United statesDepartment of the Interior
Narrox¿l- P¿nx SBnvrcB CapeCod National Seashore 99 MarconiSite Road -Weiifleet, t{[At2667 i s08.349.3785 508.349.9052Fax IN REPLYREFERTO: toL I
May 8, 2008
Dear ftrferestedParfY: electric optionsfor anupg3d9 of thepresent deteriorating underground we havebeen examining Assessment arH"*idtã;åil;;"h f*ifiiiei in Provincetown.An Environmental supptyline preparedin accordarrcewitLr înåñ"riåî"r Environmenturïãhrve"t NE?-{) hasbeen iË""tit.ñ Pres.ervatio" (l'{É{PA)to Há ñffi;;Ë;""fuenral policy Act anJtÉ NatiànalHístoric +"t includingnatural and cultural evaluatethe impacts of the project q; humanenvironment, 9" andcomment on theproject' resources,and provide an opporhrnityf"iïftt p"Ulic to review p,o19-rto. t{e document,there are three altematives for providingelectric As discussedin the 7'5 kW wind tfr, Ño Ã"i¡á altemative,u .àtnUi"t¿ small-icaleland-based beachfacilities: preferredArtemative}, or a 10kw a,,dz.64kw soiarphotovortai" ,yrå- turbine {riemali-ve.(tire electricline replacementwas solarphotovoltaic letteáative Two).Undèrground consiäeredbut rejected"tlt;lt;ativeas an altemative' Seashore'99 Marconi Site Commentscan be sentto the Superintendent,Cape Çg^dfational 349-3785,Fax:(508) 349-9052 or Road,Wellfleer, rur*ru"tt"r erc)ozsøLirr.prtoirr: (50s) park pllnmng.websiteat emaii at [email protected],or directly oì,tftê periodbègms today' May 8' 2008' and hfip:llparþlanning.nps.gov.A 30-daypublic comment closeson June 7,2008. andyour interestin Thank you for yo'*r consideraticnof this en-''konmentalassessment' ;J r"ppíValternãtives for the Hening CoveBeach facilities' "l;;t Sincerely, rtt-" GeorgeIåE. Price,Jr. Superintendent Envi ron mental Assessment
Electrical SUPPlY for Herring Cove Beach Facilities
May2008
CapeCod NationalSeash ore
99 MarconiSite Rd. Wellfleet,MA 02667 (508)349-3785 EnvíronmentalAs s es sment Electrical Supplyfor Herríng Cove Beach Facílítíes
TABLE OF CONTENTS
PageNumber
1.0 INTRODUCTION...... 4 1.1 PURPOSEAND NEED...... 4 T.2 PARKSIGNIFICANCE...... ,..7
2.0 ALTERNATIVES...... ,7 2.1 NO ACTIONALTERNATTVE...... 7 2.2 PREFERREDALTERNATME: WTND AND SOLARCOMBINED...... 8 2.3 ALTERNATIVETWO: SOLARONLY...... 11 2.4 ALTERNATTVESCONSIDERED, BUT REJECTED ...... 11 2.5 ENVIRONMENTALLYPREFERREDALTERNATIVE. ....,..12
3.0 AFFECTEDENVIRONMENT .....,....12 3.1 NATURALRESOURCES ...... 13 3.1.1 WATERRESOURCES...... 13 3.r.2 GEOLOGYANDSOILS ...... 13 (r9 3.1.3 VEGETATION...... 14 3.1..4WILDLIFE ...... r4 3.1.5 AIRQUAUTY...... 15 3.2 SIIRROI-INDINGCOMMUNITY ...... 15 3.3 PUBLICUSE ...... 16 3.4 PARKMANAGEMENT, OPERATIONS, AND PUBLICSAFETY..,...... 16 3.5 CIILTI.IRALRESOURCES ...... 16
4.0 ENVIRONMENTALCONSEQUENCES ...... 11 4.T NO ACTIONALTERNATIVE ...... 19 4.1.1 IMPACTONNATURALRESOURCES...... 19 4.1.2 SURROUNDINGCOMMUNITY '...... i9 4.T.3 IMPACTONPUBLICUSEANDACCESS...... 19 4.T.4 IMPACTON PARKMANAGEMENT AND OPERATIONS...... 20 4.1.5 IMPACTON CULTURAI RESOURCES...... 20 4.1.6 CUMULATIVEIMPACTS ...... "20 4.2 ALTERNATIVE ONE,PREFERRED ALTERNATIVE: WIND AND SOLAR COMBINED...... 2r 4.2.1 IMPACTON NATI.JRAL RESOIIRCES . ...,...21 4.2.2 IMPACTON SURROLTNDINGCOMMLINITY ...... 22 4.2.3 IMPACTON PI]BLIC USE AND ACCESS...... 23 4.2.4 IMPACTON PARKMANAGEMENT AND OPERATIONS...... 23 4.2.5 IMPACTON CULTI-]RAIRESOURCES ...... 24 4.2.6 CTIMULATIVEIMPACTS ...... 24 4.3 ALTERNATIVETWO: SOLAROPTION ONLY ...-'...25 4.3.1 IMPACTONNATURALRESOURCES...... 25 4.3.2 IMPACTON SURROTINDINGCOMMLINITY ...... 25
page 2 EnvironmentalAs s es sment ElectricalSupply for Herring CoveBeach Facilities 4.3.3 IMPACTON PI]BLIC USE AND ACCESS ...... 25 4.3.4 IMPACTON PARKMANAGEMENT AND OPERATIONS...... 25 4.3.5 IMPACTON CULTI.IRAIRESOURCES ...... 26 4.3.6 CUMULATTVEIMPACTS ...... 26
5.0 CONSULATATIONAND COORDINATION...... 26 5.1 SUMMARYOF PUBLIC INVOLVEMENT ...... '26 5.2 CONSULTATIONWITH AGENCIESAND ORGANIZATIONS...... 21 5.3 RELATIONSHIPTO OTHERPLANNING EFFORTS . . . ' ' ...... 28
6.0 COMPLIANCEWITH APPLICABLELAWS AND REGULATIONS ...... 30 6.0.1 FEDERAIREGULATIONS " ....'30 6.0.2 STATEREGULATIONS .....33
LIST OF PREPARERSAND REVIEWERS...... 34
APPENDIX AppendixA- HerringCove Wind TurbineAdaptive Management Plan .....35
LIST OF FIGURES Figure1-1 Location Map. " """ '6 Figure2-1 HerringCove Bath House- Possible Arrangement for RoofMounted SolarPV Array """"""""""10 Figure3-1 Herring Cove Beach Facilities and Proposed Project Sites ...... '38
page 3 EnvironmentalAs s es sment Electricøl Supplyfor Heting CoveBeach Facilities 1.0 INTRODUCTION
SUMMARY
The purposeof this Environmental Assessment(EA) is to addressthe need to upgradethe present deterioratingunderground electric supply line at Herring Cove Beach facilities at Cape Cod National Seashore(CCNS). The current supply line extendsapproximately two miles from Provincetown and is in need of direct replacementor provision of an alternate meansof electrical supply.
CCNS is under the mandateof Executive Order 13423,(Strengthening Federal Environmental, Energy, and TransportationManagement), requiring federal agenciesto "lead by examplein advancingthe nation's energysecurity and environmentalperformance" by achieving a number of goals, including increasedpurchases of renewablepower sourcesand increasedusage of renewablepower. Potential alternativesto direct line replacementinclude a switch to the use of a small scale stand-alonerenewable energy application such as solar panels,wind power, or a combination. This EA will examinethe National Park Service (IVPS)preferred alternativein addition to one other action alternativeand the no action alternative.
1.1 PURPOSEAND NEED:
The park needsto providereliable electricalpower to Herring Cove facilities,maximizing use of renewableand non-greenhousegas producing energy technologies where possible. The purposeof this project is to remedy the ongoing deteriorationof the electrical supply to Herring Cove in a mannerthat maximizes use of renewableand non-greenhousegas producingtechnologies.
The facilities at Herring Cove Beachincorporate a two storybath house,a snackbar located next to the bath house,and a fee booth locatedat the entranceto the parking lot. Currently, there are also eight traffrc lights located on Route 6 at the entranceto the beach.These lights are to be removed within the next few yearswhen the intersectionis better reconfiguredfor safety. The main sectionof the bath houseis usedby lifeguards,and there are restroomand changing room areason either end of the building which are open for public use.
The presentelectric supply line for Herring Cove Beach startsin east Provincetownand extendsunderground along Moors Road from a utility pole approximately two miles to the site.This supply line was installedover 30 yearsago andhas deteriorated to the point that electric service is frequently intemrpted from failures in the line. The line terminatesat a pad-mountedtransformer located on site nearthe bathhouse, and branchesto threeseparate meters.The electricitysent to the site is singlephase and 1201240V'.The currentpower line posesa potentialsafety threat to visitors and staff andlora disruptionin servicesin the event of an electricalfire. The needfor consideringalternatives is necessary.
' AntaresGroup Incorporated, 2007.
page 4 I i I EnvironmentalAs s es sment Electrícal Supplyfor Herring CoveBeach Facilíties
Two of the electric metersare locatedon the rear exterior wall of the bath house building (on the side of the facility facing away from the beach) and provide service for the bath house and the snack bar. From these meters,electric service is branchedto the electrical system for eachbuilding. The third meter is locatedin the field to the northeastof the bath house.This meter servicesthe fee booth and traffic lights.
An energy audit revealeda significant potential for energy conservationmeasures to reduce the overall capital and operational costsfor any ofthe alternativesundertaken for this project, as the most cost-effectivemethod for designinga remote power systemis to reduce the power consumptionas much as possible. The site visit revealedthe presenceof many out-of- date appliancessuch as fluorescent lights, refrigerators,upright freezers,chest freezers, electric grills, and a 52 gallon lot water heaterthat could be replacedwith newer more efficient models or equipment.z Itis anticipatedthat over time, the existing applianceswill be replaced with energy-efÍicient and gasmodels.
2 Antares Group Incorp orated,2007 .
page 5 EnvironmentalAs s es s ment Electrtcal Supplyfor Herring CoveBeach Facilitíes PROVINCELANDS NG COVE VISITOR ES
+r$i .i! FIGURE1-1 Location Map- Herring Cove BeachFacilities in relationto Lower Cape Cod, Massachusetts
ITE &
f I \ \
CHATHAM+
page 6 EnvironmentalAs s essment Electrical Supplyfor Herring CoveBeach Facilities I.2 PARK SIGNIFICANCE
CCNS was establishedto protect the outer portion of Cape Cod, from Chathamto Provincetown. As the largest glacial peninsulain the world, Cape Cod is a striking geographic feature that extendswell out into the Atlantic Ocean.One of its outstanding életn"nts is the Great Beach, a long, unintemrptednatural beach.CCNS also containsa variety of physiogfaphic features- a mosaic of landscapesand their accompanyingflora and fauna that is unique in its combination and diversity. This includes habitat for stateand federally-protectãdspecies and globally rare plant communities. In the national seashore,the relationship of the land to the wind, waves,tides, and rain, remain largely unaffectedby developmørt, so that it is easy to observethe actions of natural elementsand their affect on the land. However, undisturbedprehistoric archeologicalsites also documentthe early humanswith nature on the Cape -huu"presence of people on Cape Cod. In fact, the interactionsof got. ott foì thousandsof years.Centuries of continuoushuman occupation have resultèd in the developmentof occupations,folkways and pastimesthat have given us some of the nation's most compellingstories.
Becauseof the Cape's prominent position in the Atlantic Ocean,it has been a key landmark for explorers and mariners. The Pilgrims made their first landfall and createdthe Mayflower Compãct here. The surge in settlementthat followed featureda dynamic whaling and fishing índustry,as well as a long and famoustradition of shell fishing. CapeCod's namereflects this heiitage. The many iighthons.r, lifesaving and Coast Guard stations that dot the Cape reflect this heritageas well. In addition,because of the Cape'slocation, it was the site of many communicãtiottr milestones,including the French trans-Atlantic cable and the first two-ïay ffans-Atlanticwireless communication for the U.S., sentand receivedby Guglielmo Marconi in 1903. The beauty,sense of solitudeand other aestheticvalues of the Capehave createdan intense affection felt by residentsof the Northeast,who have come here for inspiration and renewal for more than 100 years. This includes a longstanding tradition of use of the area by artists and writers including Edward Hooper, Mark Rothko, Jackson Pollack, John Dos Passos,Mary McCarthy, and Henry David Thoreau. At present, sunbathing,ocean swimming and sport fishing are also apart of this interactive relationship. As time góes by, the relatively undisturbedcharacter of the park so close to densely populated urban areasis becoming more and more precious.
2.0 ALTERNATTVES
2.I NO ACTION ALTERNATIVE
Under the No Action Alternative,the existingelectrical supply line would not be replaced, and no renewableenergy application would be installedto supply electricalneeds of Herring Cove Beach facilities. Ífr.i-otttittred electricalservice would be dependenton the capability of the line to provide power. Over time, the existingappliances would be replacedwith energy-efficient and gas models.
page 7 Enviro nm ent al As s e s s ment Electrical Supplyfor Herring CoveBeach Facilities
2.2 ALTERNATTVE ONE, PREFERRED ALTERNATIVE: WIND AND SOLAR COMBINED
This option would entail installationof a I0.l kilowatt Windand Solar Photovoltaic(PV) Hybrid systemwith a 2.64 kw solarPV a'rray,7.5kw wind turbine,8.5 kv/ Liquid Petroleum Gas generatorsetup (LPG genset), 11 kW inverter, and 84 kWh battery storage. The systemis basedon a packagedsystem offered by Bergey windpower Company, Norman, Oklahoma (with severalcertified dealersin Massachusetts).The small-scalewind turbine would be approximately 75 feet in height with22 foot diameterblades, for an overall elevation of 91 feet above sea level. The land-based,non-commercial turbine would not have lights or guy wires.
The total estimatedinstalled cost for this systemand other required componentsto achieve the requiredobjectives of this projectwould be approximately$125,000. Significant reductions in installed costs are possiblebecause this calculationwas made using the highest estimatesfor wind tower installationcosts.
Based on performanceand economicmodeling, this systemresults in a mid-ranged2}-year life-cycle cost operation(about $159,000), but would supplyfrom 85% to 97%oof the existing requiredpower for the site from a renewableresource. This wide rangeresultsfrom the lack of site-specificwind resourcedata. Acítal performanceis expectedto be towards the high side of this rangedue to the amplewind in this coastallocation.
It should be noted that sizing (and therefore the costs)for this systemare basedon an existingpackaged system and havenot beenoptimized across all availablewind turbines. It is possiblethat the installedcosts for a smallerwind/solar/genset hybrid system,which could provide avery largefraction of this site's power from renewableresources, could be significantlylower than what hasbeen estimated at this time.r In addition,it doesnot take into accountthat existingappliances would be replacedwith energy-efficientand gasmodels.
During a site visit by consulting engineers and economists,Antares Group Incorporated, possible solar affay locations were investigated. There are many considerationsin determining the best location for a solar anay. Some of these considerationsinclude: minimizing shading,isolation to avoid vandalismor safety risks, suffrcient area to hold a solar PV systemsized to meet the electric load, and mounting requirementsto allow south facing solarPV panel orientation. Three locationswere considered:the parking lot, the sand dune directly to the north of the bath house,and the upper-storyroof of the bath house.
Although the parking lot area and the sand dune to the north provide larger areasto place modules,the bathhouseroof was consideredas the most appropriatelocation for the solarPV system.There are little shadingconcerns on the roof and the systemwould be adequately isolatedto avoid any concernsassociated with vandalism. The horizontalroof structurewill provide easyinstallation of solarPV panels,whereas with the other locations,structures will have to be built to support the panels. There are a variety of mounting systems that are
' Antares Group Incorp orated, 2007.
page 8 EnvíronmentalAs sessment Electrical Supplyfor Herring Cove Beach Facilities designedfor horizontal rooß. With a roof-mounted system, proximify to the control center will be minimized since it is most tikely that controlswill be housedin the bath house. This will help avertlosses in transmissionlines.
Dependingon the size of the solar PV system chosento be installed,various stepswould p.ihupr néed to be taken to be able to fit the entire system on the roof structure.One option õould involve installing solar PV panels horizontally on the roof to better take advantageof the area. Horizontal placement of panels, although less efficient, avoids extra spacing necessaryto avoid shaãingwhen panelsare tilted. The type of solar PV panel used could also affect the amount of area necessary. Amorphous silicon panels are the least efficient type of panel and therefore take up the most area. Monocrystalline solar PV panels are the most èfficient and use the smallest area. Also, the awnings on the east and west side of the bath house could be potential locations for panels. Based on calculations by Antares Group available on the roof and if need be on the east and west Incorporated,theie is ample space a awnings, to accommodateenough panels for the required size of solar PV system.
Severalsiting options were consideredfor the land-basedwind turbine. A rooftop installation was consideie¿,Uut the bathhousestructure is not structurally sound enoughto support a 6, turbine unit. Therefore a location 35 feet from the building was determinedto be close enoughto provide neededpower, without significanttransmission line loss,while far enough from the tuitaing to be affècted by the wind turbulence.In the event of power loss resulting from severeweather conditions, the aforementionedbattery storagewould supply electricity to the site. If the wind and solar systemsare not operationalfor any reasoll,the existing power line would be usedfor backupuntil completeline failure, at which point bio-diesel and propaneoptions would be considered.
The wind turbine would be adaptively managedto ensurethat impacts to stateand federally listed speciesare avoided,and that impactsto batsand otherbird speciesare avoidedor minimized. The two phaseadaptive management plan is describedmore fully in Appendix A, and provides for: (I) preliminury asesstnent of bird use and the Herring Cove airspaceand, (II) subsequentmonitòring and possibleadjustment to wind turbine operations.
The adaptivemanagement plan would include a pre-constructionavian use assessmentand a post-constructionnionitoring protocoldeveloped in coordinationwith the U.S. Fish and Wit¿tif. Service (FV/S) and the MassachusettsNatural Heritage and EndangeredSpecies designedto collect programG\fHESP). The pre-constructionassessment would be information on the speciesof birds flying over and through the Herring Cove area. Monitoring would be designedto detectany bat or avian mortality resultingfrom collisions with the wind turbine. Monitoring resultswould be used to determinetime of year, time of day, and weather conditions during which the turbine would be shut down, if necessary,to .rrrur" that impactsto stateand federallylisted speciesare avoided,and that impactsto bats would and other bird speciesare avoidedor minimized.Inthis event,the existingpower line be usedfor backupuntil completeline failure, at which point bio-dieseland propaneoptions would be considered.
o Antares Group Incorporated, 2007.
page 9 i t.
I l 1 l I Environmental As s es sment Electrical Supplyfor Herring Cove Beach Facilities
FIGIJRE2-1 Herring CoveBath House- Possible Arrangement for Roof Mounted Solar PV Array
N r
page i0 EnvironmentalAs s es sment Electric'al Supplyfor Herring CoveBeach Facilities
2.3 ALTERNATIVE TWO: SOLAR ONLY
This alternativewould incorporatethe considerationsof solar PV siting and placement as discussedin Section 2.2, Altemative One, Wind and Solar Combined,with the following changein the proposedrenewable energy system'
Alternative Two would entail installation of solely the I0 kilowatt Solar PV Hybrid, with a 10.0kW solarPV aÍÍay,8.5 kW LPG genset,11 kW inverter;252kWhbattery storage.This systemis designedto maximízethe power supplied by solar panels,and the solar array is larger than the alray proposedin Alternative One.
The total estimatedinstalled cost for this systemand other required componentsto achieve the requiredobjectives of this projectwould be about$152,000 (or less). Basedon performanceand economic modeling, this systemresults in the highest 2}-year life-cycle òostoperation (about $206,000) of any of the remotepower systemoptions considered, but would supply about 95o/oof the site's power needsfrom solar panels. The balance of the power would be providedby the aforementionedpropane (LPG) fueledgenset. All solarPV panels from this iystem will fit on the 2-story portion of the roof of the bath house building, but only if they are mounted flat or with a very slight angle.
If the solarsystem is not operationalfor any reason,the existingpower line would be used for backupuntil completeline failure,at which point bio-dieseland propaneoptions would be considered.
2.4 ALTERNATIVE CONSIDERED, BUT REJECTED _UNDERGROUND ELECTRIC LINE REPLACEMENT
Under this alternative,the current electric power line-rur¡ring undergroundalong the side of Moors Roadto Herring Cove facilitieswould be replaced.This would entail ground disturbancealong Moors Road to reachthe facilities.Based on quotesprovided to the NPS from local contractors,upgrading the existingelectric supply line would cost about $200'000. Including costsfor purchasingpower from the utility basedon currentelectrical loads, Antares ôto.tp Incorporated estimatesthe 2O-yearlife-cycle operationcosts to the NPS for this option toie about $219,000. The installedcosts of the remotepov/er systems considered wodã be from $48,000to $121,000less expensive than upgradingthe existingpower line. On a21-yearlife cycle.costbasis, the remotepower systemswould be from $13,000to $95,000i.r, .tp"rrrive than upgradingthe existingpower line.s
In the interestof installingrenewable technologies where appropriateand given considerationof the variousimpacts examined in this EA, it was determinedthat evenwith the plannedreduction of currentenergy consumption loads, in a cost-benefitanalysis, undãrgroundelectric line replacementis not considereda cost-effectiveand environmentally beneficiallong-term solution.
5 AntaresGroup Incorporated,2007.
page 11 l
I EnvironmentalAs s es sment Electrical Supplyfor Herring CoveBeach Facilities Opportunitiesto showcaseand inform the public about alternativeenergy were taken into accountin this decision.Also consideredwere CCNS long-termgoals of increasingusage of renewabletechnologies in order meet the mandateof the abovementionedExecutive Order 13423and move towards being a Climate Friendly Park (CFP). The CFP Programis a collaborationof the National Park Serviceand the U.S. Environmental ProtectionAgency that providesnational parks with a systemapproach to manageclimate change.The program aims to provide national parks with comprehensivesupport to addressclimate changeboth within park boundariesand the surroundingcommunity.
,< EI\IWRONMENTALLY PREFERREDALTERNATTVE
In accordancewith the NPS DO-I2, the NPS is required to identiff the "environmentally prefened alternative" in all environmentaldocuments, including EAs. The environmentally preferredalternative is determinedby applying the criteria suggestedin NEPA, which is guided by the Council on Environmental Qualify (CEQ). The CEQ provides direction that the environmentallypreferable alternative is the alternativethat will promote the national environmentalpolicy as expressedin Section 101 of NEPA. Generally,the criteria mean the environmentally-preferablealternative is the alternativethat causesthe least damageto the biologicaland physical environment and that bestprotects, preserves, and enhanceshistoric, cultural,and natural resources (Federal Register, 1981).
As consideredin this EA, the environmentallypreferred alternativeis Alternative Two, the solar only option.None of the alternativeswould causeadverse cumulative impacts upon historic or cultural resources.Under Alternatives One and Two, use of renewableand non- greenhousegas producing technologieswould have moderate,long-term beneficial impacts to public use and park operations.Due to the logistically complementarynature of wind and solar,interpretive opporhrnities of usingboth technologies,and the provisionsin the adaptive managementplan describedin Appendix A andunder Section2.2, a hybrid systemis not anticipatedto be environmentally detrimentaland is consideredthe NPS Preferred Alternative, However,Alternative Two, the solaroption only, would havea lesserchance of impactto the biological andphysical environment because it is a rooftop installationand would require lessground disturbanceand no adaptivemanagement planning.
3.0 AT'FECTED ENVIRONMENT
This chapterpresents the relevantbaseline resource components of the existingenvironment. The environmentalresources that would be affectedby the alternativesconsidered in this EA are described,including naturalresources, culfural resources, public use,the surrounding communify,and the nationalseashore management and operations.This chapterdoes not presentthe effectsofthese alternatives;these effects are describedin Section4, EnvironmentalConsequences.
page 12 EnvironmentalAs s es sment Electrical Supplyfor Herring CoveBeach Facílitíes
3.1 NATURAL RESOIJRCES
3.1.1 WATER RESOT]RCES
Cape Cod National Seashorehas a wide variety of marine and fresh water resourcesformed by the geological events that created the landmass of Cape Cod. These diverse water ,ãrour".i are often interrelated, and each is an integral part of the ecology, history, and beauty of Cape Cod. The area's ecosystems consist of various marine, freshwater, and ponds, terrestrial areasincluding beaches,sand spits, tidal flats, salt marshes,swamps' kettle scrub oak forests,dunesJand plain grasslands,amongst others6.
The entire layer or zone of fresh water underlying the Cape is referred to as an aquifer' Within this single Cape-wideaquifer are six separatelenses of groundwater,four of which underlie parts of the national seashore.Tidal rivers that cut acrossthe Capehydro geologicfuly separatethese lenses from one another.From north to south, they are the is Þitgtt-, pamet, Chequessett,and Nausetlenses. The freshwatercontained in theselenses vitãl to sustainingthe lifestyle and ecological resourcesof the Outer Cape. It is the Outer Cape'ssole sourðe of potablewater, as well asthe hydrologic sourcefor water dependent naturalresources (Cape Cod Commission1997).
The sourceof freshwaterto the aquifersof the Outer Capeis precipitation. A little lessthan half of this amount inf,rltratesthe ãquifer and rechargesthe groundwater system.Precipitation runoff is that is not rechargedto the aquifer evaporatesor is transpiredby plants. Surface percentage negligiblebecause of the highly permeablesoils of the Outer Cape.The greatest of thãrechargepasses slowfu throughthe aquiferand is dischargedinto the ocean.Every day, millionJof gallons of fresh groundwaterseep out of the ground directly into the ocean (câpe cod Planningand EconomicDevelopment commission, 1987).
Bay The potential wind turbine project site is approximately 300 feet eastof the Cape Cod be sited shorðlineat Herring Cove Ëeach,and the potentialsolar photovoltaic project would north of on the roof. The HatchesHarbor estuaryis approximately4 km (2.5 miles) to the are Herring Cove, and West End Marsh is about2.5 krfl (1.6 miles) to the south. There no nu-.rõ,r, ponds and dune slack wetlands farther eastof the project area.There.are project to wetlands in the immediate Herring Cove area.Thus, there is no potential for this further affect wetlands or marine water resources.Water resourcesmay be removed from considerationas an impact topic for this environmentalanalysis.
3.I.2 GEOLOGY AND SOILS
arederived The soils of CapeCod have beenclassified as excessivelydrained outwash and glacialtill, sand, from glacial outwashesand moraines.They vary in compositionand include of grur"i,interspersedlayers ofclay and silt, and scatteredlarge boulders.In severalareas from beach ih" Cup", dune deposiisoverlie ihe glacial soils.Many of thesedunes are formed material that was transportedinland by winds.
6 National Park Service.
page 13 Environmental As s es sment Electrical Supplyfor Herring CoveBeach Facilities
Herring Cove is at the westernend of the post-glacialportion of the Cape. This area consists of sandseroded from the bluffs in Truro and to the south, and transportedby wind and water to the north and west forming the hook at the Cape'stip. The sandin the Herring Cove area generally comesfrom the north, carried around the "race" at RacePoint, and transported southwardfeeding the beachesat W'oodEnd and Long Point.
None of the alternativeswould have an adverseimpact on the geological resourcesof CCNS. Solar panel installation would not involve removal of geological featuresor subsurface components.Replacement of the existing electrical line would involve digging in a previously disturbedarea. There would be a negligible amount of ground disturbance associatedwith the installation of the proposedturbine. Therefore,geological resourcesmay be dismissedas an impact topic for more detailed study.
3.1.3 VEGETATION
Immediately adjacentto the Atlantic Ocean,Hening Cove areavegetation is dominatedby American beachgrass(Ammophila breviligularø). Presently,no federally-listedrare plants have been identified in the proposedproject area,but the national seashore-widedistribution of 34 state-listedrare, threatened,or endangeredspecies is documented.Of these,the outer beaclris an available habitat to tluee rare plant species.They include sea lyme grass(Elymus mollis), seabeachknotweed (Polygonum glaucum), and oysterleaf(Mertensia marítima). Sea lyme grasshas been historically located on the foredune,usually among beachgrass. Seabeachknotweed has alsobeen historically found on the beachesof CapeCod.
3.I.4 WILDLIFE
A number of speciesof amphibiansand reptiles are found in the backdunehabitats behind Herring Cove and throughoutthe ProvinceLands. Theseinclude spring peepers, Fowler's toads,Eastern spadefoot toads (statethreatened), redbacked salamanders, black racers, Easternhog-nosed snakes, Eastem box turtles (statespecies of specialconcern), spotted turtles, painted turtles, and snappingturtles. Most prominently, the Easternspadefoot toad is a specialistof dry, sandyhabitat that breedsin shallow temporarywetlands. The Province Lands, with their abundanceof dune slack wetlands,provide an ideal landscapefor spadefoots,and supportsthe most significant known population of spadefoottoads in the NortheastUnited States(Cook 2005).
The beachesof lower Cape Cod provide important nesting and feeding habitat for a number of sensitivespecies including piping plovers(Charadríus melodus), which are federallyand statelisted as th¡eatened,and least and common terns(Sterna antillarum and S. hirundo), both of which are statelisted as speciesof specialconcern. The lower Cape'sbeaches, salt marshes,and estuarinewaters also provide important resting and feeding habitat for migratory speciesincluding the federally endangeredroseate tem (Sternadougalli), and severalshorebird species. The beachat Herring Cove is not usedby thesespecies. This is probablydue to the presenceof developedfacilities (parking areas, bathhouse, snack bar) alongthe length of the beach,disrupted sand dynamics due to pastpaving and seawall construction,and intensiverecreational use. While the beachat Herring Cove doesnot
page 14 EnvironmentalAss essment Electrical Supplyfor Herring CoveBeach Facilities provide habitat used by thesespecies, it is in the vicinity of areasof high habitat value. HatchesHarbor, which is about 4krn(2.5 miles) to the north, provides nesting, feeding, and staginghabitat for piping plovers. HatchesHarbor is also usedby other shorebirdsand terns during migation. West End marsh,which is about2.5krn(I.6 miles) to the south,is also usedby mìgrating shorebirdsand terns. And V/ood End/Long Point beach,starting about 8.5 km (5.-3miies) to ttre south and east,is also used by nestingplovers and migrating shorebirds and terns.
Backdunehabitats in this area supportmany speciesof terrestrial birds. The statethreatened northern harrier makes extensiveuse of the dunesand salt marshesfound throughout this areafor foraging, and the statethreatened vesper spalrow also utilizes backdunehabitats for nesting and in migration.
Mammals found in the beach,dune, and backdunehabitats of Provincetown and Truro coastal area area product of the habitatspresent. Because this landscapeis a mosaic of dune slack wetlands, standsof pitch pine and shrubs,native grasses,and open sand,it is used by many speciesof both marine and terrestrialmammals. These include coyote, red fox, ,ur"ôorr, striped skunk, long-tailed weasel,Eastern cottontail rabbit, white-tailed deer, and 4 smallermammals including variousspecies of rodent.Information about bats in this areais currently lacking.
The MassachusettsNatural HeritageAtlas, 12thEdition, publishedby NHESP in Octoberof 2006 identifies the Herring Cove areaas priority and estimatedhabitat for rare plant and wildlife species.Surveys have confirmed the presenceof the statelisted speciesdiscussed abovein the generalvicinity of the proposedproject.
3.1.s ArR QUALITY
The Clean Air Act of 1973,as amended,and associatedNPS policiesrequire NPS to protect air quality in parks.CCNS is classifiedas a ClassII areaunder the CleanAir Act. CCNS is within a non-attainmentarea for ozone, anareathat includes the entirety of the Commonwealth of Massachusetts.The primary local sourceof pollution at Herring Cove comes from emissionsgenerated by vehicles entering, exiting, and idling in the parking lot' As the parking lot capacity would not increaseunder any of the proposedalternatives, no increasèin emissionslevels is expectedas a consequenceof any of the coursesof action.
The statemay permit a moderateamount of air pollution as long as neither national ambient air quality stanãardsnor the maximum allowed increaseover establishedbaseline concentrationsis exceeded.As statedabove, the major air pollutantsoriginating in the seashoreare vehicle emissions(primarily hydrocarbons,carbon monoxide, and nitrogen oxide), most of which are generatedduring periods of high visitation (I'IPS,1999).
3.2 SURROUNDINGCOMMUNITY
The facilities at CCNS, dedicatedto public experienceas well as resourceand visitor protection, have a significant positive influence on the local economy,with statewideand
page 15 Environmental As s es sment Electrical Supplyfor Herring CoveBeach Facilities regional contributions.The quality of visitor experiencein the seashorehas contributed to regional statusas a destinationthat attractsout-of-state visitors and local residentsalike to enjoy the natural beauty ofthe area.
Herring Cove Beach is located at the most outer portion of the Cape Cod Peninsula in Provincetown, Massachusetts.None of the proposed alternatives introduce new adverse impacts to the surrounding community in the Hening Cove area.The proposedproject areais fully surroundedby park lands. There is no private land adjacent to the proposed wind or solarsite.
3.3 PUBLIC USE
CCNS was estimatedto have 4.3 million visits in 2007, including thoseby residentsand repeatvisitors. The national seashoreand adjacenttowns provide a wide variety of opportunitiesfor visitors and residentsto enjoy athletic, sporting, touring, and educational activities. CCNS has two visitor centers,two environmentaleducation centers, trails, picnic areas,historic buildings, cultural landscapes,and numerousbeach facilities available to the public, including Herring Cove beach,the areain question.
Most visitorsto CCNS come from the Northeast.However, all 50 States,plus the District of Columbia and Canada,were representedin a visitor survey, completedby the University of Vermont in 1994. Although there were 24 (including "other") activities in which visitors participateat CCNS, the primary activitiesinclude: 1) viewing scenery,2) sunbathing,3) swimming in the ocean,4) beachcombing,5) hiking, and 6) driving scenicroads. According to that survey, most visitors were highly supportiveof protecting the natural and historic resourcesof the seashore;most approvedof the currentbalance between public useand resourceprotection, and most felt that naturaland historic resources are being well preserved.
3.4 PARK MANAGEMENT, OPERATIONS, AND PUBLIC SAFETY
Herring Cove Beach facilities and servicesare describedin the introduction of this document. Parking lots throughout CCNS are open from 6 A.M. to midnight, darly,year-round.The park has developeda staff with significant expertisefor monitoring park resources,enforcing park rules, providing visitor servicesand education,and ensuringpublic safety. Unintemrpted and efficient park operationsat CCNS are vital to meetingthe NPS mission.
3.5 CULTURAL RESOURCES
There are no structures,archeological sites or cultural landscapescurrently eligible for or listed on the National Registerof Historic Placesin the direct vicinity of this project. In October 2004,NorthernEcological Associates, Inc. performeda PhaseI archeological investigationin advanceof the installationof 2 vault toilets and lift stationin the vicinity of this project area. They concludedthat no prehistoricor historic sitesor featurespotentially eligible for inclusionon the National Registerof Historic Placeswere locatedin the area.
page 16 EnvironmentalAs s es s ment Electrical Supptyfor Herring CoveBeach Facilities the The nearestNational Registerproperties are approximately 1 mile from the site outside End park boundary inthe town of Provincetown. V/ithin the park, the Race Point and Wood Lighthour"s áre both approximately| %miles from the site,and the Dune Shacksof the peãted Hills Bars Histõiic District is 2 miles distant. The Herring Cove Bathhouse,upon which the proposedsolar panelswould be placed, is currently not considereda historic the structure,but it trasn.u", b""n evaluated. It is anticipatedthat the park will evaluate Register structure in the next year and it could be determinedto be eligible for the National built of Historic places. Iiuilt in 1953,ítis over 50 yearsold and one of the first bathhouses by the Commonwealthof Massachusetts.
4.0 EIWIRONMENTAL CONSEQUENCES It is This sectiondescribes the environmentalconsequences associated with the alternatives. organízedbyimpact topics, which distill the issuesand concernspertaining to natural ,.Jo.rr"rr, pubhó ur", purkoperations, and cultural resources.NEPA requires consideration and of context, intensity und ¿utâtion of impacts, indirect impacts, cumulative impacts, resources measuresto mitigate for impacts. NPS policy also requiresthat "impairment" of be evaluatedin all environmental documents' intensity, General Definitions. The following definitionswere usedto evaluatethe context, duration, and cumulative nature of impacts associatedwith project altematives: region, Context is the setting within which an impact is analyzed,such as the affected intensity of society as a whole, tñe affected interests,ãnd/or a locality. In this EA, the of effects impacis are evaluatedwithin a local context, while the intensity of the contribution to õumulative impacts are evaluatedin a regional context.
Impact IntensitY
For this analysis,intensity, or level of the impact is defined as follows:
not measurableand Negligible- impact to the resourceor discipline is barely perceptibleand confined to a small area.
and is localized' Minor- impactto the resourceor disciplineis perceptibleand measurable
effect on the resourceor Moderate- impact is clearly detectableand could have appreciable discipline.
on the resourceor Major- impact would have a substantial,highly noticeableinfluence disciplineon a regionalscale.
Impact Duration
The duration of the impacts in this analysisis defined as follows:
page 17 EnvironmentalAs s essment Electrical Supplyfor Herring CoveBeach Facilities
Short term - when impacts occur only during treatmentor last less than one year; or
Long term - impactsthat last longer than one year.
Direct versusindirect impacts
The following definitions of direct and indirect impactswere usedin this evaluation:
Direct - an effect that is causedby an action and occursat the sametime and place.
Indirect - an effect that is causedby an action but is later in time or fartherremoved in distance,but still reasonablyforeseeable.
Cumulative Effects
The CEQ regulations,which implementNEPA, requireassessment of cumulativeimpacts in the decision-makingprocess for federalprojects. Cumulative impacts are defined as "the impact on the environmentwhich resultsfrom the incrementalimpact of the action when added to other past,present, and reasonablyforeseeable funre actionsregardless of what agency (federalor non-federal)or personundertakes such other actions" (40 CFR 1508.7).
IMPAIRMENT OF (PARK) RESOURCES OR VALUES
The 2001 NPS ManagementPolicies and otherpolicy guidancerequire analysis of potential effects to determineif actions would impair (park) resources.Initially, the National Park Servicewas establishedby its OrganicAct of 1916which chargedthe Service,as the Federal administrativebureau with the authorityand responsibility,for promotingand regulatingthe use of nationalparks, monuments and reservations, by meansand measures,to conservethe scenery,natural and historic objects and wild life therein as being the purpose [in part] for which eachpark, monument,and reservation[having nationally significant resourcevalues] was authorized.The GeneralAuthorities Act of 1970,as amendedin 1978,recognized such federal areasadministered by the National Park Service,as being a National Park System comprised of nationally significant resourcevalues, and reafÍirmed the conservationof those values to prevent their impairment, as provided for in the Service'sOrganic Act. National Park Service managersmust always seek ways to avoid or minimize to the greatestdegree practicableadverse impacts on park resourcesand values. However, the laws do give NPS managementdiscretion to allow impactsto park resourcesand valueswhen necessaryand appropriateto fulfill the purposesof a park, as long asthe impact doesnot constitute impairmentof the affectedresources and values.Although Congresshas given NPS managementdiscretion to allow certain impacts within parks, that discretion is limited by statutoryrequirement that the NPS must leavepark resourcesand valuesunimpaired, unless a particularlaw directly and specif,rcallyprovides otherwise. The prohibition of impairment includesimpacts that, in the professionaljudgment of the responsibleNPS manager,would harm the integrify of park resourcesor values,including opporfunitiesthat otherwisewould be presentfor the enjoymentof thoseresources or values. An impactto any park resourceor
page18 EnvíronmentalAs s es sment Electrical Supplyfor Hening CoveBeach Facilities value may constitute impairment. However, an impact would more likely constitute impairment to the extent it affects a resourceor value whose conservationis: o Necessaryto fulfill specific purposesidentified in the establishinglegislation or proclamationof the park; o Key to the natural or cultural integrify of the park or to opporfunities for enjoyment of the park; or
. Identified as a goal in the seashore'sMaster Plan or GeneralManagement Plan or other relevant NPS planning documents.
Impairment may result form NPS activities in managingthe park, visitor activities, or activities undertakenby concessionaires,contractors, and others operationin the park.
A determinationof impairment is made for eachalternative in each "Cumulative Impacts" sectionof this EA under "EnvironmentalConsequences."
4.1 NO ACTION ALTERNATTVE
4.I.I IMPACT ON NATURAL RESOURCES
Analysis. Therewould be no changeto the currentelecfrical service. The No Action alternativewould not affect soils,vegetation or wildlife or air quality.
Conclusion.Leaving the existingunderground line in placewould not result in new impacts to natural resources.
4.I.2 ST]RROUNDING COMMUNITY
Analysis. The deterioratedelectrical line at Herring Cove would continue to servethe bath housð,snack bar, fee booth facilities while experiencingfrequent intemrptions in service. There is no specific direct impact to the surrounding community associatedwith this of alternative.An indirect impaðt to the surroundingcommunity may be the consequences frequent reducedvisitation to the'Hèrring Cove site, due to the inconveniencein the caseof electric line failure as a short to long term adverseimpact on visitor experience'
may result Conclusion. Short and long term adverseimpacts to the surroundingcommunity from electric line failures.
4.I,3 IMPACT ON PUBLIC USE AND ACCESS
houseand Analysis. Recurringloss of electricitywill inconveniencevisitors using the bath line lasts, restroomfacilities. th"r" inconveniencescould continuelong-term if the electrical however, though operating inconsistently. Unexpectedand permanentfailure of the System,
page 19 EnvironmentalAss es s ment Electrical Supplyfor Herring Cove Beach Facilities
could resultin immediateclosure of the beachfacilities while the problemis resolved. This could tum away visitors and limit access,depending on how repairsare approached. Electricalfailure of the existingsystem could havemoderate to major impactson public use of the Herring Cove facilities.
Conclusion. The no-action alternativecould producethe long-term, indirect consequenceof turning visitors away who may be frustratedwith inconsistentservices.
4.I.4 IMPACT ON PARK MANAGEMENT AND OPERATIONS
Analysis. Park staff including rangers,lifeguards, fee booth operators,and snackbar concessionaires,are adverselyimpacted during unexpectedelectrical failures.Normal and safe operationof equipmentfor thesestaff membersand the traffrc lights leading to the beach are dependenton reliable electricity, not available with the current system. In the event of a power failure, the snack bar will indirectly suffer economically, as food storageand production will be impaired. Also, lifeguards who use the secondfloor of the bathhousefor their offices will be directly inconvenienced,as will the fee booth operators.An unexpected failure during peak visitor seasonwould requirê the park to divert significant time and resourcesto repairingthis problem.
Conclusion.The No Action alternativecould havemajor adverseimpacts on the operation and managementof Herring Cove facilities if repeatedelectrical outagescontinue to occur.
4.I.5 IMPACT ON CTJLTURAL RESOURCES
Analysis. The No Action Alternativeinvolves no new construction.There would be no historic propertiesaffected by this altemative.
Conclusion. No historic propertieswould be affectedby the No Action alternative.
4.I.6 CUMULATIVE IMPACTS
Under the No Action alternative,the existingelectrical supply line would not be replaced,no new constructionwould occur and facilitieswould not be changed.No renewableenergy applicationwould be installedto supplyelectrical needs of Herring Cove Beachfacilities. There would be no adverseimpacts upon natural or cultural resources.There would be potential long-term direct adverseimpacts upon public use, surroundingcommunity, and park managementand operations.However, this impactwould not constituteimpairment of oark resources.
page 20 EnvironmentalAs s es sment Electrical Supplyþr Herring CoveBeach Facilities
4.2 PNNTNRRED ALTERNATIVE: WIND AND SOLAR COMBINED
4,2.1 IMPACT ON NATTIRAL RESOURCES
Anatysis. The turbine proposedin the preferred alternativewould have no effect on rare plant speciesas no speciesof concernare in the project area.Vegetation would incur no ãdu"rrè impact frornthe installation of solar panels.Neither solar panels nor the wind turbine would have an adverseimpact upon marine mammals,terrestrial mammals other than bats, reptiles, or amphibians.
The use of renewableenergy technologieswould have a minor long-term beneficial impact on air quality as wind they would be non-greenhousegas emitting means of power generation.
1 been observedat a number of commercial-scalewind Direct impacts to birds and bats have l developmìnts (NWCC 2004). However, there is little information regarding the impacts of I small, singte ru-rbinewind installations. A study to assessavian mortality associatedwith a largerturbine (73.5 m (241ft) rotor tip height) at the MassachusettsMaritime Academy estimated 1.39 bird fatalities/yearresulting from collision with the turbine basedon the death of one laughinggull (Vliestra2007). This studyalso counted24,564 birds passingthough the turbine'saii spaceduring the four-monthtern nestingperiod in 2006. Of these,254 were terns which were abundantin the area,particularly foraging in the waters off the Academy during the chick rearingseason. Comparison of the numbersof terns flying throughthe rotor-iweptzonewhen the turbine bladeswere and were not spinning indicates that terns may avoià the turbine airspacewhen the bladesare rotating. No impacts to bats were detlcted. Very few bird mortalities and no bat mortalities have been detectedin association with a turbine (27 m (91 ft) rotor tip height) at Missisquoi National Wildlife Refuge in Vermont after th¡ee years of operatìon,and starlings have nestedin the structurebehind the rotor for the last fewnesting sãusonr(M. Sweeney,pers com). At the EasternNeck National Wildlife Refuge in Maryland, a total of 15 bird deathswere attributed to a turbine 18.3 meters (60 feei) tall over a three year period. Thirteen of thesewere European starlings which had nestedin the turbine structure. The other two mortalities were a bank swallow and acatbird. No effectsto batswere observed(Willis 2005)'
Based on the observationsof avian interactionswith other small, non-coÍlmercial, land- basedturbines at other sites, it appearsthat the potential for the Hening Cove turbine to have more than negligible impacts to birds is quite low, and the potential for impacts to bats would seemvirtually nonexistent. However, the habitatsand speciesin the vicinity of National Wildlife Refuge turbines are different than thosein the vicinity of Herring Cove, and althoughthe speciesof concernfor the Maritime Academy'sturbine are substantiallysimilar to Herãng Cove, the ecological setting is quite different. To ensurethat the turbine's impacts to birds and bats are minimãI, and that adverseeffects to stateand federally listed speciesare avoided, the preferred alternative incorporatesa two part adaptivemanagement strategy describedin Appendix A. The first part will focuson assessingbird use in the areaof the proposedturbine, and the secondpart integratesmonitoring into turbine managementto ènrur" that turbine operationsare modified or shut down if adverseeffects to stateor
page 21 EnvironmentalAs s essment Electrical Supplyfor Herring Cove Beach Facilities federally listed speciesappear likely, and well before any impacts to other speciesapproach the level of having an appreciableeffect. The adaptivemanagement plan includes continued and frequentcoordination with FWS andNHSP to ensurethose agencies'expertise is incorporatedinto review and interpretation of the data collected,and that those agencies concur with decisionsregarding turbine operations. As a result, direct impacts are anticipatedto be minor, and the project is not anticipatedto adverselyaffect stateor federally listedspecies.
It is projected that such small sized, land-basedturbines as the scaleproposed are not enough equipmentto form a long-term adverseeffect to migration paffernsor bird populations,thus indirect effects to birds and bats are anticipatedto be negligible.' The solar panelswould presentno adverseeffect to wildlife becauseof their stationaryposition atop the roof of the bathhouse.
Conclusion. The potential minor adverseimpacts to birds and bats would be limited by managingturbine operationsin responseto monitoring results.
4.2.2 IMPACT ON STJRROUNDINGCOMMUMTY
Analysis. The preferredalternative would provide an exampleof zero-emissionsource of electricity in the park. In addition to direct environmentalbenefits, the wind and solar alternativeswould result in indirect beneficial effect by showcasingand providing educationalinformation about renewable power opporfunities.
The proposedwind turbineis approximately11,510 feet (2.18miles) from the Provincetown Municipal Airport. It is not in the direct path of the airport runway over HatchesHarbor. Consultationwith the MassachusettsAeronautical Commissionon an airspacereview of the potential project confirms that the proposal doesnot conflict with stateaviation laws or regulations,and the FederalAviation Administration has been askedin December2007 for their findings regardingthe public use airport and navigation aid facilities as per Section 5.2 and a final determinationis pending. It is not anticipatedthat such a small wind turbine would have an adverseimpact on air traffic or safety,and would not be considered an airport obstruction.
Conclusion. Through the preferred altemative, there would be long term moderateto major beneficial impact to the community. It is not anticipatedthat such a small wind turbine would have an adverseimpact on air traffic or safety, and would not be consideredan airport obstruction.The combinationof both wind and solaris preferredin an effort to be most eff,rcientand demonstratingthe presenceof varied typesof renewablepower sources.
7 WoodsHole OceanographicInstitution Quissett Campus Pre-Construction Avian Surveys FinalReport,2007.
page 22 Environmental Ass es sment Electrical Supptyfor Herring CoveBeach Facilities
4.2.3 IMPACT ON PUBLIC USE AND ACCESS
Analysis. A combined wind and solar would provide educationalopporhrnities to the public surroundingcommunity, and thus would result in a long-term beneficial impact upon use. As issuesof sustainability becomeincreasingly acknowledged,visitors to the park could be drawn to the Herring Cove Beach to seewind and solar apparatusesin action.
The potential installation of wind and solar renewableenergy technologiesat_Herring Cove *o.rid have negligible adverseimpact on public use and accessduring the off-season installation. As all installations would be scheduledto occur when theseservices are closed for the season,there would be negligible impact on public use, aside from temporary closure of the Southparking lot.
Fee collection at the site begins on Memorial Day weekend,continues on weekendsonly and back to until the third week of Junelthen goesinto full-time operationsuntil Labor Day peak weekendoperations for the month of September.Installation would not occur during use and summer months, as this would result in ã major short-term adverseimpact on park access.For the pu{poseof construction,a small sectionof the parking lot couldbe access tg temporarily.opèdóff to ensurevisitor safetyfor a short duration.Once installed,full would be restored;no long-termadverse impacts would occur.
land-based There would be long-termminor visual impact from the presenceof the potential wind turbine. As thã turbine would be built in scalewith the existing environment,some impact. would find this to be an adverseimpact, while others would find it to be a beneficial
beneficial Conclusion.Having renewableenergy technologies on site could have long-term different impacts on public uie and accessdue to the presenceof reliable pov¿erfrom two types of renewabletechnologies.
4.2.4 IMPACT ON PARK MANAGEMENT AND OPERATIONS
park operations' Analysis. The proposedwind turbinewould havea short-termimpact on negligible As therewould-be post-construction bird and bat monitoring of the site to ensure areadaily' wildlife mortality, the park would needto schedulea staff member to survey the fee This task could be incórporatedinto the duties of park rangers,lifeguards, and/or poses collectorswho monitor ih" arearegularly for otherpurposes. Therefore, this a minor impact.
of energythat The combinedwind and solartechnologies would provide a reliable source expenseof would ensurethat the park doesnot have to anticipatethe negativeresults and have the power failures.A syståminvolving both solarPV panelsand a wind turbinewould resourcesis not complementarynature of solar and wind resources-when one of these (low resource), pleniiful, the oiher is often available.When it is either dark or overcast solar calm, solar it is often more windy. During warïn summerdays when the wind is relatively availability is often very high.ð
t Antares Group IncorPorated,2007
page 23 EnvironmentalAs s es sment Electrical Supplyfor Hercing CoveBeach Facilitíes
As discussedin Section2.2,there arecontingency plans for backuppower if necessary. There is an additional long-term moderatebeneficial impact upon park management,as increasingusage of renewabletechnologies aids the park in fulfilling the objective of preservationand stewardshipthrough using environmentallyconscious practices and educatingthe public, and meeting federal requirementsfor use of renewable energytechnologies.
Conclusion. The installation of solar and wind technologiesat Herring Cove would have long-term, moderatebeneficial impacts on park managementand operations.Despite the short-term direct adverseimpact of increaseddaily tasksfor some staff, the long-term impact upon park managementand operationswould beneficial due to the presenceof reliable power providedby renewabletechnologies.
4.2.5 IMPACT ON CIILTURAL RESOURCES
Analysis. There are currently no structures,archeological sites or cultural landscapeseligible for or listed on the National Registerin the directvicinity of this project. In October2004, NorthernEcological Associates, Inc. performeda PhaseI archeologicalinvestigation in advanceof the installation of 2 vault toilets and lift stationin the vicinity of this project area. They concludedthat no prehistoricor historicsites or featurespotentially eligible for inclusionon the National Registerof Historic Placeswere located in the area.
The Herring Cove Bathhouseis currently not considereda historic structure,but it has never been evaluated. It is anticipatedthat the park will evaluatethe structurein the next year and it could be determinedto be eligible for the NationalRegister of Historic Places.Built in i953, it is over 50 yearsold and one of the first bathhousesbuilt by the Commonwealthof Massachusetts.
Conclusion. Thereare no historic propertiesaffected for the proposedalternative.
4.2.6 CUMIILATIVE IMPACTS
There would be no adversecumulative impactsupon cultural resources.The overall impact of a varied renewableelectrical production systemwould have multiple benefits as described above upon public use, surrounding community, and park managementand operations.The adverseimpact of the wind turbine componentof this alternativeupon birds and bats is anticipatedto be minor sinceturbine operations would be managedin response to impact monitoring.
The combinedrenewable energies alternative is NPS preferredoption, as it adequately addressesthe electrical needsfor the facilities on site at the Herring Cove, offers interpretive opporfunitiesby using both technologies,and addressespotential natural resourceimpacts in the adaptivemanagement plan. Additionally, there would be no impairment to park resources expectedby this alternative.
page 24 E nvironmentalAs s es sment Electrical Supplyfor Herring CoveBeach Facilíties
4.3
4.3.1 IMPACT ON NATURAL RESOTIRCES
Analysis. SolarPV panelsinstalled on the roof of the Hening Cove bath houseare not ,*p"ðt.d to have any direct or indirect impact upon water resources,geology and soil, vegetation,air quality, marine or terrestriatwildlife. The use of this renewable energy teclbnology*ould have a minor long-term beneficial impact on air quality as it would be a non-greenhousegas emitting meansof power generation.
Conclusion. The solar panelswill have a minor long term beneficial impact on natural resources.
4.3.2 IMPACT ON SURROLT¡IDING COMMTJMTY
Analysis. Similar to the preferred alternative,the installation of solar panels would provide an exämple of a functiorrìng r"rr.*able energy sourceon a park facility' However, it would not demonstratethe advantagesof two different types of renewablesystems and the ways in which they work in concert together.The indirect moderatebeneficial effect of this showcasingcomes from educationalopportunities regarding renewable energy.
Conclusion. Installationof solarpanels would resultin a long term moderatebeneficial impact to the communitY.
4.3.3 IMPACT ON PUBLIC USE AND ACCESS
Analysis. Installationof solarpanels on the roof of the Herring Cove bath housewould prouid. educationalopportunities to the surrounding community, and thus would result in a long-term beneficial impact upon public use.
could Similar to the preferred alternative,the presenceof solar renewableenergy technology This could draw visitors to the Herring Cove facility so they can seethe appliancesin action- increased bolster public morale and s-upportfor the park operations,and possibly result in visitation to the beachfacilities in futureyears.
parking' Installationof a solarPV systemon the roof would not interferewith visitor
impactson Conclusion. Having a solarPV systemon site could havelong-term beneficial public use and u.".i, due to the presenceof reliablepov¿er from a renewabletechnology'
4.3.4 IMPACT oN PARK M,A'NAGEMENT AND OPERATIONS power Analysis. This alternativeprovides a more consistentenergy supply than the existing the fee line, iesulting in more reliáble electricityto all Herring cove serviceareas, including
page 25 EnvironmentalAs s es sment Electrícal Supplyfor Herring CoveBeach Facílities
booth,snack bar, andbath house. This alternative,estimated over a Z}-yearperiod of time, would be $47,000 more expensiveto operatethan the preferred alternative,having a major impact on the park's budget.Also, energy captureis lessconsistent with this alternative, potentially forcing the park to purchasemore energy from an electric supplier.These are minor to moderatelong-term adverseimpacts.
Conclusion. This solar-only alternativeis more costly than the preferredalternative and less reliable as an energy source.Therefore, there would be a minor to moderateimpact on park operations.
4.3.5 IMPACT ON CTJLTURAL RESOURCES
Analysis. There are currently no structures,archeological sites or cultural landscapeseligible for or listed on the National Registerin the direct vicinity of this project. ln October 2004, Northern Ecological Associates,Inc. performed a PhaseI archeologicalinvestigation in advanceof the installation of two vault toilets and lift station in the vicinity of this project area. They concludedthat no prehistoric or historic sites or featurespotentially eligible for inclusionon the NationalRegister of Historic Placeswere locatedin the area.
The Herring Cove Bathhouseis currentlynot considereda historic structure,but it has never been evaluated. It is anticipatedthat the park will evaluatethe structurein the next year and it could be determinedto be eligible for the NationalRegister of Historic Places.Built in 1953,it is over 50 yearsold and oneof the first bathhousesbuilt by the Commonwealthof Massachusetts.
Conclusion.There areno historicproperties affected for the proposedalternative.
4.3.6 CUMULATTVE IMPACTS
There would be no adversecumulative impacts upon natural or cultural resources.The overall impact of a varied renewableelectrical production system would havemultiple benefits as describedabove upon public use, surroundingcommunity, and park management and operations.The solar only option is preferred to no action and is the environmentally preferred alternative.Implementation of this alternativewould not constitutean impairment ofkey park resources.
5.0 CONSULTATION AND COORDINATION
5.1 SUMMARY OF PUBLIC INVOLVEMENT
On May 23,2007, seashorestaff held a public informationmeeting at ProvincetownTown Hall. The purposeof the meetingwas to shareinformation and acceptsuggestions on various planning and constructionprojects, including improvementsto the Herring Cove Bathhouse, in the Provincetownand ProvinceLands areas. The public was informedof this meetingvia a pressrelease of April 19,2007.
page 26 EnvironmentalAs s essment Electrical Supplyfor Herring CoveBeach Factlitíes In January2008, the park superintendentand chief of maintenancemet with Provincetown selectmenand town managementofficials in order to discusspublic feedback and the need to upgradethe presentdeteriorating underground electric supply line at Herring Cove Beach facilities.No concernsor objectionswere raisedby Town selectmenor the public presentat thesemeetings. public notice regarding the availability of this Environmental Assessmentwill be distributed to the media and interestedparties. There will be a 30-day public comment period to receive public andagencyfeedback on the plan. Commentscan be submitted to:
SuperintendentGeorge E. Price, Jr' CapeCod National Seashore 99 Marconi Site Road Wellfleet, MA 02661
5.2 CONSTILTATION \ilITH AGENCIES AND ORGANIZATIONS
The following agenciesand organizationswere consultedleading to the developmentof this EA, or arebeing sentcopies of this EA for review:
Federal Aviation Administration MassachusettsAeronautics Commission U.S. Fish and Wildlife Service U.S. CoastGuard MassachusettsDivision of Fisheriesand Wildlife: Natural Heritage and EndangeredSpecies Progtam MassachusettsHistorical Commission Advisory Council on Historic Preservation WampanoagTribe of Gay Head (Aquinnah), Tribal Historic PreservationOffice MashpeeWampanoag Tribal Council MassachusettsDepartment of Environmental Protection MassachusettsAudubon SocietY MassachusettsCoastal Zone Management ProvincetownBoard of Selectmen ProvincetownAirport Commission ProvincetownConservation Commission Provincetown DeparLmentof Public Works Provincetown Town Manager Town librariesand town halls: Chatham,Orleans, Eastham, Wellfleet, Truro, Provincetown Department of Energy FederalEnergy ManagementProgram Provincetown Alternative Energy Committee
page 27 EnvironmentalAs s es sment Electrical Supplyfor Herríng CoveBeach Facilities The NPS prepareda Notice of ProposedConstruction or Alteration with the FederalAviation Administration (FAA) for the potential wind turbine. The purposeof the consultationis to determineif the agencyhas concernsif the project presentsan airport obstruction.
FAA sentconfirmation of receivingour notice on I2lI9l07. In early May 2008,we expectto receive the FAA determinationof the impact of the potential wind turbine to a public use airport or NAVAID facility through aeronauticalstudy process.
A MassachusettsAeronautics Commission (MAC) letter of December 14,2007 confirms that the proposal of a wind turbine at the Herring Cove bath housesite doesnot violate MAC laws or regulationsand is not subjectto further action requiredby MAC laws or regulations. The letter also indicatesthat the MAC Boston office may offer additional commentsafter consideringFAA's determination.
The Advisory Council on Historic Preservation(ACHP), by letter of February19,2008, acknowledgedthe park's notificationof this EA to examinepossible effects on historic properties.Should CCNS determine,in consultationwith the StateHistoric Preservation Office, tribes, and other consulting parties, that this proposedundertaking may have an adverseeffect on propertieslisted or eligible for listing on the NationalRegister of Historic Placesthat will be documentedin the EA, ACHP requeststo be notif,redby CCNS of the adverseeffect and provided adequatedocumentation for their review.
Under Massachusettslaw, 220 CMR 11, RulesGoverning the Restructuringof the Electric Industry, specialapproval is not neededfor a wind or solar generationproject less than 60kV/, providedthe generationfacility meetsthe interconnectionstandards and all relevant safety and power quality standards.Projects above 60 kW require FederalEnergy Regulatory Commissionapproval if power is to be exportedback to the utility grid. AlternativesOne and Two would fall well below the 60kW thresholdthus would not be subjectto the review process.
The electricutility supplierwould be consultedif one of the altemativeenergy altematives, Alternative One or Two, is selected. This is becausethe utility grid-connectedunderground line would serveas back-up pov/er until it is no longer a viable power source. This consultationprocess would entail a review of the proposedutility interconnection engineeringportion of the project, particularly the inverter and transfer switch engineering, so that the independentsystem would not causeimproper feedbackto the electrical supply grid.
5.3 RELATIONSHIP TO OTHER PLANNING EFFORTS
Otherrecent and upcomingNPS activitiesin the Provincetownand Truro areasof the park includesome transportation-related construction activities that haveundergone NEPA evaluation,such as the environmentalassessment of rehabilitationof the ProvinceLands Bike Trail, and a categoricalexclusion for the Herring Cove arearoad andparking reconfigurationsas assessedby FederalHighway Administration-Massachusetts Division.
page 28 EnvíronmentalAs s essment Electrical Supplyfor Hercing CoveBeach Facilities Another potential land-basedwind-turbine relatedproject by NPS is an upcoming wind feasibility study planned for the Highlands Center at Cape Cod National Seashore,located in North Truro. There is no current proposal for this facility. An environmental assessmentwill be conductedonce the study is underway. The park is consideringundertaking a separate planning processfor dune shackuse and managementin the Dune Shacksof the PeakedHill Bars Historic District (2 miles distant from the site of this proposedaction); a separateNEPA document is expectedwhen funding becomesavailable for a civic engagementinitiative. Cumulative effectswith theseactions, therefore, are not being considered'
page 29 EnvironmentalAs s es sment Electrical Supplyfor Herring CoveBeach Facilitíes 6.0 COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS
6.0.1 FEDERALREGULATIONS
Americans with Disabilities Act: The Americanswith DisabilitiesAct establishesfederal guidelinesthat define requirementsfor disabledaccess to parking facilities, pathways,and buildings. All structuresand facilities available for public use need to be upgradedin full compliancewith the act as they are rehabilitated. The act doesnot apply to the implementationof thesealternatives.
Archeological ResourcesProtection Act of 1979:The ArcheologicalResources Protection Act (ARPA) requiresthat archeologicalresources be identified and that proper permits be obtainedprior to excavatingany resources.The NPS has not identified any known or potential archeologicalresources in the project area.
Analysis of Impacts on Prime and Unique Agricultural Lands in Implementing the National Environmental Policy Act (45 FR 59189):Federal agencies are required to analyzethe impacts of federal actions on agricultural lands,in accordancewith NEPA. This policy was developedto minimize the effect of federal programsin convertingprime, unique, or locally importantfarmland to nonagriculturaluses. There are both prime andunique farmlandswithin the seashore;however, the proposedproject at Herring Cove doesnot affect theselands nor will it convertthese lands to nonagriculturaluses.
Clean Air Act, as Amended (42 USC 7401et seq.):Cape Cod National Seashoreis designateda classII clean air area. Maximum allowableincreases of sulfur dioxide, particulatematter ad nitrogendioxides beyond baseline concentrations established for classII areascannot be exceeded.Class II incrementsallow modestindustrial activities in the vicinity of a park. Section118 of the Act requiresall federalfacilities to comply with existingfederal, state and local air pollution control laws andregulations. Cape Cod National Seashorewill work with the MassachusettsDepartment of Environmental Protection to ensurethat all activities in the national seashoremeet the requirementsof the state'sair quality implementationplan.
The CleanAir Act establishesregulations regarding disclosure, control, and abatementof air pollutants. There are no air-borne contaminantsof concem that will be generatedby the project, and thereforethe alternativesare compatible with the requirementsof the CleanAir Act.
Coastal Barrier ResourcesAct: This law encouragesthe conservationof hurricaneprone, biologically rich coastalbarriers by restrictingfederal expenditures that encourage development,such as Federal flood insurancethrough the National Flood InsuranceProgram. The alternativesites considered in this environmentalassessment do not entailfederal expendituresor financialassistance that would adverselyaffect ecologically sensitive coastal barrierresources.
page30 EnvironmentalAss es sment Electrícal Supplyfor Herring CoveBeach Facilittes
ComprehensiveEnvironmental Response,Compensation and Liability Act: The ComfrehensiveEnvironmental Response, Compensation and Liability Act establishes regulationsregarding the assessment,remediation, and liability for remediation of hazardous substancesthat have causedcontamination. None of the alternativesconsidered in this environmentalassessment have been designatedas National Priority List sites. There is no known contaminationat this site.
Endangered SpeciesAct of 1973,,as amended(16 USC 1531 et seq.): Section7 of the Endangired SpèciesAct directs all federal agenciesto further the purposesof the act, which are to conservethreatened and endangeredspecies and the ecosystemson which they depend. Federalagencies are required to consult with the USFWS to ensurethat any action authorizeá,funded, or carried out by the agency doesnot jeopardize the continued existence of listed speciesor critical habitat.
To ensurethat adverseeffects to stateand federally listed speciesare avoided, the preferred alternativeincorporates a two part adaptívemanagement strategy described in Appendix A. The first part wiil focus on assessingbird use in the area of the proposedturbine, and the secondpârt integratesmonitoring into turbine managementto ensurethat turbine operations ur. *odifr.d or shut down if adverseeffects to stateor federallylisted speciesappear likely. The adaptivemanagement plan includes continuedand frequent coordination with FWS and NHSp tó ensurethose agencies'expertise is incorporatedinto review and interpretationof the data collected,and that ihose agenciesconcur with decisionsregarding turbine operations. Based on this element of the preferred alternative,the Seashorehas determinedthat selection and implementation of the preferred alternativeis not likely to adverselyaffect federally listed species.This EA will be submittedto the USFWS with a requestfor informal consultãtionand confirmationof their concurrencewith the Seashore'sdetermination of "not likely to adverselyaffect."
Executive Order tl987z (Exotic Organisms): This executiveorder requires federal agenciesto restrict the introduction of exotic speciesinto natural ecosystemson lands and *ãt.r, that they own, lease,or hold for purposesof administration and into any natural ecosystemof the United Statesand to encouragethe states,local governments,and private citizens to prevent the introduction of exotics into natural ecosystemsof the United States. CCNS hasãetermined that the alternativesevaluated in this EA do not pertain to the infroduction of exotics as defined by this executiveorder.
Executive Orders 1l9BB (Floodptain Management) and 11990(Protection of Wetlands): ExecutiveOrders 11988 and 11990direct federalagencies to enhancefloodplain and wetlandsvalue, to avoid developmentin floodplainsand wetlandswhenever possible, and to minimize adverseimpacts if developmentcannot be avoided. None of the alternativesaffect a floodplainor wetland areasas def,rnedby the executiveorders.
ExecutiveOrder 12898(Environmental Justice in Minority Populationsand Low- Income Populations): EnvironmentalOrder 12898,"Federal Actions to Address Environmental Justice in Minority Populationsand Low-Income Populations," requires all federal agenciesto identiff and addressdisproportionately high and adversehuman health or
page 3l EnvironmentalAs s es sment Electrical Supplyfor Herring CoveBeach Facilities environmentaleffects of their programsand policies on minorify and low-income populationsand communities.None of the alternativesconsidered in this documentwould result in substantialchanges in the socioeconomicenvironment of the project area. Job creationwould be subjectto the Equal Employment Opportunity Act. Minority and low- income populations do not live adjacentto the project site. Consequently,the project is expectedto have no discernibledirect or indirect adverseimpacts to minority or low-incomepopulations.
Federal Water Pollution Control Act, as Amended (1972),Clean Water Act of 1977 and Water Qualify Act of 1987(33 USC) 125l-1376: The proposedactions will haveno effects on water quality. Constructionactivities would need to comply with the requirementsof sections401 and 404 of the Clean Water Act and other applicablefederal, state,and local regulations.
Fish and Wildlife Coordination Act: This actprovides the basic authorityfor the USFWS's involvement in impacts to fish and wildlife from proposedwater resourcedevelopment projects.The project containedin this EA doesnot entail water-relatedconstruction, and there will be no modifications to waterwaysor bodies of water protectedby this act. ái Magnuson-StevensFishery Conservation and Management Act: This act requiresfederal agenciesto consult with the National Oceanicand Atmospheric Administration (NOAA) regardingproposed actions that could damageEssential Fish Habitat (EFH) as identified by NOAA Fisheriesand the appropriatefishery managementcouncil. The proposedactions in this EA will not affect EFH; thereforeconsultation on the proposedmodifìcation to CCNS's project is not required.
Migratory Bird Treaty Act, and other laws and treaties that protect migratory birds: There are a number of laws and treaties-suchas the Migratory Bird Treaty Act, the Lacey Act, the Weeks-Mclean Law, and the Waterfowl DepredationsPrevention Act- designedto protect migratory birds. If selected,turbine operationswould be managedin responseto monitoringto ensureimpacts to migratoryspecies are minimized.
National Environmental Policy Act of l969zNEPA requiresconsideration of the environmentaleffects of proposedfederal actions. NEPA also ensuresthat environmental informationis availableto public officials andmembers of the public beforedecisions are made and before actions are taken. This EnvironmentalAssessment provides a description of the preferred alternativeplus one other alternative,the no action alternative,and summarizes potentialenvironmental consequences of the alternatives.A 3O-daypublic commentperiod will be scheduled.
National Historic Preservation Act of 1966,as Amended: Section 106of the National Historic PreservationAct requiresthat an assessmentbe conductedof any project,activity, or programthat could changethe characteror useof propertieslisted in or eligible for listing in the National Register of Historic Places.The National Park Service will preparean assessmentof effectsin accordancewith section106 that no historic propertieswill be affectedby the alternative managementand developmentactions.
page 32 EnvironmentalAs s es sment Electrical Supplyfor Herring Cove Beach Facilíties
6.0.2 STATE REGULATIONS
Coastal Zone Management Act of 1972 and,Coastal Barrier ResourcesAct (1982)both as amendedin 1990:
The CoastalZone ManagementAct requires that federal agenciesadhere to stateCoastal ZoneManagementPlans when conducting projects or activities that affect the coastalzone. Thesepolicies rccognizethe ecological significance of coastalwaters and strive to protect both the water quality and the integrity of significant resourceareas. All of Cape Cod is within the coastal zonei however this plan is not expectedto have a change in affect to coastalresources. The NPS will senda copy of this EA to the Cape and Islands Coordinator of the MassachusettsCoastalZone Managementprogtam for a federal consistencyreview a determinationof consistencywill be required for the proposedalternatives.
MassachusettsEndangered SpeciesAct
The MassachusettsEndangered Species Act (MESA) is administeredby the Massachusetts Natural Heritage and EndangeredSpecies Program G\THESP)- a branch of the Massachusetts Departmentof Fisheriesand Wildlife. MESA prohibitstake of specieslisted as endangered, 4 threatened,or of specialconcern. However,projects that will resultin take of listed species may be eligible for a Conservation& ManagementPermit if alternativesto both temporary and permanentimpacts to statelisted speciesare assessed,if the project will impactan insignificantportion of the local populationof the affectedspecies, and if the project includes a conservationand managementplan that provides a long-term net benefit to the conservationof the affectedspecies.
To ensurethat adverseeffects to stateand federally listed speciesare avoided, the preferred alternative incorporatesa two part adaptivemanagement strategy described in Appendix A. The f,rrstpart will focus on assessingbird use in the areaof the proposedturbine, and the secondpart integratesmonitoring into turbine managementto ensurethat turbine operations are modified or shut down if adverseeffects to stateor federally listed speciesappear likely. The adaptivemanagement plan includes continued and frequentcoordination with FWS and NHSP to ensurethose agencies'expertise is incorporatedinto review and interpretationof the data collected, and that thoseagencies concur with decisionsregarding turbine operations. Based on this element of the preferred altemative, the Seashorehas determined that selection and implementation of the preferredalternative is not likely to result in take of statelisted species.This EA will be submittedto the NHESP with a requestfor informal consultation and confirmation of their concurrencewith the Seashore'sdetermination that take is not likely to resultfrom the proposedaction.
page 33 EnvironmentalAs s es sment Electrícal Supplyfor Herring CoveBeach FacÌlities LIST OF PREPARERS AND REVIEWERS
CapeCod National Seashore
GeorgeE. Price,Jr., Superintendent Mark Adams, GIS Specialist JanetBarricman, Fee and RevenueSpecialist Nicole Brooks, Facility ManagementSpecialist Bill Burke, Cultural ResourceSpecialist ChelseaClarke, Park Planning Assistant Dr. RobertCook, Wildlife Biologist FredericaDimmick, Archeologist Lauren McKean, ManagementAssistant/Park Planner SueMoynihan, Chief of Interpretationand Cultural Resources Ben Pearson,Chief of Maintenance Carrie Phillips, Chief of Natural ResourceManagement Craig Thatcher, Acting Chief Ranger/lrlorthDistrict Ranger
Antares Group, Incorporated
Kevin Comer,Senior Project Manager Heidi Lestyan, RenewableEnergy Analyst
BarnstableCounty AmeriCorps CapeCod
ChristinaImrich, PlanningAssistant to CCNS Austin Krcmarik, SustainableDevelopment Researcher for CCNS
National Park ServiceNortheast Region
Dave Clark, Regional NEPA Coordinator
page 34 EnvíronmentalAs sessment Electrícal Supplyfor Herring CoveBeach Facilities APPENDIX A: Ilerring Cove Wind Turbine Adaptive Management Plan
Background:
The beachesof lower Cape Cod provide important nesting and feeding habitat for a number of sensitivespecies including piping plovers (Charadrius melodus),which are federally and statelisted as threatened,and leastand common terns (Sterna antillarum and.S.hírundo), both of which are statelisted as speciesof specialconcern. The lower Cape'sbeaches, salt marshes,and estuarinewaters also provide important resting and feeding habitat for migratory speciesincluding the federally endangeredroseate tern (Sterna dougalli), and severalshorebird species. The beachat Herring Cove is not usedby thesespecies- This is probably due to the presenceof developedfacilities þarking areas,bathhouse, snack bar) ãlotrg the length of the beach,disrupted sand dynamics due to past paving and seawall construction,and intensive recreationaluse. While the beach at Herring Cove doesnot provide habitat used by thesespecies, it is in the vicinity of areasof high habitat value. HatchesHarbor, which is about lnrr(2.5 miles) to the north, provides nesting,feeding, and staging habitat for piping plovers. HatchesHarbor is also used by other shorebirdsand terns durìng migration. West End marsh,which is about2.5 hn (1.6 miles) to the south,is also usedby mìgratingshorebirds and terns. And Wood End/Long Point beach,starting about 8.5 km (5.3 miies) tothe southand east,is alsoused by nestingplovers and migratingshorebirds and terns.
Direct impacts to birds and bats have been observedat a number of commercial-scalewind developmìnts (NWCC 2004). However, there is little information regarding the impacts of small, iingte turbinewind installations.A studyto assessavian mortality associatedwith a larger turbine (73.5 m (24I ft) rotor tip height) at the MassachusettsMaritime Academy in Buãzard'sBay estimated1.39 bird fatalities/yearresulting from collision with the turbine basedon the deathof one laughinggull (Vliestn2007). This study also counted24,564 birds passingthough the turbine's air spaceduring the four-month tern nesting period in 2006. Of thèse, 254 were terns which were abundantin the area,particularly foraging in the waters off the Academy during the chick rearing season. Comparison of the numbersof terns flying through the rotor-swept zone when the turbine blades were and were not spinning indicates that terns may avoid the turbine airspacewhen the blades are rotating. No impacts to bats were detected. Very few bird mortalities and no bat mortalities have been detectedin associationwith a turbine (27 m(91 ft) rotor tip height) at MissisquoiNational Wildlife Refuge in Vermont after three yearsof operation,and starlings have nestedin the structure behind the rotor for the last few nestingseasons (M. Sweeney,pers com). At the Eastern Neck National Wildlife Refuge in Maryland, a total of 15 bird deathswere attributedto a turbine 18.3meters (60 feet) tall over a threeyear period. Thirteenof thesewere European starlings which had nestedin the turbine structure. The other two mortalities were a bank swallow and a catbird. No effectsto batswere observed(Willis 2005).
Basedon the observationsof avian interactionswith small turbinesat other sites,it appears that the potential for the Herring cove turbine to have more than negligible impactsto birds is quite low, and the potential for impactsto bats would seemvirtually nonexistent. However, tile habitats and speciesin the vicinity of National Wildlife Refuge turbines are different than
page 35 EnvironmentalAs s essment Electrical Supplyfor Hetíng Cove Beach Facilities
those in the vicinity of Herring Cove, and althoughthe speciesof concern for the Maritime Academy'sturbine are substantiallysimilar to Her¡ing Cove, the ecological setting is quite different. To ensurethat the turbine's impactsto birds and bats are minimal, and that adverse effects to stateand federally listed speciesare avoided,turbine operationswill be guided by a two-phaseadaptive management approach. The first phasewill focus on assessingbird use in the area of the proposedturbine, and the secondintegrates monitori4g into turbine managementto ensurethat turbine operationsare modif,redor shut down well before any impacts approachthe level of having an appreciableeffect on the resource.
PhaseI: Assessmentof Bird Use of Herring CoveAir Space
Bird abundancein the Seashoreis highest and the speciesof concern are presentduring the spring and summermonths when nesting and migration occur. To better understandwhich speciescould be affectedby the turbine, a non-quantitativesurvey of birds moving through the air spaceabove Hening Cove will be conductedMay through Septemberof 2008. Surveyswill be conductedat random times during day-light hours. Observationswill be collected from a stationarypoint selectedby the observerbased on light conditions at the time. Observationpoints will be selectedto providea view of the airspaceover and surroundingthe bathhouse. Information recordedwill include: start and end times of each survey, weatherand light conditions, observationpoint location, number of eachspecies observedflying through the bathhouseairspace, the height at which eachbird transitsthe bathhouseair spaceestimated relative to the height of the bathhouse,and the number of each speciesobserved flying in the Herring Cove areain general.
The information will be compiled into a brief summaryreport, and sharedwith FWS and NHESP. This informationwill be usedto reassessthe likelihood of adverseeffects to state or federallylisted species,and to determineif changesshould be madeto the designof PhaseII.
PhaseII: Adaptive Managementof Turbine Operations
Mortalify Monitoring:
Oncethe turbineis operational,the areawithin a 30 meter(100 ft) radiusof the turbine would be surveyedfor evidenceof bird and bat mortality. After turbine constructionis completed,a grid, incrementally increasingradius, or other searchmethod would be establishedto aid thorough searchingof the survey area. Carcasssurveys would be conducteda minimum of four times per week April I throughOctober 10. To assessnight- time mortality, survey times would include first light. Surveyswould also occur randomly throughoutdaylight hours,or might be focusedon specifictimes of the day as indicatedby the resultsof the PhaseI bird use assessment.Any carcassesrecovered would be photographedin place,and then examinedfor signsof injury, scavenging,starvation, or other visual indicationsof potentialcauses of death. Datarecorded would includespecies, sex and ageclass if evident,condition, and presumedcause of death. Carcasseswould be disposedof at leasta half mile from the turbine.
page 36 EnvironmentalAs s es sment Electrical Supplyfor Herring CoveBeach Facilities Reporting: Resource Recoveriesof any carcasseswould be reported by phone to the Chief of Natural results would Management(NRM) upon completion olthut day's survey. Survey efforts and a weekly basis' be summari zedínu 6tièf *titten report and provided to the Chief of NRM on October and These weekly reports would be syrrjthesizedinto an arutualreport at the end of provided to NIIESP and FV/S.
Coordination and Turbine Management:
were detectedto The Chief of NRM would forward any weekly reports in which mortalities generateconcern NHESP and FWS. At any time that levels of mortality or the specieskilled the statusof the among NHESp, FWS, orih. park, a conferencecall would occur to discuss is not turbine and whether or not it ihould be shut down. While take of listed species Maintenance and anticipated,should it occur, NRM would immediately notiff the chief of the turbine would be shut down. NRM would then notiffNHESP and FWS immediately thereafter.
Adaptive ManagementPlan Review: will be reviewed At the end of the year, the results of mortality surveysand turbine operation this to inform plansfor the followingyear. Issuesthat shouldbe addressedin review include:
-changesin mortalify monitoring methods; -whether or not studiesshould bè included to estimatescavenging effects and searcherefficiencY; -effectiven.r, und utility of the reporting and coordination strategy;and -times of year, weather conditions, or other conditions during which the turbine should be preemptively shut down to avoid wildlife impacts. to guide Any agreedupon changesin monitoring or turbine managementwill be documented tglryy' and revised activities in the cominiyear. This cyciã of monitoring, reporting, annual as long as desiredby the park, NHESP, or FWS' flans for the comingyear will be repeated
Appendix A References:
Marksweeney, Missisquoi National wildlife Refuge.Personal communication,200T' researchresults and NWCC. 2004.wind TurbineInteractions with Birdsand Bats: A summaryof remainingquestions. National Wind Coordinating Committee' t tÇ,7rut'ä."ationalwínd.org/publications/wildlife/wildtife-factsheet.pdf. wind Turbineon common vliestra,L.S. 2007.Potential Impact of theMassachusetts maritime Academy 60 pp' andRoseate Tems. Massachusetts Maritime Academy Report, Buzzards Bay' MA' NeckNational V/ildlife Willis, T. 2005.A SmallScale, Hybrid, Altemative Energy Project at Eastern Chestertown, Refuge,Rock Hall, Maryland, Finai Report. Looking Glass Environmental Consultants, MD. 26pP
page 37 FIGURE 3-1 Herring Cove BeachFacilities and ProposedProject Sites- Herring Cove Bathhouse,parking lot, enhancefee booth, and proposed wind tower site
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