December 13, 2016
To Whom It May Concern:
We appreciate the opportunity to comment on New England Aqua Ventus’ wind energy project off of Monhegan Island through the NEPA process. We have been following this project’s evolution since 2014 and have steadfastly believed that it is a poorly sited project from the perspective of wildlife conservation. The presence of these turbines will negatively impact the birds that migrate past and through the island every spring and fall, and also have consequences economically for the island community. Monhegan is a well-known destination for birders from far and wide who visit to witness the volume of avian migrants that travel through this region. Their presence is a huge boost to the business owners on the island, as these visitors stay in the hotels and frequent local restaurants and stores during the shoulder season when the majority of tourists have left for the year. Other visitors to the island want to go there to experience the tranquility of the island, whether it is to paint, hike, or simply relax. The presence of these turbines as close as they are to the island will no doubt interfere with the visitor experience, result in significant bird mortality, and reduce the appeal to birders as well.
Of all of the possible locations for this so-called experimental project, Monhegan Island has the most potential negative consequences. While none of the potential test sites are truly “offshore” (“nearshore” would be the most accurate description) it seems unwise to locate the project where known costs are greatest.
Bird populations throughout the world are declining due to a variety of human-induced impacts (or anthropogenic threats). A recent study showed that fully one-third of native North American bird species are in serious trouble and will require concerted conservation efforts to ensure their future. Large-scale impacts such as habitat loss aside, the second biggest threat (behind outdoor cats) is from collisions with structures, including towers and windows. Though these structures constitute anything from buildings to cars to power lines and towers to wind turbines, we must take into account the fact that global energy demand is forecasted to increase 37% by 2040. This will mean more wind turbines, and more negative effects on birds and bats. It also makes it critical that as new projects are proposed, they are developed with the best available technology to minimize risk. The American Bird Conservancy has estimated that wind turbines alone will kill 5 million birds annually when the electricity produced by turbines reaches 35%. Add to that the number tens of millions already taken by collisions and electrocutions by their associated power lines and towers and the loses are hardly trivial.
Mortality from the Monhegan project, or any other specific development, does not exist in a bubble. It is one piece of the cumulative mortality that occurs by a variety of different means, leading to the population declines exhibited by many species. So, how do we measure mortality at a site? Right now all fatality data are collected by paid consultants to the wind industry—a direct conflict of interest. For offshore wind projects, it is virtually impossible to obtain accurate counts. Any surveys that are done post construction for dead birds will come up empty as birds disappear in the open ocean. Even if it was thought that mortality will be negligible around these wind turbines,that is not a reason for inaction or lack of mitigation strategies (Loss 2016).
However, we realize that there is a good chance that this misguided and poorly-sited project will go forward. Therefore, we insist that New England Aqua Ventus and partners take whatever steps necessary to reduce and/or mitigate the possible extensive negative impact on wildlife. Very little is known about offshore wind development, and this project could in fact be used as a case study of how to produce cleaner energy in a way that minimizes consequences to wildlife. New studies are being regularly published that offer up ideas to be tested.
It is our intent in this letter to raise awareness of the potential issues this project will have on migratory birds in the Gulf of Maine, and where possible, to suggest some options. We have done some research in the peer-reviewed literature, but this is by no means exhaustive. As stated above, since no one will be able to adequately assess the actual impact of the turbines in this location it is imperative that the project is developed in a way to minimize any possible negative effects. Offshore wind development projects are still a relatively new phenomenon and there is much to be learned. Preliminary studies have posed a wide array of theories and conclusions, but admittedly some of it is contradictory indicating that these projects should be studied on a case by case basis. Let us learn from the trials of this project to make it as safe as possible while netting the highest energy returns.
- In addition to direct mortality, the effects of turbines include several indirect impacts, including displacement and the creating of barriers that change flight patterns, effects on breeding performance, adult survival rates, and on land-based development, and changes in predator abundance. Furthermore, recent research suggests that the low-frequency noise produced by turbines may disrupt acoustic communication the effects on nocturnal flight calls, which have been proposed of as a way of providing “air traffic control” apparently remains unstudied (summary from Smith and Dwyer, 2016).
- The issue goes much further than “just” a concern about birds traveling to and from Monhegan Island. Because of the concentration of migratory birds that pass through the area, over, and immediately around the island, significant mortality will indirectly impact breeding populations elsewhere (Smith and Dwyer, 2016).
- Turbine height deserves attention. One study has shown that as wind turbine hub height increases from 36 meters to 80 meters, there is a 10-fold increase in average mortality rate (Loss et al, 2013)
- Therefore, we call on this project to:
1) Move the turbines to a different location. Unfortunately, the current proposed location puts the turbines right in the path of migrating songbirds that get caught up offshore overnight in spring and fall. The Gulf of Maine is vast and there are many other options that would have much less of an impact.
2) Minimize the height of the turbines.
3) The type of lighting used can make a significant difference in how nocturnally migrating birds are affected. The slow blinking red light has been shown to be one of the most deadly. There is promise, however, for pulsating and/or lights of a different color (see Mitigation section below).
4) The only effective form of mitigation is actually curtailing the turbine blades during peak migration (Arnett and May 2016). If the wind industry were really concerned about the fate of our ecologically important birds, they should turn off their turbines when large concentrations of birds are present.
- Offshore wind power needs to be connected to the grid. Underwater cables eventually need to reach land, and when they do, they are almost invariably raised on lines (as opposed to buried) that have their own consequences. Additional habitat fragmentation occurs as new corridors are cut or existing corridors or widened. The footprint of all industrial-scale development reaches far beyond the footprint of the actual electricity-generating equipment. Therefore, the direct and indirect effects of all infrastructure needs to be considered in order to fully identify and understand cumulative effects (Smith and Dyer, 2016).
- Overhead powerlines themselves have an ecological consequence, as many birds – especially raptors including locally-beloved Ospreys and Bald Eagles, and waterfowl (important regionally for birding and for hunters) – are susceptible to collisions that result in further, often unquantified, mortality in addition to the actual wind turbines themselves (Loss et al 2015). In the case of high-tension lines from grid-scale development, the overhead shield wires that are used for protection from lightning can be especially hazardous, and particularly so in conditions such as dense fog which is so common along the Maine coast.
- However, recent research has shown that even when powerlines that rise above forest canopy height and cross major migration pathways, well-marked shield wires can significantly reduce collisions, at least diurnally during clear visibility, when most of migration occurs for raptors in particular. (Luzenski et al, 2016).
- Therefore, we call on the project to:
- Avoid additional forest fragmentation and habitat loss by minimizing development beyond existing transmission corridors.
- Avoid habitats that concentrate birds that are most likely to collide with transmission lines. Since waterbirds are particularly susceptible to collisions. wetlands and other aquatic habitats should be avoided as much as possible. See Smith and Dwyer 2016).
- Mitigate any additional loss of wildlife habitat from creation or expansion of corridors.
- And most importantly, require that ALL new wires (especially shield wires) associated with this project be marked thoroughly with visual markers such as “Swan Flight Diverters” (Preformed Line Products, Cleveland, Ohio) especially near wetlands, water crossings, and other avian concentration points.
- “Existing gray literature, much of which is held by private companies, would likely shed additional light on the direct and indirect effects of renewable energy infrastructures. This, increased public availability of privately funded data is urgently needed” (Loss 2016; Smith and Dwyer 2016).
- Commonly, site-specific study results are used, post-construction, to show little or no deleterious effects on birds. Aside from the fact that finding dead birds is inherently difficult due to scavenging and, in the case of offshore sites, the disappearance of evidence, many of the cited studies are not peer-reviewed. Nor are the companies responsible required to release their data. In fact, at least two developers have sued to keep their data secret from the public (ABC 2016). While we believe that federal law should require that these data be collected by third party, independent experts using standardized methods, the only place this is currently done is in Hawaii (Hutchins 2016). However, Aqua Ventus should voluntarily do so to contribute to our collective knowledge of what works or doesn’t when it comes to such projects.
- Therefore, we call on this project to:
- Make its processes (i.e. how these turbines were erected, their structures, height, etc.) known to any entities who request such information
- Make public any deleterious impacts that this project has on wildlife, especially any mortality data that becomes evident, either anecdotally or through scientific study, especially using radar or acoustic monitoring.
Sharing these data, good or bad, can only make the wind energy cause stronger. At the very least it is good public relations, but more significantly it will aid in the further study of how offshore wind energy can be implemented with the lowest possible impact and the biggest energy gains. In the end that is presumably what everyone wants.
- “Mitigation typically follows what is now a well-established hierarchy described by numerous authors (Kiesecker et al. 2010, 2011a, Jakle 2012, Hayes 2014, May 2016). This hierarchy typically involves avoidance of high-risk sites during planning of wind-turbine facilities, followed by minimization measures during operations, and compensating for unforeseen or unavoidable impacts through compensatory measures (often called biological offsets; Kiesecker et al. 2010, 2011a; Cole and Dahl 2013).” (Arnett and May, 2016) Since this project is already in the planning stages, we are past the avoidance stage. Therefore, we offer suggestions for minimizing mortality during operation.
- Operation curtailment: This is “one of the only mitigation approaches proven effective at reducing wildlife mortality” (Arnett & May, 2016). Temporarily shutting down the turbines during high-risk time periods or weather conditions can reduce bird mortality. This can be done selectively to also minimize effects on energy production (deLucas et al, 2010). We have the capability to use weather radar and weather forecasts to get a good idea of when there will be a heavy movement of migrants.
- Visual deterrents: The type of lighting used has different effects on nocturnally migrating birds. Pulsating lights or other wavelengths (i.e. blue or green) may reduce mortality at turbines (Poot et al, 2008; Johnson et al, 2007). Painting 1 blade a different color (W. Hodos, National Renewable Energy Lab, unpublished data) or even using a UV-reflective paint (D. Young, Western Ecosystems Technology, unpublished data) can make the turbines more visible to diurnally migrating birds.
- Auditory deterrents: Ultrasonic auditory deterrents hold potential for reducing bat mortality at turbines, but this technology requires further study (Arnett & May, 2016).
- As only an absolute last resort, mitigate the avian mortality by offsetting mortality from other sources, protecting and enhancing key habitat, etc.
In closing, we firmly believe that these turbines should not be placed off of Monhegan Island, especially because of the threat they pose to migratory birds. However, if this offshore wind energy pilot project is to go forward, it offers an opportunity to expand our collective knowledge of how energy can be generated in a way that minimizes its unintended impacts. Much can be learned from this if a sincere effort is invested to implement new and developing technologies that can be used in forthcoming projects throughout the world. The preliminary research is out there, but there is still so much to be tested and quantified.
The references we used are simply a starting point and we urge Aqua Ventus to delve further into the research.
Derek and Jeannette Lovitch
Freeport Wild Bird Supply
ABC. 2016. Wind energy company sues to keep bird kill data out of public hands. https://abcbirds.org/article/wind-energy-company-sues-keep-bird-kill-data-publics-hands/
Arnett, E. B. & R.F. May. 2016. Mitigating wind energy impacts on wildlife: Approaches for multiple taxa. Human–Wildlife Interactions 10(1):28–41.
Dahl, E. L., R. May, T. Nygård, J. Åstrøm, and O. H. Diserud. 2015. Repowering Smøla wind power plant: an assessment of avian conflicts. Norwegian Institute for Nature Research, Trondheim, Norway.
de Lucas, M., M. Ferrer, M. J. Bechard, and A. R. Munoz. 2012. Griffon vulture mortality at wind farms in southern Spain: distribution of fatali- ties and active mitigation measures. Biological Conservation 147:184–189.
Hutchins, M. 2016. To protect birds from wind turbines: look to Hawaii’s approach. Bird Calls: https://abcbirds.org/to-protect-birds-and-bats-from-wind-turbines-adopt-hawaiis-approach/
Johnson, G. D. 2007. Use of data to develop mitigation measures for wind power development impacts to birds. Pages 241–257 in M. de Lucas, G. F. E. Janss, and M. Ferrer, editors. Birds and wind farms, risk assessment and mitigation. Servicios Informativos Ambientales/Quercus, Madrid, Spain.
Loss, S. R. 2016. Avian interactions with energy infrastructure in the context of other anthropogenic threats. The Condor. V.118: 424-432.
Loss, S. R. et al. 2013. Estimates of bird mortality mortality at wind farms in the contiguous United States. Biological Conservation. 168:201-209.
Loss, S.R., Will, T., and Marra, P.P. 2015. Refining estimates of bird collision and electrocution mortality at power lines in the United States. PLoS ONE 9(7): e101565. doi:10.1371/journal.pone.0101565.
Luzenksi, et al. 2016. Collision Avoidance by migrating raptors encountering a new electric power transmission line. The Condor. V.118: 402-410.
Poot, H. 2008. Green light for nocturnally migrating birds. Ecology and Society 13:47.
Smallwood, K. S., and B. Karas. 2009. Avian and bat fatality rates at old-generation and re- powered wind turbines in California. Journal of Wildlife Management 73:1062–1071.
Smith, Jennifer A and James F. Dwyer. 2016. Avian interactions with renewable energy infrastructure: An update. The Condor. V.118: 411-423.