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American Bird Conservancy's Wind Energy Policy

I. ABC POLICY

Birders, ornithologists, and conservationists are debating whether to fully support the rapidly growing construction of wind turbines to generate clean electricity from a renewable source. Concerns have surfaced over the potential threat to birds and bats from the construction and operation of wind energy projects.

For decades, conservationists have urged a shift away from nuclear and fossil-fueled electrical generation to clean, renewable sources of power such as wind and solar energy. ABC supports the development of renewable energy in the U.S., including wind power, as an alternative to fossil-fueled power plants to meet the current and growing demand for electrical energy. In doing so, ABC recognizes that all energy choices have implications for birds.

While ABC supports alternative energy sources, including wind power, ABC emphasizes that before approval and construction of new wind energy projects proceeds, potential risks to birds and bats should be evaluated through site analyses, including assessments of bird and bat abundance, timing and magnitude of migration, and habitat use patterns. Wind energy project location, design, operation, and lighting should be carefully evaluated to prevent, or at least minimize, bird and bat mortality and adverse impacts through habitat fragmentation, disturbance, and site avoidance. For example, wind power projects should be sited on areas with poor habitat, such as heavily disturbed lands, (e.g. intensive agriculture), where possible.

Sites requiring special scrutiny include sites that are frequented by federally listed endangered species of birds and bats, in known bird migration pathways, areas where birds are highly concentrated, and areas that have landscape features known to attract large numbers of raptors. See pages 8-9 for specific recommendations on assuring that construction and operation of wind energy projects at these sites of special concern do not adversely affect birds.

ABC also recommends that:
Wind turbines, associated communication towers, and permanent meteorological (met) towers should be monopoles, and not of lattice construction, and use no guy wires;
The number of turbines that are lit should be minimized and the lit turbines use only simultaneously pulsing white or red strobes; and
All connecting power transmission lines be underground and, if above-ground lines are required, the lines and poles should comply with Avian Power Line Interaction Committee (APLIC) standards.
With sound pre-construction analysis of each wind energy site and with proper safeguards to protect birds and bats, ABC believes that wind energy can be a good choice for our nation's future and for our wildlife.

II. BACKGROUND

A. WIND ENERGY DATA

While still a small component of overall electrical energy output in the U.S. (0.3%), wind energy production is the most rapidly growing electrical energy source. In 1981, there were 10 megawatts (MW) of U.S. installed wind energy capacity. This rose to 2,554 MW in 2000 and has grown rapidly to a currently installed capacity of over 6,370 MW, with utility-scale wind turbines operating in 30 states. The wind industry goal is to provide 6% of America’s electrical energy by 2020, enough to power 25 million homes.

There are approximately 16,000 operating wind turbines in the U.S., all land-based. Newer turbines are larger and can produce 20-30 times more electricity than turbines from the early 1980's. One of the largest wind turbines installed in the U.S. can generate 1.8 MW of electricity, enough to serve 500 households. These large turbines operate with three blades, each over 130' in length. Total height of the wind tower structure (without blades) can reach 262'. For the newer, larger turbines, with the turbine blades fully extended, total height can reach over 400'. Wind turbines operate (blades spinning) about 60%-80% of the time each year. Utility-scale wind power plants require an average wind speed of approximately 13 mph. For general data on currently operating wind plants with a state-by-state list, go to: http://www.awea.org/projects/ and visit the American Wind Energy Association for other background data on wind plant operations.

Fourteen states have adopted Renewable Portfolio Standards requiring utilities to use a specified percentage of renewable energy in their electrical supply. Federal legislation is pending to require 10% renewable use nationwide by 2020. California requires that 20% of electrical use come from renewable sources by 2017 and New York, 25% by 2012. Some states also provide financial incentives to encourage wind energy use. Under the Energy Policy Act of 1992, the federal government provides a wind energy production tax credit of 1.8 cents per KW for wind plants. This tax credit expired on December 31, 2003 when Congress failed to enact a new energy bill that included the wind energy incentive. Until this credit is renewed, most new wind plants will be delayed.

Federal and state governments also are purchasing alternative electrical energy as are individuals and many NGOs, including conservation groups, who purchase wind energy.

B. BIRD MORTALITY


ABC’s mission is to conserve wild birds and their habitats in the Americas and our policies, including on wind energy, strive to achieve that mission. As a national leader in science-based, bird conservation policies, ABC is increasingly called upon for information on avian impacts from wind turbines. ABC has spearheaded national efforts to protect birds from mortality at communication towers, on longline fishing hooks, from pesticides, and from cats. ABC has been a leader in estimating the potential impacts of global warming, largely caused by fossil fuel emissions, on birds. ABC also has been a leader in efforts to assemble and evaluate the best data and solutions to avian mortality at wind turbines. ABC helped form a Wind Energy and Birds Steering Committee of scientists, conservationists, and wind energy officials to conduct a rigorous two-day workshop on wind energy and bird and bat impacts and solutions. The workshop, conducted in May 2004, analyzed the best available data on avian mortality and disturbance at wind turbines and discussed the best data on locating, constructing, and operating wind turbines to prevent/minimize mortality and disturbance to birds and bats. Proceedings will be published and posted at this web site.

Any structure erected, including our homes, may lead to avian mortality. Communication towers kill up to 50 million birds a year; over 90% of the fatalities are neotropical migratory birds. To learn more about bird mortality at communication towers and to view our Tower Kill Report. Collisions with building glass also kill millions of birds each year.

Wind energy production may affect birds through:
1) Mortality from collisions with the turbine blades, towers, power lines, or with other related structures, and electrocution on power lines;
2) Avoidance of the wind turbines and habitat surrounding them; and
3) Direct habitat impacts from the turbines’ footprint, roads, power lines, and auxiliary buildings.

Recent U.S. studies indicate that bird mortality at wind turbine projects varies from less than one bird/turbine/year to as high as 7.5 birds/per turbine/year. The latter fatality rate was at Buffalo Mountain, TN, where three wind turbines are in use, each with a 154' diameter, 3-blade rotor mounted on a 213' tall tubular steel tower. A meteorological (met) tower constructed for the Buffalo Mountain wind plant had a mortality rate of 8.1 birds/year.

At the Foote Creek Rim (Wyoming) wind energy facility, average per guyed meteorological tower mortality was approximately 3 times higher than per turbine mortality. Met and communication towers at turbine sites appear to have more fatalities per tower than fatalities per turbine, hence the necessity for keeping these permanent met and communication towers unguyed and unlit.

At the Mountaineer Wind Energy Project in West Virginia, another Appalachian ridgeline wind facility, 44 tall turbines (345') and related structures caused an estimated mortality of 4.80 birds per turbine in 2003. Approximately 211 birds of 24 species were killed at this West Virginia facility. The data from operating wind projects in the East indicate that 80% of avian fatalities are neotropical migratory birds. At the Mountaineer plant, the largest east of the Mississippi, the most common species found was Red-eyed Vireo (63 birds, 30% of all mortalities). The Red-eyed Vireo is also one of the most frequently killed species at communication towers. Over 90% of species found at communication towers are neotropical migratory birds.

The results of a number of recent studies can be accessed at: http://www.west-inc.com/wind_reports.php. These studies document bird mortality per turbine per year and species composition. For example, the Stateline Wind project on the Oregon/Washington border is one of the world’s largest at 300 Megawatts. The first phase of 399 large operating turbines was assessed at 1.70 bird fatalities/turbine/year, 43% of them Horned Larks, a common year-long resident grassland songbird. Fatality rates at the Foote Creek Rim Wind Project in Wyoming, with 105 large turbines built at 7,600' to 8,000' elevation, was estimated to be 1.75 bird fatalities/turbine/year.

A report for the National Wind Coordinating Committee completed in 2001 examined avian mortality studies at wind turbines (nearly all west of the Mississippi) and found that the annual estimate of all avian mortality from the 15,000 operational wind turbines in the U.S. was 10,000 to 40,000 birds, about 80% passerines. About 14% of the mortality was House Sparrows, European Starlings, and Rock Pigeons. A more recent publication estimated 20,000 bird fatalities based on the 6,400 MW of capacity generation installed at the end of 2003, with approximately 9,000 birds killed at the ~4,000 turbines outside of California. The average number of bird kills per turbine was estimated at 2.1 birds per turbine per year. This equates to 3 birds killed per turbine, per MW per year. Approximately 200 raptor fatalities were estimated nationwide, outside of California. Approximately 700 raptor fatalities occurred in California, many at the Altamont Pass site. Go to: Avian Collisions with Wind Turbines: A Summary of Existing Studies, W. P. Erickson et al, West, Inc., NWCC, (August 2001).

With more and larger turbines operating, new data suggests that the total number of raptor fatalities has risen, but raptor mortality per turbine at new wind projects is very low. At Altamont Pass, the number of Golden Eagles and other raptors killed continues to be a concern. The location of over 5,400 wind turbines with an abundance of raptors and ground squirrels and other prey has led to the raptor mortality concerns, even though the mean for raptor kills over the years has been estimated between 0.048 and 0.10 per turbine per year. Nearly all of the turbines are small, older generation turbines.

See data published on avian mortality and habitat issues on the National Wind Coordinating Council’s web site and visit the Wildlife Working Group section.

Even though local or regional avian population impacts have not been documented and mortality or habitat disturbance may not directly affect the overall population of an avian species, ABC notes these specific concerns:
1) Mortality or other effects on Endangered Species Act listed species or birds of conservation concern. At least 21 species on the U.S. FWS list of Birds of Conservation Concern have been killed at wind turbines, although only a few mortalities of some of these species have been found at individual wind energy facilities.
2) Local or regional population impacts are of concern. e.g. Golden Eagles, other raptors, prairie grouse, and other grassland breeders.
3) Cumulative impacts on species are of concern, nationally, regionally, and with individual projects, especially large ones.
4) While many wind turbine projects have been rigorously monitored for avian impacts, many have not. Data from the newer wind plants in the East is just starting to be published.
5) Location of wind turbines along ridge tops in the East and offshore may present greater potential threats to birds than some wind projects in other parts of the country; and
6) Rapid growth in wind turbine size (rotor-swept area and height) and an increase in the numbers of turbines may cause increased avian impacts.

Bird and bat mortality is expressed throughout this policy statement as birds or bats/per turbine/per year. As wind energy turbines have become larger and able to produce much greater amounts of electricity per turbine, researchers have begun to express mortality in terms of birds or bats per MW generated per year. Unlike estimates for communication towers, mortality estimates for wind turbines have been adjusted upward from the whole carcasses and carcass parts (e.g., feather spots) that are found. This adjustment is made to account for incomplete searcher efficiency and scavenger/predator carcass removal.

C. BAT MORTALITY

Bat mortality ranges from 0.7 bats per turbine per year at the 38 turbines at Vansycle, OR to a high of 47.53 in 2003 at the Mountaineer Wind Energy Project in West Virginia. At the 16 turbines at Klondike, OR, bat mortality is 1.2; at Foote Creek Rim, WY, 1.3; at the 281 turbines at Buffalo Ridge, MN, 2.0; at the 31 turbines at Northeastern Wisconsin, 4.3; and at the three turbines at Buffalo Mountain, TN, 19.5. The high mortality rates at the 44 turbines at the West Virginia Mountaineer wind project and at the three turbines at Buffalo Mountain have created concerns throughout the country.

Conservationists, wind industry officials, and federal agencies joined together to address the causes of this high bat mortality at the wind turbines on ridges in the East. Bat Conservation International (BCI), the American Wind Energy Association, the U.S. Fish and Wildlife Service, and the U.S. Department of Energy’s National Renewable Energy Laboratory met at a two day workshop on February 19-20, 2004. Several of the world’s leading bat scientists attended to share information and discuss what is needed to understand and resolve issues involving bat mortality at wind turbines. Wind-energy companies and government agencies are providing funding for this cooperative effort. BCI is using some of that money to hire a full-time biologist who will spend three years coordinating work related to bat interactions with wind turbines and ensuring that planned studies are formally peer-reviewed. For the Proceedings of the Bats and Wind Power Technical Workshop, go to: www.abcbirds.org.

In addition to attempting to prevent collisions, the group will suggest methods to help site wind projects in locations that may be safer for bats. Short-term efforts may also include testing potential bat deterrents and developing tools to help document bat interactions with the turbines.

Nine of the 46 U.S. bat species account for almost 90% of the bat deaths at wind projects and, while none of the nine are federally ESA listed, several of the species are in decline. It is not clear why some bat species seem susceptible to collisions with the turbines, and that information likely will be critical in developing effective preventative strategies.

D. ELECTRICAL ENERGY CHOICES AND BIRDS

As electrical demand grows, the importance and necessity of energy conservation and shifting from fossil-fueled electrical generation to renewable energy becomes paramount. Solar and wind energy are two of the clean, alternative energy choices. ABC has joined with other conservationists in supporting energy conservation and the use of renewable energy in the U.S. In supporting alternative energy, including wind energy, ABC has evaluated other energy choices and found that all such choices have implications for birds.

Over 52% of the nation’s electrical production now comes from coal burning and there has been a move to burn even more coal. At least 94 large, new coal-fired electric power plants with the capacity to power 62 million American homes, are now planned across 36 states. These new plants would add another 20 percent to the U.S.'s current coal-generating capacity. The plants, slated to start coming on line as early as 2005, would pump more mercury and greenhouse gases such as carbon dioxide and nitrogen oxide, as well as sulfur dioxide, into the air. In 2001, electrical generating power plants produced 36% of the carbon dioxide, 68% of the sulfur dioxide, 38% of the nitrogen oxide, and 23% of toxic heavy metals in the U.S. As an example of the latter, nearly 48 tons of mercury are emitted each year by coal burning power plants.

The current wind energy generating capacity in the U.S. could prevent the burning of 8.4 million tons of coal at the current utility fuel mix. For each megawatt of wind energy produced, 2,000 tons of carbon dioxide greenhouse gases are avoided, 10 tons of sulfur dioxide and 6 tons of nitrogen oxide.

Power generated from coal and other fossil fuels, and the extraction of these fossil fuels have had, and will continue to have, impacts on birds. For example, more than 3,000 birds were killed by collisions during one night in fall migration at a four-smokestack Florida coal-fired power plant. Hundreds of thousands of birds were killed in the Exxon Valdez oil spill and thousands of acres of habitat were damaged.

ABC’s Global Climate Change Program documents the significant changes in store for many migratory bird species in this century due to fossil fuel burning. Without a significant change in electrical power conservation and/or a major shift to alternative fuels, the U.S. is projected to increase its greenhouse carbon dioxide emissions between 2001 and 2025 by 43.5 percent. Global warming is predicted to cause changes in the ranges of birds, disruption of migration timing and synchrony with food resources. Avian species and some ecosystems may be threatened. For a state by state analyses of the effects on birds, go to ABC's web site at: http://www.abcbirds.org/climatechange/statepage.htm and access The Birdwatcher's Guide to Global Warming.

Acid rain is known to reduce food and habitat availability for some avian species. Acid rain has been implicated as a major cause of the decline of the Wood Thrush in the eastern U.S. The extraction of coal, oil, and natural gas also impacts avian species. For example, mountaintop mining/valley fill operations in the Appalachians in West Virginia, Tennessee, Kentucky, and Virginia will cause a projected loss of over 380,000 acres of high-quality, mature deciduous forest to coal mining in the next ten years. This is in addition to 380,000 acres having been lost in the previous ten years. This will lead to a massive and permanent impact on the entire suite of Partners in Flight priority mature forest birds within the coal mining area, including Cerulean Warbler, Louisiana Waterthrush, Worm-eating Warbler, Kentucky Warbler, Wood Thrush, Yellow-throated Vireo, and Acadian Flycatcher. This mountain top coal mining is projected to result in a loss of at least 137,836 breeding Cerulean Warblers in the next decade. This species has been petitioned for listing under the Endangered Species Act and is also on the U.S. FWS National List of Birds of Conservation Concern.

Energy conservation and efficiency need to be re-emphasized. Alternative energy sources to produce electrical power, including wind energy, need to be developed. The key is to develop wind energy to assure that any adverse impacts to birds and bats is prevented, or at least kept to a minimum.

III. RECOMMENDATIONS TO PREVENT AVIAN MORTALITY

 

A. GUIDELINES AND REGULATIONS OVERVIEW


The increasing number of proposals for new projects have stimulated discussion on the need for proper siting, operation, and monitoring guidelines or regulations to prevent, or at least keep to a minimum, avian and bat mortality.

Very careful consideration must be given to each site for wind turbine projects. Each state should adopt guidelines or regulations to assure the prevention or minimization of avian impacts from new wind turbine construction and operation. Comprehensive voluntary guidelines for siting, operating, and preventing/minimizing avian and other wildlife impacts have been issued by the U.S. Fish and Wildlife Service. The FWS Guidelines are open to comment for two years, and will be modified after two years. See, FWS Interim Voluntary Guidelines To Avoid and Minimize Wildlife Impacts from Wind Turbines, dated July 2003.

Also useful are the comprehensive Washington State Department of Fish and Wildlife Guidelines for Wind Energy Projects dated August 2003 and the National Wind Coordinating Committee document: Studying Wind Energy/Bird Interactions: A Guidance Document, December 1999.

Another set of wind energy siting guidelines was developed for Kansas. Such guidelines generally cover three distinct issues: the proper evaluation and selection of potential wind energy development sites, the proper location and design of turbines and associated structures within sites selected for development, and research and monitoring to identify and assess impacts to birds, bats, and other wildlife.

The construction and planning of wind turbines on ridges, such as in the Appalachians, where birds migrate has raised concerns from ornithologists and birders. A thorough review for potential avian mortality and disturbance of critical habitat should be conducted for each new wind turbine farm.

NOTE: Wind energy facilities are typically comprised of several components, including wind turbines, meteorological towers (“met towers”), communication towers, auxiliary structures, and electrical transmission lines. The following guidelines offer recommendations for avoiding/minimizing impacts to birds from the combined effects of these wind facility components.

B. SITING, LIGHTING, GUY WIRES, AND POWER LINES-RECOMMENDATIONS


1) Siting Review. As recommended by guidelines referenced above, surveys should be conducted before wind turbines are approved or constructed that would entail both on-site observations of birds on a seasonal basis (e.g., bird passage during spring and fall migration), as well as more detailed evaluation of the use of the site by birds, particularly of species of concern. Surveys for nocturnal migrants where migratory corridors exist, especially for wind projects along mountain ridgelines, should be conducted. If there are science-based concerns over avian mortality requiring more detailed surveys, two years of pre-construction surveys of migratory birds should be considered. As migration is highly variable in magnitude and temporal and spatial distribution, one year is considered a minimum for identifying potential problems, unless projects are very small or located in areas that have a very low risk to birds. The intensity and duration of preliminary studies can be reduced for projects in areas where risk to birds and bats is clearly low, such as small projects or projects in areas where existing data suggest little bird or bat use. Other research techniques and tools, such as Nexrad, may evolve that can provide an adequate level of confidence about migratory patterns and behavior and may be able to reduce the time required for such studies.

There are two basic steps that should be followed when reviewing sites for bird abundance and migration patterns:
1. Biologists should complete a site assessment by conducting a literature review, evaluating existing published and unpublished data, speaking with people knowledgeable about the area, and conducting reconnaissance surveys to document major vegetation types and likelihood of bird, bat and other wildlife impacts. These reconnaissance surveys should be used to identify potential issues related to site development and to eliminate sites that have a likelihood of causing significant negative wildlife impacts following development.

2. After potentially suitable sites are located, a second level of more intensive surveys should be initiated, if warranted, that quantify bird and bat use of the proposed sites. These follow-up surveys may be necessary because reconnaissance surveys may not provide the level of understanding and detail needed for siting a wind farm, or for siting individual turbines. In other situations, such as for Golden Eagles at Altamont Pass in California, even more intensive studies are needed (i.e., population level studies).

Sites known to be used by birds and bats listed under the Endangered Species Act should be avoided if the construction and operation of wind plants might adversely affect these species. ABC also recommends that locating turbines in known local bird migration pathways, in areas where birds are highly concentrated, or in areas or landscape features known to attract large numbers of raptors should be avoided, unless mortality risk has been analyzed and the likelihood of significant mortality has been ruled out. ABC also recommends that locating turbines in known local bird migration pathways, in areas where birds are highly concentrated, or in areas or landscape features known to attract large numbers of raptors should be avoided, unless mortality risk has been analyzed and the likelihood of significant mortality has been ruled out.

Independent analysis is important to the process. The U.S. FWS Guidelines contain a site evaluation checklist process for pre-development site evaluations and a ranking system for comparison with different sites. These Guidelines recommend that pre-development evaluations should be conducted by a team that includes federal and/or state agency wildlife professionals with no vested interests (such as monetary or personal) in the sites selected. These pre-development evaluations may include academic and industry consultants on the team. ABC suggests that these site assessments, as well as all other studies related to the impact of wind energy on birds and bats, be conducted by qualified professionals without a vested interest in the outcome of the studies. ABC recommends that all studies be conducted in a collaborative manner involving stakeholders.

2) Minimize Lighting. From studies of avian mortality at communication towers, a high priority to prevent bird mortality is to limit lighting on wind turbine towers and associated meteorological towers, communication towers, and auxiliary buildings. Under FAA Guidelines, any structure over 200' must be lit for aviation safety. The lights can cause problems for birds, especially for migratory birds during bad visibility conditions at night. Of particular concern are steady burning red lights--FAA Obstruction Lighting Advisory Circular L-810 red solid state lights. These red solid-state lights are to be avoided. Only a few wind turbines in a project should be individually lit and efforts to assure this may be necessary with regional FAA officials. For example, only 12 of the 44 turbines at the Mountaineer, WV site are lit and all of the lit towers employ red strobes, pulsing at 24 times per minute. Any lighting should be with strobe lights, either white or red. Currently, the FAA is recommending red strobes with a pulse rate of 24 per minute on wind turbines. Preliminary indications are that these lights do not appear to be attracting birds. The pulse rate should be no more than the 24 pulses of light per minute and should be kept to 20 pulses per minute, if possible. The pulses should be synchronized.

Any related structures should not be lit unless required by the FAA, and these lights should be shielded and kept to a minimal intensity. Turbine, met tower, communication tower, substation, and building lights may attract birds to their deaths. The largest single avian mortality event ever recorded at a wind turbine site (27 birds found) is believed to have been caused, or at least aggravated, by a bright, sodium vapor lighting system on a substation building. This was at the Mountaineer Wind Energy Project in West Virginia, where the building lights were eventually turned off after the mortality event and no such event has occurred since then.

3) Avoid Guy Wires and Lattice Supports. Guy wires should not be used for turbines, permanent met towers, or communication towers. Tubular supports with pointed or sloped tops should be used rather than lattice supports to minimize bird perching and nesting. Where met towers use lattice supports, they should be diagonal. Nearly all utility-scale wind turbines are monopoles, without guy wires. In one study, a researcher compared the likelihood of a bird with a one-foot wing span colliding with a guyed 343' communication tower as compared to a 300' extended height wind turbine with three 65 meter blades. The bird had three times the likelihood of collision with the guyed communication tower than the turbine with moving blades, assuming equal avoidance or attractiveness of both structures and with other important assumptions. This is likely one of the reasons avian mortality appears to be so much higher at many guyed communication towers. Communication and permanent met towers should be unguyed at turbine sites.

4) Wind Turbine Power Lines Should be Underground and, if not, Comply with APLIC Standards to Prevent Avian Electrocutions. Power lines should be placed underground, when feasible, to prevent avian collisions and electrocutions. All above-ground lines, transformers, or conductors should fully comply with the Avian Power Line Interaction Committee (APLIC) published standards to prevent avian mortality.

C. HABITAT REVIEW AND MITIGATION

Habitat fragmentation, avian disturbance, and avian site avoidance from the construction and operation of wind turbines, roads, transmission facilities, met towers, and other related facilities should be reviewed and considered. Such turbine-related facilities should be minimized. For example, every effort should be made to use existing roads. When disturbance is temporary, such as from construction impacts, disturbed areas should be fully reclaimed to approximate the same habitat functions for wildlife that existed before the disturbance. While conducting the avian surveys and gathering the data for avian mortality impacts as mentioned above, direct and indirect habitat and disturbance factors need to be thoroughly reviewed at each site of a wind turbine project. Disturbance of critical habitat for birds and other species is to be avoided, and all habitat disturbance or fragmentation should be reviewed.

As noted in the Washington State Department of Fish and Wildlife Guidelines for Wind Energy Projects, wind project developers should be encouraged to:
1) site wind power projects on disturbed lands (i.e., developed, cultivated, or otherwise disturbed by road or other corridors);
2) place linear facilities (such as collector cable routes, transmission line routes, or access roads) in or adjacent to existing disturbed corridors in order to minimize habitat fragmentation and degradation; and
3) avoid using or degrading high value habitat areas.

Habitat mitigation should be considered for wind energy projects developed on undisturbed habitat or, where appropriate, to mitigate direct mortality to birds and bats. See the Washington State Guidelines for an example of mitigation measures that could be applied.

D. SAMPLING FOR AVIAN MORTALITY

Statistically robust post-development mortality studies of avian and bat mortality should be required for at least two years after operation of the turbines begins. If there are legitimate mortality concerns raised by the monitoring, the studies should continue until monitoring demonstrates that the mortality concerns are resolved. Permits should specify the degree of precision required to attain statistically robust data in these studies, including how many days monitoring is done, at how many towers, for how long each day, at what radius around the turbine, and to what extent monitoring is to be done outside of spring and fall migration. The approval process should require that this data be made available to the public. After the completion of field work, a written annual report on avian and bat mortality should be required. Mortality and mortality rate estimates should be developed that reflect adjustments to carcasses found based on carcass removal by scavengers/predators and for searcher efficiency.

The operation of any turbine or turbines that cause significant avian mortality or mortality to any species that may result in population declines, should be rectified to resolve the mortality problem. In cases that cannot be resolved in any other way, the turbine or turbines should be shut down during the periods of peak risk to birds or bats, if these operational changes will resolve the mortality problem and until the cause of the mortality is resolved by other means.

E. RESEARCH NEEDED

More research is needed to better determine methodologies for preventing bird and bat mortality and other impacts from wind turbines. Research is needed on why certain species are affected, and why in some cases, they seem to be drawn to turbine areas. Questions need to be answered about why some turbine sites with an abundance of migratory and resident birds have low mortality. Turbine lighting as an attractant to birds should be evaluated more thoroughly to further document the best lighting to avoid avian mortality. Evaluations are needed of whether avian mortality at turbines follow the patterns of communication towers where over 90% of species killed are neotropical night migrants, with most mortalities during fall and spring migration at night. The effect of turbine characteristics should be evaluated further (e.g., do larger turbines result in increased per megawatt fatalities). Scientific protocols for consistent site evaluations should be developed. Site evaluation data should be used to micro-site turbines and other wind plant facilities to reduce risk to birds and bats. Impacts to birds from habitat disturbance and avoidance also needs to be further evaluated. The planned research on bat mortality is important to resolving mortality to bats nationwide. See Section II. C. Research on ridgeline turbines in the East is needed, as is research on offshore towers.

F. WIND INDUSTRY CODE OF CONDUCT

Wind energy development is occurring at an auspicious time when real progress is being made not only on the technology employed to develop wind energy, but also in the science to assess its potential impacts to birds and bats and to avoid or minimize any such impacts. ABC calls on this growing industry to adopt a code of conduct that will support a standard of continuous and ongoing improvement in the way the industry avoids/minimizes, assesses, and monitors impacts to birds and bats at wind energy projects and responds to those impacts with refinements in design and operating procedures.

IV. OFFSHORE WIND TURBINES

 

A. ABC WIND ENERGY POLICY APPLIES TO LAND-BASED PROJECTS

While some of the siting, operational, and monitoring recommendations contained herein may be useful in reviewing offshore wind project proposals, the ABC Wind Energy Policy applies to land-based wind energy projects. ABC notes that offshore wind power in the U.S. is a nascent industry without statutory interpretation, case law, or administrative guidance. The U.S. Fish and Wildlife Service voluntary guidelines for siting and operating wind turbines cited above, as well as state guidelines for wind energy projects, all apply to land-based turbines. Efforts are underway to develop guidelines for offshore projects. ABC will update its wind energy policy and information at a later date to include offshore wind plants.

B. OFFSHORE WIND PROJECT STATUS

There are no currently operating offshore wind turbines in the U.S. and none under construction. More than a dozen offshore wind energy plants are operating in Europe with over 200 turbines. Information is available on most of these European wind projects. Seven applications for offshore wind energy projects have been filed with the U.S. Army Corps of Engineers for turbines off the coast of Massachusetts, New York, Virginia, and in the Great Lakes. Siting is expected to be a critical issue with potential problems for slower flying, larger seabirds and waterfowl.


C. LITERATURE ON EUROPEAN OFFSHORE WIND PROJECTS AND BIRDS

For background information on the siting and operation of European offshore wind projects see:
1) BirdLife International, Windfarms and Birds: analysis of the effects of wind farms on birds, and guidance on environmental assessment criteria and site selection issues, UK. (Sept. 2003).
2) Klaus-Michael Exo et al., Birds and offshore wind farms: a hot topic in marine ecology. Wader Study Group Bulletin 100:50-5. (April 2003).
3) I. Tulp et al., Nocturnal flight activity of sea ducks near the windfarm Tuno Knob in the Kattegat, Bureau Waardenburg, Netherlands. (Dec. 1999).
4) National Environmental Research Group, Base-line investigations of birds in relation to an offshore wind farm at Horns, Denmark. (2001).
5) Magella Guillemette et al., Impact assessment of an off-shore wind park on sea ducks, Denmark. (1998).

 
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