Docket 7156: Petiton of UPC Wind for a CPG
Re: Post construction bird and bat fatality study at the Maple Ridge wind facility on the Tug Hill Plateau, Lowville, NY – 2006
March 26, 2007
Dear Ms. Hudson,
The attached, recently released, report may be of interest to the board.
Please note that the study began from mid to late July, omitted the Spring migration and early Summer (p.8), did not search high grass (p.18) or trees, and did not count incidental kills, which were described as kills that were found but not attributed to turbines. These incidental kills amounted to 10.9% of the total for birds, and 15.1% of the total for bats (p.28). In spite of this, mortality for birds and bats over the four months of the study was estimated to be from 3000 to 6100. Much higher than had been predicted in preconstruction studies.
Despite the fact that only 57% of the bat carcasses found had been processed, the report declared that none of species found were rare or endangered (p.54) or [their losses] “biologically significant”.
Impacts on forested ridge lines with wetlands could be higher than at Maple Ridge. The report states on page 54, “turbines nearer to wetlands are likely to be more involved in greater number of collisions of bats than turbines farther from wetlands”, and that taller towers with larger rotor swept areas, as proposed on this project, would increase fatalities.
This and other post construction studies in W VA and Tenn demonstrate that wind turbines on NE ridge lines are an undue adverse affect on birds and bats, difficult, if not impossible to mitigate.
The ANR failed to mention the January 3, 2007 USFWS letter, critical of UPC’s study, and have changed their initially serious concerns about the project to a stipulation for yet another post construction study that is to rely on UPC’s good graces and bogus consultants and to which a high mortality is assured.
Further comments not sent in above letter: The study was done by Curry and Kerlinger, wind industry whores who made every attempt to down play the result.
Calculating the kills on a per kilowatt basis using the total installed megawatt capacity or nameplate rating p.54 is meaningless. Using rotor diameter and swept area would be make for better comparisons between existing facilities.
Comparing communication tower fatalities to turbine fatalities p.54 is misleading and irrelevant, and a common technique used by developers.