, wrote a letter to the Lake Township (Huron County, Michigan) Deputy Clerk, in regard to the Garden Peninsula wind project near Lake Huron and Saginaw Bay. In it, Mr. Czarnecki does state, “The Service recommends that no turbines be located within three miles of a Great Lake’s shoreline.”  He also references Interim Guidelines to Avoid and Minimize Wildlife Impacts from Wind Turbines that were created in 2003. In the letter, high levels of avian use are cited as the basis for this recommendation. Additionally, Dr. Jeff Gosse, also from the USFWS East Lansing office, has documented high levels of migratory birds and bats using radar technology, and also cites this as a reason to recommend siting wind projects more than three miles from the Lake Huron shoreline. 

Of note is that in Mr Czaernecki’s recommendation to Huron County, no analysis was provided of the actual impacts that a wind project might cause to these migrating species, nor were recommendations made on operational or monitoring protocols that could minimize or identify potential for their interaction with turbines. The letter is supposing that the presence of large numbers of wildlife during migration is incompatible with wind energy development. This assumption, although seemingly intuitive, is simply not supported by research or facts from operating projects and ignores what is known about wind/wildlife interaction at this time.  Of particular interest to this matter is that monitoring of this Huron County project has been decisively clear in documenting low levels of impacts that are consistent with wind projects located away from shorelines (i.e., low levels of bird mortality).  A variety of other well-studied projects near the Great Lakes (Steel Winds in Buffalo New York, Wolfe Island near Kingston, Ontario) and near the Texas Gulf of Mexico (Penescal and Gulf Wind Projects in Kenedy County, Texas) have documented low levels of impact during migratory periods as well.  It is probable that during low visibility conditions, migrating birds may be at greater risk of collision with operating turbines, just as they appear to be with communications towers and transmission lines and other tall structures; however, the mere presence of high numbers of migrating species does not seem to be a causative agent in mortality.

Dr. Gosse’s technical report on the radar data collected in Huron and Ocean Counties, Michigan, states specifically that “combining the results of radar studies and fatality searches would greatly improve risk assessments and assist with interpretation of standardized radar studies.” This is exactly what was done at the Michigan project in question: 27 months of fatality monitoring was completed using study designs reviewed and approved by the USFWS. The results show that with no operational adjustments, the fatality rate by turbines at the project is very low and the minimal impacts are consistent with those of other wind projects across the continent, despite the radar data demonstrating high levels of migration period use. The studies conclude that in no way can the project be construed as having significant impacts to the populations of any bird species.

To Apex’s knowledge, a shoreline setback recommendation has not been made by the USFWS Northeast Region (Region 5) or the New York USFWS offices, as applicable to all Great Lakes or Lake Ontario specifically.  It most certainly has not been made directly to Apex in regard to the Lighthouse Project.  In fact, although USFWS has noted its concern to Apex regarding the large-scale movement of wildlife along the southern shore of Lake Ontario in springtime, the agency is working closely with Apex to design and implement site-specific studies and review findings for the Lighthouse Wind project to make informed decisions on siting, impact avoidance, operational protocols and monitoring if the project is built.

The most effective way to protect local wildlife when siting and operating a wind farm, or any other type of development, is to understand the site-specific characteristics regarding species that may be at risk of impact. This includes evaluating patterns of activity during all seasons, such as breeding, migration, wintering, and other behavioral characteristics, and making informed decisions on siting, monitoring, and operational protocols. Lighthouse Wind is working closely with the USFWS and the New York Department of Environmental Conservation (NYSDEC) to design and operate the project so that impacts are not significant or adverse at the local or regional levels by using the processes outlined in the 2012 USFWS’s Land-Based Wind Energy Guidelines (WEGs) and NYSDEC’s guidelines. Lighthouse Wind will continue to work with the USFWS and the NYSDEC throughout the entire development and permitting process to agree on appropriate studies, analyze all data collected, and respond to findings appropriately.

The following wildlife surveys have been recommended and are currently being completed and reviewed in order to determine the most wildlife-friendly turbine layout and operational protocols for the wind farm:

  • Breeding Bird Survey
  • Raptor Migration Survey
  • Winter Grassland Raptor Study
  • Year-round General Avian Use Survey
  • Year-round Eagle Use Survey
  • Acoustic Bat Activity Survey
  • Federal/State-listed Bat Presence/Absence Surveys
  • Spring and Fall Migration Radar Assessment Studies

Additional surveys may be recommended and completed during development of the project and robust monitoring during operations would be expected to evaluate the effectiveness of impact avoidance measures.

Wind energy projects protect birds and wildlife by producing no dangerous pollutants or carbon emissions. They also require no mining or drilling for fuel, use virtually no water, and create no hazardous or radioactive waste. Clean, renewable wind energy is a safer generation option for people, wildlife, and natural ecosystems.  In fact, climate change is considered one of the biggest threats to the long term survival of America’s wildlife. Changes in species ranges, timing of natural events (e.g., migration, nesting) and habitat loss are being documented in recent years along with changing temperatures, and clean power projects such as Lighthouse Wind are thought to directly address this problem by reducing carbon pollution.