Champaign County Wind received an email about an upcoming deadline and we are asking you, as our friends and neighbors, to consider submitting a comment on Everpower's plan to mitigate the environmental impacts of installing their turbines. The fact is that, with reduced bat populations, pests and insects will increase and it is estimated that Champaign County Farmers will have to spend an additional $12 million per year on pesticides. This money will devastate any potential income that farmers will gain from hosting a turbine on their land. Not to mention the increased health concerns as the environmental difficulties of increased pesticide use become more and more apparent.
The following information is from the email we received -- please feel free to spread the word:
"The deadline to comment on Everpower's Environmental Impact Statement and
Habitat Conservation Plan is this week on Thursday,
September 27th. Attached is Everpower's proposed Action Plan to mitigate
adverse impact on wildlife, and specifically the Endangered Indiana bat. To be
considered, comments filed with the U.S. Fish and Wildlife Service must be
received or postmarked by Thursday. WE
ARE ASKING YOU TO FILE A COMMENT.
USFWS has provided the following instructions for submitting comments:
Electronically:
Go
to the Federal eRulemaking
Portal: www.regulations.gov .
In the Search box, enter
FWS-R3- ES-2012-0036, which is the docket number
for this notice. Then, on the left side of
the screen, under
the Document
Type
heading, click on the Notices link to locate this document and submit a comment. (or you can just click on the box to
the right.)
By hard copy:
Submit
by U.S. mail or hand-delivery
to: Public Comments Processing, Attn: FWS-R3-ES-2012-0036; Division of Policy
and Directives Management; U.S. Fish and
Wildlife Service; 4401 N. Fairfax
Drive, MS 2042–PDM; Arlington, VA
22203.
Below
are some of the concerns we have identified but we urge you to put
your comments in
your
own words.
The biggest issue we see is that Everpower has chosen the least burdensome and
least protective plan for the Buckeye Wind project(s). Everpower argues that
more
stringent restrictions are not financially feasible,
but what they really mean is that they won’t make as much money under a more
stringent scenario. We
noted in an earlier newsletter to you that Boston University estimates the cost
to Champaign County farmers as $12 million annually in increased pesticide costs
from the loss of bats due to wind turbines and White Nose Syndrome.
We
request that the project be denied or, alternatively, that the Buckeye Wind
project operate under Alternative A (Maximally Restricted Operations)."
Draft Environmental Impact Study and Habitat Conservation
Plan
Buckeye
Wind Power Project, Champaign County, Ohio
Docket
No. FWS-R3-ES-2012-0036
Key
Issues for Comment
1.
The
proposed location of the Buckeye Wind facility is inappropriate because it poses
a significant risk of death or injury to Indiana Bats. The project is located
within a major migration route from a Priority 1 Hibernacula to summer roost
locations. The Draft EIS estimates that up to 5,800 Indiana bats migrate through
the Action Area each year.[1][1]
Furthermore, the summer population of Indiana bats in the Action Area is
estimated to be up to 2,271 bats. Maternity roosts are known to exist in the
Action Area, and numerous other undiscovered maternity roosts are likely to
exist.
2.
The
Draft EIS does not evaluate all reasonable alternative minimization measures,
such as:
a.
Appropriate
turbine siting setbacks: five miles from known capture-roost sites, ten miles
from hibernacula, and appropriate distances from riparian corridors as
determined based on available data.
b.
A
cut-in speed of 6.7 m/s without adjustment by season or habitat classification,
as proposed in Draft EIS for Invenergy's Beech Ridge Energy facility in West
Virginia.
c.
The
following minimization measures as recommended previously by the FWS to Babcock
& Brown that was planning a project in Logan
County:
i.
A
cut-in speed of 7 m/s, without adjustment for season or habitat
classification;
ii.
Construction
and operation of the facility in phases. Construct and operate 1/5 of total
planned turbines with post-construction mortality surveys conducted at all
turbines for 2 years before more turbines may be
constructed.
iii.
Ban
on forest clearing;
iv.
Siting
of turbines to avoid shadow flicker on known Indiana Bat maternity colony
locations.
3.
The
Draft EIS and HCP fail to demonstrate that proposed off-site habitat protection
will adequately mitigate actual losses of Indiana bats from the Buckeye Wind
project. The estimated benefits to the species from off-site habitat protection
are speculative. Even if such estimates were reliable, which they are not, the
proposed one-to-one mitigation ratio would not result in a net benefit to the
species.
4.
There
is presently inadequate data to evaluate the risk of harm to Indiana bats from
the Buckeye Wind project. For example, the HCP’s estimates of “take” from the
project are based on data from only 12 Indiana bats, compared to an estimated
summer population of up to 2,271 and an estimated migration of up to 5,800.
5.
The
spread of White Nose Syndrome in the Midwest Recovery Unit is a critical threat
to the survival of the Indiana bat which heightens the importance of protecting
the life of every Indiana bat. Buckeye Wind’s consultant claims that since it is
inevitable that the Indiana bat will be eliminated in the Midwest Recovery Unit,
it does not matter how many Indiana bats are killed by the Buckeye Wind project.
To the contrary, the possibility of saving the Indiana bat from extinction
depends on the protection of every individual member of the species. Using White
Nose Syndrome as an excuse to write off the species is contrary to the purpose
of the Endangered Species Act.
6.
The
proposed mortality monitoring program should include the following elements
required in the USFWS Draft Recommendations to Babcock &
Brown:
a.
Searchers
should utilize trained dogs for the searches;
b.
Area
under the turbines should be kept mowed;
c.
If
a carcass cannot be identified, DNA analysis is required to identify the
species;
d.
Unidentified
bats must be counted as Indiana bats;
e.
From
April 1 through August 15, any female Indiana bat carcass must be counted as two
Indiana bat fatalities.
In addition, because Buckeye Wind’s consultant did not
find any of the Indiana bats that were discovered in the Action Area, all
monitoring should be performed by a third party under contract with the FWS, but
funded by Buckeye Wind.
7.
Section
10 of the Endangered Species Act requires the applicant for an ITP to minimize
and mitigate take of endangered species to the maximum extent practicable.
Although the Draft EIS states in several places that more stringent protections
are not economically feasible, the record does not support that claim. To the
contrary, Buckeye Wind’s consultant merely claims that it will cost more money
to implement Alternative A or other heightened protections.
8.
In
addition to the proposed Incidental Take Permit (“ITP”) and Habitat Conservation
Plan (“HCP”) for the Buckeye Wind facility, the Fish and Wildlife Service is
also currently considering an Incidental Take Permit and Habitat Conservation
Plan for the Beech Ridge Energy facility in West Virginia. The FWS is also
seeking comment on a proposed multi-species Midwest Energy HCP that would
establish a template for minimizing harm to endangered species from wind energy
developments in an eight-state region. The FWS should evaluate all of these
proposals—including the proposed Buckeye Wind ITP and HCP—as part of a single
program-wide Environmental Impact Statement, so that the Service may evaluate
public input regarding all of the proposals concurrently. Otherwise, the
approval of the Buckeye Wind ITP and HCP may set a precedent across the region
before the Service has fully evaluated the proposed Midwest Energy HCP and the
Beech Ridge ITP and HCP.
9.
Conclusion:
For all the above reasons, the Preferred Alternative poses an unacceptable risk
to the Indiana bat and other species. U.S. Fish and Wildlife Service should
select the No Action alternative and deny the requested ITP. In the alternative,
the U.S. Fish and Wildlife Service should require that the Buckeye Wind project
operate under Alternative A (Maximally Restricted Operations).
[1][1] The Action Area is described on pages 1-3 (a map
depicting the area) and 4-1 (describing its boundaries) of the Proposed Habitat
Conservation Plan.