DRAFT
Environmental Assessment for Proposed Habitat Conservation Plan and Incidental Take Permit
Blue Creek Wind Farm, LLC
Van Wert and Paulding Counties, Ohio
December 2019
U.S. Fish and Wildlife Service Ohio Ecological Services Office 4625 Morse Road, Suite 104 Columbus, Ohio 43230
DRAFT ENVIRONMENTAL ASSESSMENT FOR PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC
Table of Contents Introduction ...... 1 1.1 Project Background ...... 1 1.1.1 Blue Creek Wind Farm Project ...... 1 1.1.2 Habitat Conservation Plan Permit Area ...... 2 1.2 Regulatory and Policy Background ...... 2 1.2.1 National Environmental Policy Act ...... 2 1.2.2 Endangered Species Act ...... 4 1.2.3 Ohio Department of Natural Resources ...... 5 1.3 Action Agency Purpose and Need...... 5 1.3.1 The Role of the Environmental Assessment ...... 5 1.3.2 Proposed Federal Action ...... 5 1.3.3 Purpose and Need of Proposed Federal Action ...... 5 Alternatives ...... 6 2.1 Development of Alternatives ...... 6 2.2 Alternatives Retained for Detailed Analysis ...... 7 2.2.1 Alternative 1: No-Action ...... 8 2.2.2 Alternative 2: Applicant’s Proposed Project ...... 9 2.2.3 Alternative 3: More Restrictive Operations ...... 14 2.2.4 Alternative 4: Less Restrictive Operations ...... 16 2.3 Summary of the Alternatives Analysis ...... 17 2.4 Alternatives Eliminated from Detailed Analysis ...... 18 Affected Environment ...... 19 3.1 Overview of the Permit Area ...... 19 3.2 Overview of the Plan Area (Mitigation Habitat Options) ...... 20 3.3 Resources Evaluated and Dismissed from Further Analysis ...... 21 3.4 Resources Evaluated and Brought Forward for Detailed Analysis ...... 22 3.4.1 General Wildlife Resources ...... 22 3.4.2 Avian Resources ...... 23 3.4.3 Bat Resources ...... 26 3.4.4 Climate Change ...... 39 Environmental Consequences ...... 40
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4.1 Overview of the Effects Analysis ...... 40 4.2 Biological Environment ...... 40 4.2.1 General Wildlife Resources ...... 40 4.2.2 Avian Resources ...... 42 4.2.3 Bat Resources ...... 48 4.2.4 Climate Change ...... 60 4.3 Cumulative Effects ...... 61 4.3.1 Other Wind Energy Development ...... 61 4.3.2 Avian Resources ...... 63 4.3.3 Bat Resources ...... 68 Consultation and Coordination ...... 74 5.1 Agency and Tribal Coordination ...... 74 5.2 Distribution of the Draft EA ...... 75 List of Preparers ...... 75
List of Tables Table 2-1. Alternative 2 Operational Minimization Plan ...... 10 Table 2-2. Results from Publicly Available Curtailment Effectiveness Studies ...... 11 Table 2-3. Comparison of Alternatives Considered for Detailed Analysis ...... 17 Table 3-1. Post-Construction Monitoring 2012, 2013, and 2015 – Bird Fatalities ...... 25 Table 3-2. Potential Bat Presence by Season ...... 27 Table 3-3. Indiana Bat Population Estimates for the Midwest Recovery Unit ...... 30 Table 3-4. Post-Construction Monitoring 2012, 2013, 2015, and 2016 – Bat Fatalities ...... 37 Table 4-1. Comparison of Direct Effects to Bats for Each Alternative ...... 54 Table 4-2. Comparison of Estimates of Indiana Bat, Northern Long-Eared Bat, and Unlisted Bat Species Mortality Across Alternatives ...... 59 Table 4-3. Installed and Projected Wind Energy Capacity in former Service Region 3, MRU, and BCR 23 ...... 62 Table 4-4. Cumulative Avian Mortality Estimates and Wind Power Capacity in BCR 23 ...... 65
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Table 4-5. Cumulative Effects to Indiana Bats, Northern Long-Eared Bats, and Unlisted Bat Species from the Project and Projected Installed Wind Power Capacity in the Midwest Recovery Unit and former Service Region 3 ...... 70
List of Figures Figure 1-1. Blue Creek Wind Farm Location Figure 1-2. Turbines Locations and Boundary of the Permit Area for the Blue Creek Wind Farm Habitat Conservation Plan Figure 3-1. Blue Creek Wind Farm Land Cover
List of Appendices Appendix A – Acronyms and Abbreviations Appendix B – Figures Appendix C – References Appendix D – USFWS Template Language to Be Included in Easement and Fee Simple Conveyances Appendix E – Reference Tables
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Introduction
1.1 Project Background The U.S. Fish and Wildlife Service (Service)1 received an application for an incidental take permit (ITP), pursuant to the provisions of section 10(a)(1)(B) of the Endangered Species Act of 1973, as amended (ESA;16 United States Code [USC] 1531–1544.) for the Blue Creek Wind Farm Project (Project) in Van Wert and Paulding counties, Ohio (Figure 1-1). If issued, the ITP will authorize the incidental take of the Indiana bat (Myotis sodalis), a federally endangered species, and northern long-eared bat (NLEB) (Myotis septentrionalis), a federally threatened species (Covered Species), during operation of the Project. Under Section 10 of the ESA, applicants may be authorized, through issuance of an ITP, to conduct activities that may result in take of a listed species as long as the take is incidental to, and not the purpose of, otherwise lawful activities. The Project is owned and operated by Blue Creek Wind Farm, LLC (the Applicant), a wholly owned subsidiary of Avangrid Renewables, LLC. The Applicant’s ITP application includes a Habitat Conservation Plan (HCP) that specifies, among other things, the impacts that are likely to result from taking Indiana bat and NLEB and the measures the Applicant will undertake to minimize and mitigate such impacts. This Environmental Assessment (EA) is prepared in accordance with the National Environmental Policy Act (NEPA) of 1969 to evaluate the impact that approving the HCP and issuing an ITP (the Proposed Federal Action) will have on the human environment.
1.1.1 Blue Creek Wind Farm Project
The Project is an existing wind energy facility located in Van Wert and Paulding counties, Ohio, north of the city of Van Wert (Figure 1-1)2. The Project has a nameplate capacity of 304 megawatts (MW) and includes 152, 2.0-MW Gamesa G90 wind turbines, as well as support facilities including turbine pads, an operations and maintenance (O&M) facility, access roads, a collector line system, two substations, and two permanent meteorological towers. Project construction began in September 2010, and commercial operation began in June 2012. 1.1.1.1 Turbines The Gamesa G90 turbine towers are 100 meters in height, with a rotor blade length of 45 meters. Therefore, the maximum height of the turbines from tower base to highest blade tip is 145 meters above the ground. Gamesa G90 turbines are designed to begin generating electricity when the wind speed reaches 3.0 meters per second (m/s), known as the “manufacturer’s cut-in speed.” The turbines reach their maximum generation at approximately 12 m/s, at a rotational speed of approximately 18.6 revolutions per minute, at which point the blades pitch to catch less wind and remain revolving at this speed. At about 25 m/s the turbine shuts down to prevent an overspeed
1 A complete list of acronyms and abbreviations can be found in Appendix A. 2 See Appendix B for document figures.
December 2019 U.S. Fish and Wildlife Service 1 DRAFT ENVIRONMENTAL ASSESSMENT FOR PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC scenario of the generator, known as the “cut-out speed.” Each turbine includes a supervisory control and data acquisition (SCADA) operations and communications system that allows automated, independent, and remote operation of the turbine. 1.1.1.2 Support Facilities Roads associated with the Project include upgraded existing roads and new access roads that were constructed for the Project. The permanent width of access roads is approximately 14 feet. Gravel pads under each turbine extend approximately 6 feet from the base of the turbine. Electrical power generated by the wind turbines is transformed and collected through a network of underground and overhead collection circuits leading to the two Project substations. The Project substations cover a total of less than 10 acres. The O&M facility consists of an approximately 5,000-square foot building. Regular maintenance activities are conducted during daylight hours when Covered Species are not active. Two permanent un-guyed 100-meter meteorological towers are located within the Permit Area.
1.1.2 Habitat Conservation Plan Permit Area
The lands covered by the HCP include the Permit Area (Figures 1-1 and 1-2) and the Plan Area (the state of Ohio). The Permit Area is a subset of the Plan Area. The Permit Area, approximately 40,426 acres, includes the area that is leased by the Applicant for the Project, and contains all Project turbines. The requested ITP will cover the entire Permit Area and mitigation sites within the Plan Area. The Plan Area includes all areas that will be affected directly or indirectly by activities associated with Project operations and mitigation. Thus, the Plan Area is the Permit Area plus areas involved in off-site mitigation projects. Mitigation areas have not yet been identified; however, they would be located within Ohio (see HCP Section 5.2.3), thus the Plan Area is the State of Ohio.
1.2 Regulatory and Policy Background
1.2.1 National Environmental Policy Act
The environmental review process under NEPA (42 USC § 4321 et seq.) provides the acting agency with the framework for reviewing the federal action, alternatives, environmental effects, and possible mitigation of potentially harmful effects of the action. NEPA is an environmental law fashioned to ensure careful decision-making with respect to the environment. NEPA also established the Council on Environmental Quality (CEQ) in the Executive Office of the President to formulate and recommend national policies to ensure that the programs of the federal government exercise careful decision-making with respect to the environment. The CEQ has set forth regulations (40 Code of Federal Regulations [CFR] 1500-1508) to assist federal agencies in implementing NEPA policies and to ensure that the environmental impacts of any proposed decisions are fully considered, and that appropriate steps are taken to mitigate potential environmental impacts. The NEPA review also provides an opportunity for the public to be involved in the acting agency’s decision-making process. For this Project, the public may comment on the
December 2019 U.S. Fish and Wildlife Service 2 DRAFT ENVIRONMENTAL ASSESSMENT FOR PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC draft EA and Project HCP for 30 days from publication in the Federal Register. The culmination of the EA process is either a Finding of No Significant Impact (FONSI) or a decision to prepare an Environmental Impact Statement. This EA and its analyses assist the Service with making an informed decision on issuance of an ITP. At this juncture, the Service is undertaking an EA to review the Applicant’s proposal, based upon the following:
• The Project is not located near suitable winter or summer habitat for the Covered Species;
• The Project will not impact critical habitat;
• The Applicant will implement a multi-year monitoring and adaptive management program;
• The Project site presents relatively low risk for resident and migratory birds because of its size, distance from sensitive avian resource areas, lack of open water, and predominantly agricultural setting;
• The Applicant’s proposed mitigation measures will fully offset the impact of taking Covered Species;
• The Proposed Federal Action will not:
o Affect historic or cultural resources, park lands, wetlands, wild and scenic rivers, or ecologically critical areas;
o Have uncertain effects on or pose unique or unknown risks to the human environment, and is not likely to be highly controversial;
o Contribute to cumulative significant impacts; o Result in any violation of federal, state, or local law, or requirements imposed for the protection of the environment;
o Expose future generations to increased safety or health hazards, does not conflict with local, regional, state, or federal land use plans or policies, and does not impose adverse effects on designated or proposed natural or recreation areas; and
• The issuance of an ITP is consistent with the Service’s responsibilities under the ESA and NEPA, and does not set a precedent for future actions with significant effects or represent a decision in principle about a future consideration; and In implementing NEPA, the Service must also comply with U.S. Department of the Interior (USDOI) regulations (43 CFR Part 46) and internal Service policies and guidance. The Service policies, guidance, and regulations pertaining to NEPA, including preparation of EAs, is found in the Service Manual, Series 500 (USFWS 2019a3). The Service must comply with page limits and time limits for the EA, consistent with Executive Order (EO) 13807 and the associated USDOI Secretarial Order (SO) 3355 (USDOI 2017) and USDOI Deputy Secretary memorandum dated August 6, 2018, titled
3 See Appendix C for document references.
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Additional Direction for Implementing Secretary’s Order 3355 Regarding Environmental Assessments (USDOI 2018).
1.2.2 Endangered Species Act
The Service is responsible for implementing and enforcing federal wildlife laws, including the ESA. Federally listed threatened and endangered species and designated critical habitat are governed by the ESA and its implementing regulations (50 CFR Parts 13 and 17). Section 9 of the ESA prohibits certain activities that directly or indirectly affect endangered species, while ESA Section 4(d) addresses the applicability of Section 9 prohibitions for threatened species. For the purposes of the EA and the proposed ITP, the most relevant Section 9 activity is the prohibition of take of wildlife species listed under the ESA. The ESA defines the term take to include harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect; or to attempt any of these acts (16 USC § 1532(19)). Take of listed wildlife is illegal unless otherwise authorized by the Service (or the National Marine Fisheries Service [NMFS] in marine systems) pursuant to Section 7 or 10 of the ESA. Section 10(a)(1)(B) provides that the Secretary of the Interior and the Secretary of Commerce may permit, under certain terms and conditions, any taking otherwise prohibited by Section 9(a)(1)(B) if such taking is “incidental to, and not the purpose of, the carrying out of an otherwise lawful activity.” To issue an ITP, the Director of the Service must find that the proposed activities meet the criteria included in Section 10(a)(2)(B) of the ESA and its implementing regulations (50 CFR § 17.22(b)(2), and 17.32(b)(2)). Under Section 7 of the ESA, issuance of an ITP is a federal action subject to Section 7. This means the Service must conduct an internal Section 7 consultation on permit issuance. This consultation terminates with preparation of a Biological Opinion (BO), which provides the Service’s determination as to whether issuing the ITP (the Proposed Federal Action) is likely to jeopardize the continued existence of a listed species or result in the destruction or adverse modification of designated critical habitat. During Section 7 intra-Service consultation, the Service may develop reasonable and prudent measures and terms and conditions to minimize the impacts of incidental take anticipated from the Proposed Federal Action when that action is not likely to jeopardize listed species or adversely modify designated critical habitat. The Service may also identify reasonable and prudent alternatives that would avoid the likelihood of jeopardy to listed species or adverse modification of designated critical habitat. “Reasonable and prudent measures” are required actions the Regional Director believes necessary or appropriate to minimize the impacts of incidental take to listed species and designated critical habitat and must be consistent with our statutory and regulatory authority in 50 CFR Part 402. Reasonable and prudent measures, terms, and conditions are included in the BO. The Service and NMFS have developed comprehensive guidance on the ITP program, which is found in the HCP Handbook (USFWS and NMFS 2016). This guidance assists USFWS staff and Applicants in developing an HCP that satisfies the application and issuance criteria listed in 50 CFR § 17.22(b)(1) and (2), respectively for endangered species and 17.32(b)(1) and (2), respectively for threatened species.
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1.2.3 Ohio Department of Natural Resources
State threatened and endangered species, including birds and bats, are protected under Ohio Revised Code (ORC) 1518.01–99, 1531.25, and 1531.99, which prevent the “taking or possession of native wildlife, or any eggs or offspring thereof, that [are found] to be threatened with statewide extinction” (ORC 1531.25). The Ohio Department of Natural Resources (ODNR) must issue a scientific collectors permit in accordance with ORC 1533.08 (and further defined under Ohio Administrative Code Section 1501:31-25-01 and 02) to authorize collection of carcasses during post-construction monitoring. There is currently no state-specific permit system authorizing incidental take of state-listed species. Because the Project has the potential to affect species protected under ORC, this EA addresses effects to state-listed species from issuance of an ITP (Sections 3.4.1.1, 3.4.2.6, 3.4.3.1, and 4.2.2.2).
1.3 Action Agency Purpose and Need
1.3.1 The Role of the Environmental Assessment
This EA evaluates and publicly discloses the potential environmental impacts on the human environment that may be caused by issuance of an ITP to the Applicant for the Indiana bat and NLEB in order to provide the Service with relevant information and to facilitate a “hard look” at the potential environmental consequences of issuing the requested ITP. It is prepared in accordance with the NEPA of 1969, CEQ’s regulations for implementing NEPA at 40 CFR 1500-1508, EO 13807, and USDOI’s and the Service’s policies and procedures for compliance with those laws and regulations (see 43 CFR Part 46, SO 3355, and associated implementation memos).
1.3.2 Proposed Federal Action
The Proposed Federal Action being evaluated by this EA is the issuance of an ESA ITP by the Service that would authorize the take of Indiana bats and NLEBs incidental to operation of the Project and implementation of the conservation plan in the associated HCP. The Proposed Federal Action would be carried out in accordance with the statutory and regulatory requirements of the ESA.
1.3.3 Purpose and Need of Proposed Federal Action
The Service’s purpose in considering the Proposed Federal Action is to fulfill our authority under the ESA, Section 10(a)(1)(B). Non-Federal applicants, whose otherwise lawful activities may result in take of ESA-listed wildlife, can apply to the Service for incidental take authority so that their activities may proceed without potential violations of Section 9. To carry out these responsibilities, we must comply with a number of environmental laws and regulations, Executive Orders (EO), and agency directives and policies. As the Service fulfills these responsibilities and obligations, we will:
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• Ensure that issuance of the ITP and implementation of the HCP achieve long-term species and ecosystem conservation objectives at ecologically appropriate scales; and
• Ensure that the conservation actions approved with issuance of the ITP occur within a spatially explicit landscape capable of supporting species mitigation projects over the long- term, or for a period commensurate with the nature of the impacts. The Service’s need relative to the Proposed Federal Action derives from Section 10 of the ESA which specifically directs the Service to issue ITPs to non-Federal entities for take of endangered and threatened species when the criteria in Section 10(a)(2)(B) are satisfied by the applicant. Once the Service receives an application for an ITP, we need to review the application to determine if it meets issuance criteria. The Service also needs to ensure that issuance of the ITP and implementation of the HCP complies with other applicable Federal laws and regulations. We must ensure our permit decision complies with the National Historic Preservation Act; treaties; and Executive Orders 11998, 11990, 13186, 12630, and 12962. In addition, the Service enforces the Bald and Golden Eagle Protection Act (BGEPA), the Migratory Bird Treaty Act (MBTA), and other requirements of the ESA in addition to Section 10. If we issue an incidental take permit, we may condition the permit to ensure the permittee’s compliance with BGEPA, MBTA, and all ESA requirements. On November 19, 2019, the Service received a complete application from the Applicant for an ITP under the authority of Section 10(a)(1)(B) of the ESA. If the application is approved and the Service issues a permit, the ITP would authorize the Applicant to take Indiana bats and NLEB as a result of their operation of the Project over the 35 year permit term. The Service is preparing this EA to inform the public of our proposed action and the effects of the proposed action and its alternatives, seek information from the public, and to use information collected and analyzed to make better informed decisions concerning this ITP application.
Alternatives
The Service’s NEPA regulations require that an EA include brief discussions of the proposal, the need for the proposal, environmental impacts of the proposed federal action, and the environmental impacts of the alternatives considered (43 CFR 46.310(a); 40 CFR 1508.9(b)). When the decision-maker determines that there are no unresolved conflicts about the proposed federal action with respect to alternative uses of available resources, the EA need only consider the proposed federal action and does not need to consider additional alternatives, including the no- action alternative (43 CFR 46.310(b)). The EA may also describe a broader range of alternatives to facilitate planning and decision-making (43 CFR 46.310(c)).
2.1 Development of Alternatives The scope of reasonable alternatives is defined by the purpose and need for the proposed federal action and guided by the Service’s goals and objectives. Reasonable alternatives include those that
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are practical or feasible from both a technical and economic standpoint and using common sense, rather than simply desirable from the standpoint of the Applicant. With respect to this EA, the Service identified four alternatives for consideration. Alternatives propose variations on operation of the turbines during seasons of the year when Covered Species are at risk of take. Turbine operations would vary based on the feathering (adjusting the angle of the rotor blade parallel to the wind, or turning the whole unit out of the wind, to slow or stop blade rotation) and cut-in speed (i.e., the wind speed at which turbines begin generating power and sending it to the grid) regime, which has been shown to significantly influence bat mortality rates. The alternatives also consider dates, times of night, and temperatures when Covered Species are most at risk. The alternatives do not address other aspects of the wind farm, such as turbine siting and construction, because the Project is already constructed and operating, and the only proven mechanism to reduce mortality of migrating bats is operational adjustment of the turbines. The potential effects on avian and bat resources for each of the alternatives are described in detail in Section 4.0, Environmental Consequences. Section 2.4 identifies alternatives considered but eliminated from detailed analysis, along with an explanation of why these alternatives were dismissed from consideration.
2.2 Alternatives Retained for Detailed Analysis In this EA, the Service has retained four alternatives for detailed analysis. These alternatives are evaluated based on their capacity to meet the purpose and need of the Service’s action and the Project intent (described in Section 1.3). The alternatives vary primarily based on the cut-in speeds that will be applied seasonally, the resulting take of Covered Species that is predicted to occur at those cut-in speeds, and the quantity of mitigation needed to fully offset the impact of that taking. Feathering below cut-in speeds and raising cut-in speeds above those set by the turbine manufacturer have both been shown to reduce bat fatality at multiple wind power projects (Table 2-2). As is clear from Table 2-2, the effectiveness of cut-in speeds varies between sites, and between years at the same sites so our ability to predict bat mortality rates accurately based on application of cut-in speeds by season is limited. Thus we opted for a more simplistic method to compare between alternatives that would capture the scale of difference between various operational protocols annually. Each action alternative uses the same spring and summer cut-in speed (manufacturer’s cut-in speed of 3.0 m/s); only the fall cut-in speed varies between action alternatives. Therefore, for each action alternative evaluated we started with the annual predicted take amount without cut-in speeds and then applied a reduction in take that was equal to the mean percent reduction associated with the fall cut-in speed shown in Table 2-2. For example, if a 5.0 m/s fall cut-in speed was applied, we assumed annual take would be reduced by 61 percent. This is appropriate because the majority of all-bat fatality occurs in the fall, and because we lack specific data on feathering below a manufacturer’s cut-in speed of 3.0 m/s; however, two studies have found that feathering below a manufacturer cut-in speed of 3.5 m/s and 4.0 m/s reduces all-bat fatalities by 36 and 58 percent, respectively (Table 2-2). Further, breaking out each season’s mortality rate is complex and not necessarily accurate (varying by site and by year). We also assume that reductions in mortality seen in all-bat mortality rates will apply to Covered Species similarly.
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Likewise, the Service used a simplified methodology to calculate the mitigation that would be needed to offset the impact of predicted take4 for each action alternative. We assume that documented summer habitat for both Covered Species will be preserved, and we use the Service’s Resource Equivalency Analysis (REA) models for Indiana bat (USFWS 2016a) and NLEB (USFWS 2016b) and apply a 10 percent stacking adjustment. In this simplified methodology, the Service calculates mitigation quantities that would cover the full predicted and permitted take amount, and assumed that the mitigation would all occur upfront. This was done for several reasons: 1) providing all the mitigation upfront would result in lower total mitigation need because benefits to the species would accrue over a longer period of time, and thus less total mitigation acres would be needed, so this provides a conservative minimum estimate of mitigation acreage; 2) Actual mitigation owed will be dependent on how many Covered Species are estimated to have been killed based on carcasses found during Intensive Monitoring and the resulting take estimate5 generated by USGS Evidence of Absence (EoA) software (Dalthorp et al. 2014), so actual mitigation implemented may be less than what is needed to fully offset the amount of take that is originally predicted and permitted; and, 3) The REA model uses a large number of mitigation site-specific inputs that are not available because the mitigation site(s) has not yet been identified. Predicted take of Covered Species and mitigation for the impact of take for each alternative are generated by models that have multiple inputs with variability and error. While they are estimates based on best available data, the Service recognizes they contain inherent error. The estimates generated are intended to provide a relative scale for comparison among alternatives.
2.2.1 Alternative 1: No-Action
Under this alternative, the Service would not issue an ITP to the Applicant and their HCP would not be implemented because take of Indiana bats and NLEBs would be unlikely at the Project. Under the No-Action Alternative, Project turbines would be feathered until wind speeds reach 6.9 m/s from a half-hour before sunset to a half-hour after sunrise during the entirety of the fall migratory period (August 1 through October 31) and spring migratory period (March 15 through May 15) (Project HCP Section 8.2). The spring emergence and early migration period includes March 15-April 1, and fall migration may occur through the end of October. It is possible that small numbers of individuals of Covered Species may migrate through the Permit Area during these early spring and late fall periods, though peak migration is likely to occur April 1-May 15 and August 1-October 15. The Service considers take of Covered Species to be unlikely when operating at these parameters, therefore, the Applicant would not need an ITP or to implement an HCP. The No-Action Alternative is the anticipated outcome if the Service denies the Applicant the ITP, and is the current operational strategy being implemented at the Blue Creek Wind Farm. As no take of Covered Species is likely
4 Predicted take is the Service’s or Applicant’s prediction of the amount of take that is likely to occur in the future; this take would be permitted by the ITP. 5 Estimated take is the value estimated to have occurred based on the results of site-specific mortality monitoring data entered into the USGS Evidence of Absence (EoA) software (Dalthorp et al., 2014); this take would be used to calculate total mitigation owed.
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under the No-Action Alternative, the Applicant would not conduct fatality monitoring, adaptive management, or mitigation under this alternative.
2.2.2 Alternative 2: Applicant’s Proposed Project
Under Alternative 2, the Applicant’s Proposed Project, the Service would issue an ITP to authorize incidental take of Covered Species associated with the Project’s operations as described in the Applicant’s HCP. In summary, the Applicant would feather turbine blades below 3.0 m/s from one- half hour before sunset until one-half hour after sunrise during spring migration and summer, and would feather turbine blades below 5.0 m/s from one-half hour before sunset until one-half hour after sunrise during fall migration when temperatures are above 10 degrees Celsius (Table 2.1). The Applicant would continue to operate the Project and implement their HCP, summarized below. The Applicant has requested that the Service authorize take of Covered Species under this Alternative, as described in Section 4.0 of the HCP. Based on existing curtailment studies (Table 2- 2), raising the cut-in speed to 5.0 m/s during the fall migration period is likely to reduce all-bat fatalities, including Covered Species, by an average of 61 percent as compared to operations without curtailment. As described in Section 2.2, the Service applied this 61-percent reduction to the annual take prediction. Applying this percentage, the Service predicts an annual take of 2.5 Indiana bats per year, for a total of approximately 87.5 Indiana bats over the 35-year permit term, and take of 1.6 NLEBs per year for a total of approximately 57.7 NLEBs over the 35-year permit term (Service’s predicted take). In the Project HCP, the Applicant has sought to avoid potentially underestimating the level of take by conservatively assuming a reduction in bat fatalities of 30 percent (instead of 61 percent per Table 2-2), increasing the annual take prediction to 4.39 Indiana bats and 2.96 NLEBs per year. Hence, the Applicant requests an authorized take level of 154 Indiana bats and 103 NLEBs based on the Applicant’s predicted cumulative take over the 35-year operational life of the Project (Applicant’s predicted take). Because the Applicant’s assumption of a 30 percent reduction in predicted take is a smaller reduction than what is predicted from cut-in speed studies, the requested take number will be higher than other Alternatives where the take predictions are based on the results of cut-in speed studies. Thus the Service had to develop a methodology for calculating take and comparing among the Alternatives that was consistent between all Alternatives. To apply a consistent methodology across the action alternatives in this EA, the Service evaluates the potential environmental impacts of the alternatives based on the Service’s predicted take level for Alternative 2. The Applicant’s predicted take values from the HCP are provided and analyzed throughout this EA; however, the EA document focuses on presenting the Service’s analysis for the sake of comparison between alternatives, alongside of the Applicant’s proposed take predictions. In each instance, the analysis of the environmental impact of the Applicant’s proposed action is also evaluated using the Applicant’s assumption of a 30-percent reduction in take in order to fully analyze the alternatives. To complete ESA compliance per Section 1.2.2, the Service will carry forward the Applicant’s predicted take levels in the BO for the ITP.
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2.2.2.1 Operational Minimization Measures The Applicant’s operational plan is described in HCP Section 5.2.2. Under Alternative 2, turbines would be feathered one-half hour prior to sunset to one-half hour after sunrise until wind speed and, during fall migration, temperature criteria have been met (Table 2-1). The proposed minimization plan focuses on the season, wind speed, time of day, and temperatures that are the highest periods of risk to Covered Species, while optimizing renewable energy production when risk to Covered Species is lowest.
Table 2-1. Alternative 2 Operational Minimization Plan Season Time of Day Turbine Operations Temperature One-half hour prior to Spring All turbines feathered until Implemented at all sunset1 to one-half hour (April 1 – May 15) wind speed of 3.0 m/s temperatures after sunrise One-half hour prior to Summer2 All turbines feathered until Implemented at all sunset to one-half hour (May 16 – July 31) wind speed of 3.0 m/s temperatures after sunrise One-half hour prior to When temperature is Fall All turbines feathered until sunset to one-half hour greater than 10 degrees (August 1 – October 15) wind speed of 5.0 m/s after sunrise Celsius (°C) Winter Normal turbine operation (October 16 – March 31)
1. Civil sunset and sunrise. 2. Although no take of Covered Species is expected during summer, the Applicant will implement this measure to minimize impacts to all bats in general.
The hub would not be locked, but turbine blades would be feathered to the wind such that revolutions per minute are minimal during periods when wind speed or temperature criteria are not met. Each turbine includes a SCADA operations and communications system that allows automated independent and remote operation of the turbine. Turbine feathering will begin when the average wind speed is less than the specified cut-in speed. Turbine feathering will cease and normal operation will resume when the average wind speed is equal to or greater than the specified cut-in speed. The time period for which these averages are calculated can be set to values between 5 and 20 minutes, depending on level of refinement chosen by the Applicant. The Applicant’s rationale for the 3.0 m/s cut-in speed in spring and summer, and 5.0 m/s cut-in speed in the fall for nighttime temperatures above 10 degrees Celsius (°C), is informed by curtailment studies (Baerwald et al. 2009, Arnett et al. 2010, Arnett et al. 2013, Good et al. 2011, Good et al. 2012, Hein et al. 2013, Hein et al. 2014) and bat activity studies (Kunz 1973, Barclay 1982, Kunz et al. 2007a, Arnett et al. 2008, Arnett and Baerwald 2013, Roby and Gumbert 2016a and 2016b, USFWS 2016c, Brooks et al. 2017). Table 2-2 presents the results of the publicly
December 2019 U.S. Fish and Wildlife Service 10 DRAFT ENVIRONMENTAL ASSESSMENT FOR PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC available curtailment effectiveness studies.6 These studies suggest that feathering below 5.0 m/s, as proposed in fall, would reduce bat mortality by an average of 61 percent, with specific reductions shown between 47 to 82 percent.
Table 2-2. Results from Publicly Available Curtailment Effectiveness Studies Percent Mean Percent Normal Cut- Treatment Reduction in Reduction in Study Name In Speed Cut-In Speed Source All-Bat All-Bat (m/s) (m/s) Mortality Mortality Fowler Ridge, IN 20111 3.5 3.5 36 36 Good et al. 2012 Summerview, Alberta 1 4.0 4.0 58 58 Baerwald et al. 2009 Fowler Ridge, IN 2011 3.5 4.5 57 Good et al. 2012 Anonymous Project (AN01), 52 3.5 4.5 47 Arnett et al. 2013 USFWS Region 3 Casselman, PA 2008 3.5 5.0 82 Arnett et al. 2010 Casselman, PA 2009 3.5 5.0 72 Arnett et al. 2010 Fowler Ridge, IN 20102 3.5 5.0 50 61 Good et al. 2011 Pinnacle, WV 20123 3.0 5.0 47 Hein et al. 2013 Pinnacle, WV 2013 3.0 5.0 54 Hein et al. 2014 Summerview, Alberta 3.5 5.5 60 Baerwald et al. 2009 Fowler Ridge, IN 2011 3.5 5.5 73 Good et al. 2012 61 Anonymous Project (AN01), 3.5 5.5 72 Arnett et al. 2013 USFWS Region 3 Sheffield, VT4 4.0 6.0 60 60 Arnett et al. 2013 Casselman, PA 2008 3.5 6.5 82 Arnett et al. 2010 Casselman, PA 2009 3.5 6.5 72 Arnett et al. 2010 77 Fowler Ridge, IN 20102 3.5 6.5 78 Good et al. 2011 Pinnacle, WV 2013 3.0 6.5 76 Hein et al. 2014 1. Manufacturer’s cut-in wind speed was not raised, but turbines were feathered under normal cut-in wind speed. 2. Study did not include turbine feathering below cut-in speed. 3. This effect was only found when an outlier (i.e., a night when 7 fatalities were recovered from a 5 m/s all-night treatment turbine) was removed from the dataset. 4. Raised cut-in speeds were applied only when temperatures were above 9.5°C (49°F).
2.2.2.2 Mitigation The Applicant proposes mitigation measures to compensate for the impact of estimated take of Indiana bats and NLEBs, as described in Section 5.2.3 of the Project HCP. The Applicant has not yet finalized the exact mitigation projects proposed for implementation; however, the Applicant has committed to siting mitigation areas within Ohio and of sufficient quantity and quality to offset the
6 Table 2-2 differs from Table 5.2 in the HCP because the Service has deleted references to studies that did not provide a site-specific within-year control and those that included unusual components that may have influenced the study results.
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full impact of estimated take in two phases. Phase I would cover the first 20 years of the Applicant’s predicted take (4.39 Indiana bats and 2.96 NLEB per year, times 20 years), including a mitigation project(s) secured with a management plan for bat conservation within two years of ITP issuance. At year 19, USGS’s EoA software (Dalthorp et al., 2014) would be used to generate Indiana bat and NLEB annual take estimates resulting from the first 19 years of data collected during Intensive Monitoring. The estimated take rates would be multiplied across the 35 year permit term to estimate take and calculate mitigation need across the remainder of the permit term. Phase II (last 15 years of permit term) mitigation would be needed if estimated take across the 35-year permit term had not been completely mitigated by Phase I mitigation. Any required Phase II mitigation project(s) would be implemented by year 19 of the ITP (see Project HCP Section 5.2.3). The Indiana Bat Resource Equivalency Analysis (REA) Model (USFWS 2016a), the NLEB REA Model (USFWS 2016b), and the USFWS Guidelines for Non-REA Staging/Swarming Mitigation Option (USFWS 2016d)7 will be used to evaluate the amount of take a mitigation project will offset for Covered Species, unless a conservation bank or other mitigation method becomes available as a viable mitigation option for the Covered Species (see Section 9.1 of the Project HCP). Based on guidance from the Service, mitigation projects that provide conservation value for both of the Covered Species will be adjusted by a 10 percent stacking ratio when more than one species is present. Mitigation projects must occur in Ohio and within the documented summer home range of a maternity colony of one or both Covered Species (using the REA model to calculate mitigation acreage) or within the swarming buffer of a documented hibernaculum for one or both Covered Species (using the non-REA staging/swarming mitigation option). Mitigation projects may include gating of a hibernaculum, preservation of existing suitable forested habitat, or creation of suitable foraging and roosting habitat that is protected and managed for the benefit of Covered Species. Restoration projects would entail planting native Ohio hardwood trees at a minimum of 436 trees per acre and ensuring at least 300 native, live, and healthy trees per acre are established at the end of the fifth growing season after planting. The mitigation site(s) would need documented occupancy of the species for which mitigation is provided within 10 years. Mitigation sites would be protected in perpetuity and would be subject to a conservation easement, deed restriction, or other similar legal mechanism. Template language for easements that protect habitat for listed bats can be found in Appendix D. The Service must confirm in advance that the mitigation site is appropriate as a mitigation location for Covered Species, and must approve the form of site protection instrument and a management/monitoring plan for all mitigation sites. The Project mitigation plan is described in detail in Section 5.2.3 of the Project HCP and is subject to Service approval. To support comparison of alternatives in this EA and as described in Section 2.2, the Service used a simplified methodology to calculate an example summer habitat preservation quantity using the REA models and applying the 10 percent stacking adjustment where both Covered Species would be present. In this simplified methodology, the Service calculated mitigation quantities that would cover the full predicted and permitted take amount, and assumed that the
7 The Applicant may, at its discretion, opt to use a more current version of any of the Models, should one be published or provided by the Service.
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mitigation would occur upfront (instead of a two-phased mitigation plan as proposed by the Applicant). Under Alternative 2, a total of 219.8 acres of summer habitat preservation would be needed to mitigate the impact of Service predicted take, while 382.1 acres of summer habitat preservation would be needed to mitigate the impacts of the Applicant’s predicted take. As noted above, actual mitigation acreage will depend on the final mitigation project(s) selected and estimated take level generated following Intensive Monitoring at the Project. 2.2.2.3 Monitoring and Adaptive Management The monitoring program that would be implemented as part of the HCP consists of two components: take limit compliance monitoring and mitigation effectiveness monitoring. The goal of take limit compliance monitoring is to ensure compliance with the terms of the ITP. The Applicant will do this by conducting Intensive Monitoring (Project HCP Section 6.1.2) for carcasses during the first two years of the Project and every fifth year thereafter, and Operations Monitoring (Project HCP Section 6.1.3) for carcasses in all other years. Intensive Monitoring is designed to have an annual probability of detection (g value) of 0.15 (e.g., approximately 15 percent of all bat carcasses would be detected per year). Over the 35-year permit term, Intensive Monitoring at this level would detect approximately 3.4 percent of all bat carcasses. Operations Monitoring consists of year-round reporting of carcasses observed by all on-site personnel. The results of monitoring would be entered into the USGS EoA software package (Dalthorp et al. 2014). Finds of covered bat carcasses during Intensive Monitoring would be entered into EoA software to generate take rate estimates at the 50-percent credibility level (“estimated take”). If covered bat carcasses are detected during Operations Monitoring, the default prior in EoA will be replaced with a truncated prior equal to the number of covered bat carcasses found that prevents the take estimate from being less than the total number of carcasses detected8. If covered bat carcasses are detected during Operations Monitoring, the next Intensive Monitoring event will be moved up such that it is implemented the following year. In this way, EoA software will be used to generate estimated take for determining ITP compliance, to ensure mitigation fully offsets the estimated take, and to trigger adaptive management (Dalthorp and Huso 2015). Monitoring reports will be submitted to the Service by April 1 the calendar year following each round of Intensive Monitoring. Information on bats found incidentally during Operations Wildlife Monitoring will also be made available to the Service annually. The primary objectives of Mitigation Effectiveness Monitoring are to ensure that the mitigation project(s) is (are) meeting the Performance Criteria (Project HCP Section 5.2.3) and that the conditions in the legal protection instrument are being met. Mitigation effectiveness monitoring will also document that the quantity of mitigation implemented to date is sufficient to fully offset, and stay ahead of, the impact of take that has been estimated to have occurred to date, and is projected to occur over the next 5-year period.
8 Use of EoA to address covered bat carcasses found during operations monitoring is being evaluated by USGS and will be the subject of a forthcoming Open File Report.
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Based on information derived from monitoring, adaptive management would be used to make modifications to the minimization and mitigation measures if the Applicant and Service find these measures have been ineffective at meeting the biological goals and objectives of the HCP. For example, if EoA’s short term trigger (Dalthorp and Huso 2015) is met, this indicates that monitoring data over a 6–year rolling window estimated a take rate that exceeds the predicted take rate with 95 percent confidence. In this event the Applicant may change operational protocols (e.g., increases in cut-in speeds per season, changes to the dates that define seasons, changes in temperature that triggers cut-in speeds, etc.), based on the data available to inform the change. Changes made would ensure take of Covered Species remains below the authorized total in the ITP. If EoA’s long term trigger (Dalthorp and Huso 2015) indicates that the permitted level of take has been met or exceeded (based on the cumulative estimated take using the 50th credible bound), the Applicant will feather turbines at wind speeds below 6.9 m/s from one-half hour before sunset to one-half hour after sunrise in spring and fall to avoid additional take of the Covered Species. EoA’s reversion trigger (Dalthorp and Huso 2015) may be implemented to reverse an adaptive management response if the monitoring data collected to date indicate the estimated take rates of both Covered Species are equal to or less than 60 percent of the predicted take rates with 95 percent confidence. Adaptive management for mitigation may include, as an example, if monitoring indicates a decline in forest canopy cover or an increase in non-native woody species such that it exceeds 10 percent of the site, adaptive management would be triggered to restore the habitat characteristics of the mitigation site per performance criteria in a Service-approved management plan. Further details of the monitoring program and adaptive management are provided in Section 6.0 of the Project HCP. In addition, the Project HCP includes funding assurances in Section 7.0 that assure that the Applicant will fully implement the HCP as well as contingency mechanisms in the event they are needed. The Project HCP also identifies changed and unforeseen circumstances in Section 9.0, to ensure commitments made in the HCP and compliance with the ITP are assured by identifying specific triggers and response plans for foreseeable changes during the permit term.
2.2.3 Alternative 3: More Restrictive Operations
2.2.3.1 Operational Minimization Measures Under Alternative 3, all turbines would be feathered up to 3.0 m/s during the spring migration season (April 1 through May 15), 3.0 m/s in summer (May 1-July 31), and 6.5 m/s during the fall migration season (August 1 through October 15), applied in all seasons from one half-hour before sunset to one half-hour after sunrise when the ambient temperature is above 10°C based on a 5- minute rolling average. Additionally, the temperature threshold in spring and summer could allow limited additional operations during low-temperature and low-wind speed times during the spring and summer when all bat activity is very low (see Project HCP Section 3.4.2 for detailed temperature threshold background). Based on existing curtailment studies (Table 2-2), raising the cut-in speed to 6.5 m/s during the fall migration period is likely to reduce all-bat fatalities, including Covered Species, by an average of 77
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percent as compared to operations without curtailment. As described in Section 2.2, the Service applied this 77 percent reduction to the annual take prediction. Applying this percentage, the Service predicts Alternative 3 would result in the take of 1.4 Indiana bats per year, for a total of 49 Indiana bats over the 35-year permit term, and take of 1 NLEB per year for a total of 34.1 NLEBs over the 35-year permit term. This is the level of take that would be authorized in an ITP issued by the Service under Alternative 3. 2.2.3.2 Mitigation The HCP would include mitigation to fully offset the impact of the taking of Indiana bats and NLEBs. The type of mitigation under this alternative and method for calculating quantity of mitigation owed using take estimates generated by EoA software (Dalthorp et al., 2014), REA Models (USFWS 2016a, USFWS 2016b), and the USFWS Guidelines for Non-REA Staging/Swarming Mitigation Option (USFWS 2016d) would be the same as that described for Alternative 2 (in Section 2.2.2.2) and in Section 5.2.3 of the Project HCP. However, less mitigation would be needed due to the estimated decrease in the impact of take when operating at a higher cut-in speed. As described in Section 2.2, for the purposes of this EA, the Service used a simplified methodology to calculate an example summer habitat preservation quantity using the REA models and applying the 10 percent stacking adjustment where both Covered Species would be present. For purposes of comparison among the alternatives, this assumed mitigation would occur for the full predicted and permitted take amount upfront (instead of in 2 phases). Under Alternative 3, a total of 128.4 acres of summer habitat preservation would be needed to mitigate the impact of take that would be authorized by the ITP. 2.2.3.3 Monitoring and Adaptive Management The Applicant would implement post-construction monitoring consisting of compliance monitoring and mitigation effectiveness monitoring. When using EoA software to estimate take, it requires a greater amount of search effort to have a specific amount of credibility (e.g., 50 percent) around smaller take estimates than larger take estimates. According to the Applicant, the lower take limits would require a doubling of take limit compliance monitoring effort and cost to document ITP compliance using the EoA software and cause a power production loss approximately 8 times that of Alternative 2 (see HCP Section 8.3). This additional monitoring could be achieved in many different ways, for example by searching twice as hard (ex., a g value of 0.3 in Intensive Monitoring years), or by searching at the same annual g value but twice as frequently, any of which would increase the Applicant’s monitoring costs. Mitigation effectiveness monitoring would be reduced to correspond to the reduced mitigation acreage needed to offset the impact of the take. The Adaptive management framework would be the same as that described under Alternative 2, and in Section 6.0 of the Project HCP, but would respond to the lower take numbers permitted under this Alternative. Funding assurances and changed/unforeseen circumstances would also be similar to Alternative 2, as described in Sections 7.0 and 9.0 of the HCP, except that the funding assurance dollar values would differ because mitigation costs would be less and monitoring cost would be greater under Alternative 3.
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2.2.4 Alternative 4: Less Restrictive Operations
2.2.4.1 Operational Minimization Measures Under Alternative 4, all turbines would be feathered up to 3.0 m/s in spring and summer, and 4.0 m/s in fall, from one-half hour before sunset to one-half hour after sunrise when the ambient temperature is above 10°C based on a 5-minute rolling average. This is a less restrictive operational alternative, which would have greater impacts to bats than Alternative 2 and require increased mitigation, per Section 2.2.4.2 below. Based on existing curtailment studies (Table 2-2), raising the cut-in speed to 4.0 m/s during the fall migration period is likely to reduce all-bat fatalities, including Covered Species, by an average of 58 percent as compared to operations without curtailment. As described in Section 2.2, the Service applied this 58-percent reduction to the annual take prediction. Applying this percentage, Alternative 4 would result in predicted take of 2.6 Indiana bats per year, for a total of 91 Indiana bats over the 35-year permit term, and predicted take of 1.8 NLEBs per year for a total of 62.2 NLEBs over the 35-year permit term. This is the level of take that would be predicted and authorized in an ITP issued by the Service under Alternative 4. 2.2.4.2 Mitigation The HCP would include mitigation to fully offset the impact of the taking of Indiana bats and NLEBs. The type of mitigation under this alternative and method for calculating quantity of mitigation owed using EoA software (Dalthorp et al., 2014), REA Models (USFWS 2016a, USFWS 2016b), and the USFWS Guidelines for Non-REA Staging/Swarming Mitigation Option (USFWS 2016d) would be the same as that described for Alternative 2 (in Section 2.2.2.2) and in Section 5.2.3 of the Project HCP. However, more mitigation would be needed due to the estimated increase in the impact of take when operating at a lower cut-in speed. As described in Section 2.2, for the purposes of this EA, the Service used a simplified methodology to calculate an example summer habitat preservation quantity using the REA models and applying the 10 percent stacking adjustment where both Covered Species would be present. For purposes of comparing the alternatives, we assumed mitigation would occur for the full predicted and permitted take amount upfront (instead of in 2 phases). Under Alternative 4, a total of 233.9 acres of summer habitat preservation would be needed to mitigate the impact of take that would be authorized by the ITP. 2.2.4.3 Monitoring and Adaptive Management The Applicant would implement post-construction monitoring consisting of compliance monitoring and mitigation effectiveness monitoring. When using EoA software to estimate take, it takes a lower amount of search effort to have a specific amount of credibility (e.g., 50 percent) around larger take estimates than smaller take estimates. Thus, the monitoring level of effort to document ITP compliance using the EoA software would be lower under this Alternative than under Alternative 2, the Applicant’s Proposed Project. Mitigation effectiveness monitoring would be increased to correspond to the higher quantity of mitigation needed to offset the impact of the take. The adaptive management framework would be the same as that described under Alternative 2, and in Section 6.0 of the Project HCP but would respond to the higher take numbers permitted under this
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Alternative. Funding assurances and changed/unforeseen circumstances would also be similar to Alternative 2, as described in Sections 7.0 and 9.0 of the HCP, except that the funding assurance dollar values would differ because mitigation costs would be greater and monitoring cost would be less under Alternative 4.
2.3 Summary of the Alternatives Analysis Reasonable alternatives determined to minimize and mitigate adverse effects to Indiana bats and NLEBs and other resources were compared and contrasted based on results of the detailed analysis. Table 2-3 summarizes elements that would vary among the No-Action and action alternatives. For Alternative 2, the Service’s predicted take is provided first, followed by the Applicant’s predicted and requested take level in parentheses/italic. See Section 2.2.2. for discussion.
Table 2-3. Comparison of Alternatives Considered for Detailed Analysis ITP/ Permitted Alternative Operations Mitigation Monitoring Implement Take HCP 6.9 m/s cut-in speed one- half hour before sunset to one-half hour after sunrise during entire fall migration Alternative 1: No- (August 1 – October 31) None None None No Action and entire spring migration (March 15 – May 15) at all turbines and at all temperatures.
5.0 m/s cut-in speed Yes; 2 years of during fall migration Intensive (August 1 – October 15) Monitoring one-half hour before Indiana bat: (g=0.15) and in sunset to one-half hour every fifth year 2.5 (4.39) after sunrise, when the bats/year, 87.5 Yes; example thereafter for ambient temperature is estimate = life of Project; Alternative 2: (154) total. above 10°C. 219.8 (382.1) Operations Applicant’s NLEB: Yes 3.0 m/s cut-in speed acres summer Monitoring in Proposed Project1 1.6 (2.96) during spring migration habitat intervening bat/year, 57.7 (April 1 – May 15) and preservation years; (103) total. summer (May 16-July 31) Mitigation one-half hour before Monitoring; sunset to one-half hour adaptive after sunrise, at all management for temperatures. life of Project.
3.0 m/s cut-in speed Indiana bat: Yes; example Yes, double the Alternative 3: More during spring migration 1.4 bats/year, 49 estimate = effort of Restrictive (April 1 – May 15) and total. 128.4 acres Intensive Yes Operations summer (May 16-July 31), NLEB: summer Monitoring as in and 6.5 m/s cut-in speed 1 bat/year, 34.1 habitat Alternative 2;
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ITP/ Permitted Alternative Operations Mitigation Monitoring Implement Take HCP during fall migration total. preservation. Mitigation (August 1 – October 15); Monitoring as in all seasons one-half hour Alternative 2; before sunset to one-half adaptive hour after sunrise, when management for the ambient temperature life of Project. is above 10°C.
3.0 m/s cut-in speed during spring (April 1 – Yes, less effort May 15), and summer that Intensive (May 16-July 31), and 4.0 Indiana bat: Yes; example Monitoring as in m/s cut-in speed during 2.6 bats/year, 91 estimate = Alternative 2; Alternative 4: fall migration (August 1 – total. 233.9 acres Mitigation Less Restrictive Yes October 15); all seasons, NLEB: summer Monitoring as in Operations one-half hour before 1.8 bats/year, habitat Alternative 2; sunset to one-half hour 62.2 total. preservation. adaptive after sunrise, when the management for ambient temperature is life of Project. above 10°C. 1. For Alternative 2, the Service’s predicted take is provided first, followed by the Applicant’s predicted and requested take level in parentheses/italic. See Section 2.2.2. for discussion.
2.4 Alternatives Eliminated from Detailed Analysis NEPA requires that federal agencies consider and objectively evaluate a range of reasonable alternatives, and briefly explain the basis for eliminating those alternatives not retained for detailed analysis (40 CFR 1508.9). Early discussions between the Service and the Applicant on potential minimization and mitigation measures resulted in an initial list of potential alternatives for achieving the purpose and need of the Service and Applicant’s Project. Some of these alternatives were later determined to not meet the purpose and need of either the Service or Applicant. Alternatives considered and eventually dismissed from detailed analysis include Project shut-down at night during the active bat period, and an alternative with 6.5 m/s cut-in speeds applied in both spring and fall. However, as shut down at night during the active bat period would be more onerous to the Applicant than long-term operation at 6.9 m/s during spring and fall migration as per Alternative 1 with the same result (take of Covered Species unlikely to occur) nightly shut down during the bat active period was eliminated from consideration. Because spring risk to all bats is lower than fall risk, spring may not warrant as high of cut-in speeds, therefore the 6.5 m/s cut-in speed in spring and fall approach was eliminated from consideration (HCP Section 8.3). An additional alternative was considered that included the same HCP implementation with more intensive monitoring and a permit duration of 6 years. This alternative was dismissed because
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there is no assurance that additional permits would be re-issued following the 6-year period and this approach puts a considerable financial and labor-intensive burden on the Applicant to repeat the HCP process for a project with an operational life extending out to 35 years, while not reducing annual take any further.
Affected Environment
The affected environment is the area and its resources potentially impacted by the Proposed Federal Action and alternatives. The purpose of describing the affected environment is to define the context in which the impacts would occur. To make an informed decision about which alternative to select, it is necessary to first understand which resources would be affected and to what extent. The affected environment section of this document provides the context for this understanding. The affected environment includes those settings where any activities associated with the Proposed Federal Action would occur. This is the Plan Area, which includes 1) the Permit Area--the site of Project operations and monitoring, and 2) the mitigation area(s). However, as the mitigation area(s) has not yet been specifically identified within Ohio, the following affected environment discussion provides detail relative to the Permit Area and provides a more general discussion of the potential habitat that may be impacted from mitigation projects in the Plan Area.
3.1 Overview of the Permit Area The Project is located in Van Wert and Paulding counties in northwestern Ohio, north of the city of Van Wert. The Permit Area extends to the outermost boundary of the parcels leased for the Project and covers 40,426 acres (Figure 1-1). The primarily agricultural landscape is crisscrossed by a network of local and state roads, open ditches and subsurface tiled drains, and electrical power lines. On the leased parcels, private landowners will continue their current land uses in conjunction with the wind development. Nearby small towns include Scott, Convoy, Grover Hill, and Haviland. The Project is situated within the Huron/Erie Lake Plains Ecoregion, which encompasses a large portion of northern Ohio and part of southeastern and east-central Michigan (Woods et al. 1998). The Huron/Erie Lake Plains Ecoregion is a broad, fertile plain punctuated by relict sand dunes, beach ridges, and end moraines. The region is characterized by nearly flat topography; the Permit Area is relatively flat with no hills, ridges, or other areas of elevated topography. Although carbonate rock is present beneath the ground surface at depths of 6 to 21 meters, there are no records or observed evidence of karst topography (e.g., sinkholes, solution cavities) to suggest the potential presence of caves in vicinity of the Permit Area (BHE Environmental 2010). According to the 2011 National Land Cover Database (USGS 2011, Homer et al. 2015) the two main land cover types in the Permit Area are cultivated crops (92.5 percent) and developed lands (6.3 percent). Deciduous forest, herbaceous cover, open water, barren land, and wetlands each account for less than 1 percent of the total land cover in the Permit Area (Figure 3-1). Cultivated cropland is ubiquitous throughout the Permit Area and the Project’s vicinity, while deciduous forest is generally restricted to small, isolated tracts of forest and windbreaks, fence lines and hedgerows
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bordering fields, and residences, farms, and roads scattered throughout the vicinity of the Project. Wetlands and open water are rare within the Project vicinity and are limited primarily to farm ponds and areas along small creeks and irrigation ditches. Developed areas are scattered along roads throughout the Project vicinity. As described in Section 1.1.1, the 304-MW Project consists of 152 wind turbines, underground and overhead power collection lines, two substations, one O&M facility, access roads, and two permanent meteorological towers. As a leaseholder, the Applicant’s rights are limited to those incorporated in the lease agreement with each landowner, which allow for safe and effective construction and operation of the Project. The Applicant has no control over landowner activities on the properties where the Project is located to the extent not covered in specific lease provisions.
3.2 Overview of the Plan Area (Mitigation Habitat Options) Mitigation for the impacts associated with Alternatives 2, 3, or 4 will occur in Ohio, and may be comprised of one or more of the following options: gating of a hibernaculum used by one or both Covered Species; permanent preservation of existing suitable forested habitat where a maternity colony where one or both Covered Species have been documented to occur in the summer; permanent preservation of existing suitable forested habitat near a hibernaculum where one or both Covered Species have been documented to occur; creation and permanent preservation of suitable foraging and roosting habitat where a maternity colony of one or both Covered Species have been documented to occur in the summer; or creation and permanent preservation of suitable foraging and roosting habitat near a hibernaculum where one or both Covered Species have been documented to occur. A mitigation site may count toward mitigation for both covered species only if summer or winter colonies of both species have been documented to occur there. Forests cover approximately 30 percent (7.9 million acres) of Ohio’s total area (Albright 2018). Forest habitat is classified by composition. The three most common forest habitat types in Ohio are oak/hickory (comprising 63 percent of forest land), maple/beech/birch (comprising 21 percent of forest land), and elm/ash/cottonwood (comprising 9 percent of forest land; Albright 2018). Covered Species are known to occur throughout Ohio in deciduous forest land, most often found in oak/hickory and maple/beech/birch forest habitat types. Large portions of Ohio have been cleared of historic forested areas, drained, and converted to agriculture. Currently there are approximately 13.9 million acres of agricultural operations in Ohio (USDA 2019), covering over half of the state’s total area (about 53 percent).The majority of this is in cultivated cropland, with soybeans and corn accounting for approximately 62 percent of total agricultural operations (USDA 2019). Covered Species often occur in Ohio where the landscape is comprised of a patchwork of forest and agricultural uses. Natural cave or sinkhole habitats in Ohio could provide hibernation habitat for Covered Species. These areas are known as karst landforms, associated with significant amount of limestone, dolomite, and gypsum bedrock at or near the surface where soil and rock deposited by ancient glaciers is relatively thin. Nearly one-third of Ohio is underlain by bedrock that has the potential to develop karst features; however, less than two percent of the Ohio landscape includes karst terrain
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because most associated bedrock in Ohio is covered with a thick layer of glacial deposits that impede active cave or sinkhole formation (Hull 1999). Probable karst areas are concentrated in three counties in south/southwest Ohio (Adams, Brown, and Highland counties) and three counties in north/northwest Ohio (Seneca, Sandusky, and Erie counties), and otherwise scattered primarily in western Ohio (ODGS 2006]). Sandstone outcroppings in northeastern Ohio have also been documented to potentially serve multiple habitat functions for Indiana bat, including as migration stopover, location for swarming, or for hibernation (USFWS 2007a). Covered Species in Ohio have also been documented to hibernate in abandoned limestone and coal mines. Ohio’s largest bat hibernaculum in Preble County is an abandoned limestone mine and supports thousands of individual bats of Covered Species. While this hibernaculum is already gated, habitat around it could be protected or restored. Coal mining via underground mines was historically common in southern and eastern Ohio, where remaining underground coal mines are still concentrated (ODNR 2019a), and many of these historic mines have now been abandoned. ODNR has records for 3,424 abandoned mines located primarily in eastern and southern Ohio with an estimated total extent of nearly 400,000 acres (ODNR 2019b). Abandoned mines sometimes develop thermal regimes suitable for bat hibernation. Covered Species have been documented hibernating in abandoned coal mines in Wayne National Forest in Lawrence County.
3.3 Resources Evaluated and Dismissed from Further Analysis Several resources were identified which do not have the potential to be impacted by the Applicant’s Proposed Project, No Action, or other action alternatives. Because wind project operators are not legally required to seek or obtain an ITP (i.e., the wind project can operate without an ITP and the ITP does not authorize operation of a project), the Applicant has the option of continuing Project operations without filing an ITP application. The Service has concluded that a number of resources would not be impacted by the Applicant’s Proposed Project, No Action, or other action alternatives; these include: environmental justice, land use, fisheries, geology and soils, human health and safety, surface waterbodies and floodplains, vegetation, visual resources, and wetlands. These resources are not discussed further in this document. Regarding historic and cultural resources, the Service has concluded that because there are no tribal lands in Ohio, and no construction is proposed within the HCP, impacts to historic resources or tribal lands is unlikely. As noted in Section 5.1, the Service will send this Draft EA to Tribes with historic interest in Ohio during the public comment period to solicit input. Impacts to these resources are not discussed further in this document. For other similar ITP applications, the Service has evaluated potential effects to air quality, noise, and social and economic values (USFWS 2019b, USFWS 2017a, USFWS 2016e). In each case, the Service found that continued wind project operations under an HCP would have minor or negligible effects on these resources. None of these prior analyses, which evaluated a comparable range of alternatives, have found a significant adverse effect or required mitigation related to these resources. The Service has reviewed these existing NEPA analyses and concluded the information continues to be compelling and relevant to the alternatives in this Draft EA, and that the Applicant’s
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Proposed Project, No Action, and other action alternatives do not introduce a new circumstance not previously analyzed. The existing NEPA analyses discussed above are incorporated by reference into this Draft EA (USFWS 2019b, USFWS 2017a, USFWS 2016e), consistent with federal regulation (43 CFR §46.120). Therefore, impacts to these resources are not discussed further in this document.
3.4 Resources Evaluated and Brought Forward for Detailed Analysis
3.4.1 General Wildlife Resources
This section addresses general wildlife (excluding birds and bats). Birds and bats are addressed in Sections 3.4.2 and 3.4.3, respectively. General wildlife includes common terrestrial and aquatic animals and rare, threatened, and endangered animals. Project operations may affect wildlife resources within the Permit Area. The proposed mitigation projects are expected to have a beneficial effect on wildlife resources in the Plan Area. 3.4.1.1 Habitat Conditions for General Wildlife The Project is located within an area formerly dominated by extensive elm (Ulmus spp.), ash (Fraxinus spp.) swamps, and American beech (Fagus grandifolia) forests, with oak (Quercus spp.) savanna typically restricted to sandy, well drained dunes and beach ridges. Today, most of the forests have been cleared and artificially drained for highly productive farms that produce corn (Zea mays), soybeans (Glycine max), livestock, and vegetables. As described in Section 3.1, the dominant cover type in the Permit Area is cultivated cropland, which accounts for 92.5 percent of the Permit Area. Developed lands account for 6.3 percent of the Permit Area, with deciduous forest, herbaceous cover, open water, barren land, and wetlands each accounting for less than 1 percent of the total land cover in the Permit Area (Figure 3-1). Deciduous forest is restricted to small, isolated tracts of forest and windbreaks, fence lines and hedgerows bordering fields, and residences, farms, and roads spread throughout the vicinity of the Project. Water and wetlands are limited primarily to farm ponds and areas along small creeks and irrigation ditches. Because most of the habitat consists of agricultural lands, a majority of the terrestrial wildlife associated with the Permit Area are generalist species that are adapted to living in agricultural environments. Limited habitat for aquatic species exists in the Permit Area. There are no state or federal nature preserves, forests, public recreation areas, natural areas, or fish and wildlife areas in or adjacent to the Permit Area. Common mammal species that may be present include white-tailed deer (Odocoileus virginianus), raccoon (Procyon lotor), red fox (Vulpes vulpes), striped skunk (Mephitis mephitis), squirrels (Sciurus spp.), eastern chipmunk (Tamias striatus), woodchuck (Marmota monax), Virginia opossum (Didelphis virginiana) white-footed deermouse (Peromyscus leucopus), eastern mole (Scalopus aquaticus), meadow vole (Microtus pennsylvanicus), and several shrew species (Blarina brevicauda, Cryptotis parva, and Sorex spp.) (ODNR 2016, BHE Environmental 2008). Aquatic areas, although very limited in the Permit Area, may be used by amphibians such as American toad (Anaxyrus americanus) and Fowler’s toad (Bufo woodhousii fowleri), and reptiles such as common snapping turtle (Chelydra serpentine serpentina), midland
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painted turtle (Chrysemys picta marginata), and garter snake (Thamnophis sirtalis). See Section 3.2 for additional information about habitat in the Plan Area relevant for potential mitigation sites. 3.4.1.1 Threatened and Endangered Wildlife Based on current information from the Service and ODNR, there are no state or federally-listed wildlife species (excluding birds and bats) in Van Wert or Paulding County, and therefore not in the Permit Area (USFWS 2018a, ODNR 2019d). No state or federally-listed wildlife species were observed during pre-construction environmental surveys or during post-construction monitoring in the Permit Area. Not including birds or bats, the Plan Area, which includes the state of Ohio, is within the known range of 15 other federally-listed wildlife species: two reptiles, one fish, nine freshwater mussels, and three insects. Aside from birds and bats there are 109 state-listed endangered species and 46 state-listed threatened species in Ohio (ODNR 2019d). Mitigation in the Plan Area would not be approved by the Service if adverse effects to or take of state or federally- listed species would occur.
3.4.2 Avian Resources
For the purposes of this EA, the scope of this analysis includes avian resources within the Permit Area specifically (Sections 3.4.2.1-3.4.2.5), and birds in forested Ohio ecosystems of the Plan Area generally (Section 3.4.2.6). Birds are highly mobile, and dispersal and migration are important aspects of their life strategies. Birds will occur within and travel through the Permit Area while flying to and from natural resources within the surrounding landscape and during migration. All bird species known to occur within the Permit Area are addressed in this section. Avian species that occur in the Permit Area are diverse and use various habitats. To facilitate analysis, the Service considered avian resources based on the following group classifications: Passerines (songbirds and corvids); Shorebirds; Waterbirds (waterfowl, loons, grebes); Game birds; and Raptors (falcons, eagles, hawks, vultures, and owls). 3.4.2.1 General Conditions in the Permit Area Potential resources for avian species include tilled row-crop fields that may be used by shorebirds, blackbirds, and waterfowl as over-wintering habitat and stopover habitat during migration. Tilled crop-fields also provide foraging opportunities for raptors, such as red-tailed hawks (Buteo jamaicensis) and northern harriers (Circus cyaneus). Raptors, owls, and corvids may perch on telephone poles and in hedgerows along roadsides in the Permit Area. Farm and residential buildings may provide roosting habitat for some species of passerines and owls. Trees are limited to narrow bands of trees and shrubs, or small woodlots often associated with field edges, property lines, streams, drainages, or wetlands; they provide little habitat for tree-nesting birds and perches for stopover during migration. As many birds migrate at high altitudes, the airspace above the Permit Area is potential migration habitat for a variety of species of birds, including passerines, shorebirds, waterbirds, and raptors.
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3.4.2.2 Pre-Construction Surveys Pre-construction surveys for avian species included a site visit on October 10, 2008 (BHE Environmental 2008) and additional wildlife surveys conducted in 2009 (WEST 2009, OPSB 2010). The 2009 surveys included fixed-point avian use surveys and raptor nest surveys within the Permit Area and within 0.25 miles of the Project boundary. Passerines The 2008 site visit documented nine passerine species (BHE Environmental 2008), including the American goldfinch (Carduelis tristis), black-capped chickadee (Poecile atricapilla), blue jay (Cyanocitta cristata), European starling (Sturnus vulgaris), house sparrow (Passer domesticus), mourning dove (Zenaida macroura), northern cardinal (Cardinalis cardinalis), red-bellied woodpecker (Melanerpes carolinus), and yellow-rumped warbler (Dendroica coronate). Two additional species, both Ohio state species of concern, were identified in a 2009 survey: the sedge wren (Cistothorus platensis) and bobolink (Dolichonyx oryzivorus) (OPSB 2010). Shorebirds and Waterbirds The 2008 site visit identified mallard ducks (Anas platyrhyncos) and killdeer (Charadrius vociferous) in the Permit Area (BHE Environmental 2008). In addition, an Ohio Natural Heritage Database search revealed a great blue heron (Ardea herodias) rookery (10-15 nests) within the Flatrock Creek riparian corridor, which is located within a half mile of the Project boundary (OPSB 2010). ODNR recommended mitigative measures to reduce impacts to the rookery, which included a 0.5- mile non-development buffer around the rookery during construction, as well as avoiding staging or operating machinery within the 0.5-mile buffer during breeding season (February 1 to July 1) once Project operations began (OPSB 2010). Game Birds One quail species, the northern bobwhite (Colinus virginiana), was identified in the Permit Area during the 2009 survey (OPSB 2010). Raptors The October 2008 site visit identified the turkey vulture (Cathartes aura) in the Permit Area (BHE Environmental 2008). Surveys in 2009 documented two additional raptor species through limited sightings: the northern harrier and sharp-shinned hawk (Accipiter striatus) (OPSB 2010). The northern harrier is an Ohio state-endangered species, and the sharp-shinned hawk is an Ohio state species of concern. No raptor nests were observed in the woodlots in the Permit Area (WEST 2009). Based on the intense agricultural use of the Permit Area and the lack of significant habitat areas, the Service has indicated low potential risk to nesting raptors (OPSB 2010). The Permit Area is within the known range of the bald eagle (Haliaeetus leucocephalus; OPSB 2010). However, due to the Project type, location, and lack of nests within 5 miles of the Permit Area, impacts are unlikely.
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3.4.2.3 Post-Construction Monitoring Fatality searches were conducted in 2012, 2013, and 2015 at all 152 turbines, in accordance with ODNR’s On-Shore Bird and Bat Pre- and Post-Construction Monitoring Protocol for Commercial Wind Energy Facilities in Ohio, Option B protocol (ODNR 2011). Table 3-1 provides a summary of the bird fatalities documented during each monitoring season at the Project. In 2012, monitoring found 107 birds representing 38 identified species. In 2013, monitoring found 270 birds representing 41 identified species. In 2015, monitoring found 202 birds representing 37 identified species. In total over all three years, monitoring documented 513 fatalities representing 71 identified species and 66 fatalities of birds that were not identified to species for a total of 579 fatalities. Passerines represented the largest proportion of birds (82 percent) found over the three survey years. Shorebirds and raptors represented 10 percent and 4 percent of total bird fatalities, respectively. The top three bird species found most frequently as fatalities across all years were: horned larks (Eremophila alpestris) at 37 percent (n = 212), killdeer at 10 percent (n=57), and golden-crowned kinglet (Regulus satrapa) at 8 percent (n=46). Each of the other species comprised less than 3 percent of total fatality across all years. None of the birds found were federal or state-listed species. Seven species were USFWS birds of conservation concern, discussed further below. Overall, the bird fatality rate was estimated to be 1.43, 6.25, and 3.41 bird fatalities per MW per year for 2012, 2013, and 2015, respectively (Shoenfeld estimator; Shoenfeld 2004).
Table 3-1. Post-Construction Monitoring 2012, 2013, and 2015 – Bird Fatalities Bird Total Number of Year Fatality Rate Bird Fatalities Identified Species (per MW per year) 2012 107 38 1.43 2013 270 41 6.25 2015 202 37 3.41 Total 579 711 3.7 (average) 1. Total number of unique species over three-year period; value is not a sum of the rows due to overlap in species occurrence.
3.4.2.4 Listed Species No state or federally-threatened or endangered bird species were found during post-construction monitoring in 2012, 2013, and 2015. 3.4.2.5 USFWS Birds of Conservation Concern The Fish and Wildlife Conservation Act mandates the Service to “identify species, subspecies, and populations of all migratory non-game birds that, without additional conservation actions, are likely to become candidates for listing under the ESA” (16 USC § 2912). These species are “Birds of Conservation Concern (BCC)” and represent the Service’s highest bird conservation priorities (USFWS 2008). The Permit Area is located in the Prairie Hardwood Transition Bird Conservation Region (BCR) 23 (Bird Studies Canada and NABCI 2014). For this BCR, the Service has identified 30
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BCC species. Among these 30 species, one was documented during pre-construction surveys (bobolink), and seven species were found during post-construction monitoring surveys: (n=1), black-billed cuckoo (Coccyzus crythropthalmus) (n=2), bobolink (n=2), brown thrasher (Toxostoma rufum)(n=2), cerulean warbler (Setophaga cerulea) (n=1), dickcissel (Spiza americana)(n=1), golden-winged warbler (Vermivora chrysoptera) (n=1), and marsh wren ( (n=1) Cistothorus palustris) (n=2). 3.4.2.6 General Conditions in the Plan Area Historically, numerous species of birds used forests in Ohio (ODNR 2015). There are no federally- listed threatened or endangered birds that are known to use Ohio’s forests. There is one state-listed endangered avian species that uses Ohio’s forests: Kirtland’s warbler (Setophaga kirtlandii) (ODNR 2019d). There are six avian state species of concern that use forests in Ohio: black-billed cuckoo, cerulean warbler, eastern whip-poor-will (Caprimulgus vociferus), red-headed woodpecker (Melanerpes erythrocephalus), ruffed grouse (Bonasa umbellus), and sharp-shinned hawk (ODNR 2019d). Additionally, there are 19 avian species listed as Species of Greatest Conservation Need in the State Wildlife Action Plan that are associated with Ohio’s forests (ODNR 2015). Agricultural habitats are man-made, artificial habitats (ODNR 2015). There are no avian species that prefer agricultural habitats over their traditional habitats (e.g. grasslands). However, some species have adapted to utilize agricultural habitats. One such species, the horned lark, has the most incidents of fatalities at operational windfarms (AWWI 2019a). Five BCRs cover portions of Ohio, including: BCR 13 (Lower Great Lakes/St. Lawrence Plan), BCR 22 (Eastern Tallgrass Prairie), BCR 23 (Prairie Hardwood Transition), BCR 24 (Central Hardwoods), and BCR 28 (Appalachian Mountains) (Bird Studies Canada and NABCI 2014). As discussed above in Section 3.4.2.5, the Permit Area is located in BCR 23; however, mitigation projects may be located in any of the five BCRs in the Plan Area. Bald eagles have made a significant recovery in Ohio since 1979 when there were only four nesting pairs remaining in the state. As of 2018 there were an estimated 286 breeding pairs of bald eagles in Ohio, with populations continuing to expand across the state (ODNR 2019e). Golden eagles’ nesting range does not include Ohio. Occasionally golden eagles will winter in Ohio and observations are scattered throughout the state (eBird 2019). The mitigation plan to be submitted by the Applicant will be subject to Service approval, and the mitigation site will not be approved if it has any adverse impact to bald or golden eagles.
3.4.3 Bat Resources
This section describes existing conditions for bats potentially within the Permit Area and in Ohio (Plan Area). For this NEPA analysis, conditions for federally listed and unlisted bats (those species not listed as threatened or endangered under the ESA) are summarized together in the following section. Section 3.4.3.2 provides additional information specific to Indiana bats and NLEBs pertinent to the analysis of Covered Species.
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3.4.3.1 Distribution, Habitat Use, and Status Twelve bat species occur in Ohio (Plan Area), ten of which have the potential to occur in the Permit Area (Table 3-2) based on species range maps and natural history (ODNR 2016). Of these ten species, two are Covered Species in the Project HCP. The Indiana bat is federally and state-listed as endangered, and the NLEB is federally and state-listed as threatened. Initial listing considerations for the Indiana bat included loss of habitat and human disturbance, especially at winter hibernacula. Currently, the main threat to Indiana bats as well as the primary listing consideration for the NLEB are impacts from white-nose syndrome (WNS), a fungal disease affecting cave- hibernating bats (see Section 3.4.3.2). As shown in Table 3-2, the Service assumes that while twelve bats occur in the Plan Area, only ten bat species may be present in the Permit Area during spring and fall migration. Two species, Rafinesque’s big-eared bat and eastern small-footed bat are unlikely to migrate through the Permit Area, due to limited distribution in Ohio and lack of suitable rocky habitat nearby. No records indicate the presence of a hibernaculum in the Permit Area or otherwise suitable winter habitat, as discussed below, so no winter presence of any Ohio bats is expected in the Permit Area. Based on summer mist net and acoustic survey data for the Project (see Section 3.4.3.3), the Service assumes Indiana bats and NLEBs are not present during the summer. Mist net survey data confirmed the summer presence of the hoary, red, and big brown bats. Summer mortality data confirmed the summer presence of hoary, silver, red, big brown, and evening bats (Section 3.4.3.3). Tricolor bats and little brown bats were detected during acoustic surveys though the date/season of these calls is not reported (HCP Appendix A).
Table 3-2. Potential Bat Presence by Season Potential Presence within Permit Area Migration Winter Common Name Scientific Name Status Summer (April 1- (Oct. 16- (May 16- May 15; March July 31) Aug. 1-Oct 31) 15) big brown bat Eptesicus fuscus Ohio: species of concern Yes No Yes Lasionycteris silver-haired bat Ohio: species of concern Yes No Yes noctivagans eastern red bat Lasiurus borealis Ohio: species of concern Yes No Yes hoary bat Lasiurus cinereus Ohio: species of concern Yes No Yes little brown bat Myotis lucifugus Ohio: species of concern Yes No Yes
northern long-eared Myotis Federal: threatened No No Yes bat septentrionalis Ohio: threatened Federal: endangered Indiana bat Myotis sodalis No No Yes Ohio: endangered
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Potential Presence within Permit Area Migration Winter Common Name Scientific Name Status Summer (April 1- (Oct. 16- (May 16- May 15; March July 31) Aug. 1-Oct 31) 15) Nycticeius evening bat Ohio: special interest Yes No Yes humeralis Perimyotis tri-colored bat Ohio: species of concern Yes No Yes subflavus Rafinesque’s Big- Corynorhinus none No No No eared bat fafinesquii Eastern small-footed Myotis leibii Ohio: species of concern No No No bat Seminole bat Lasiurus seminolus None No No Yes
Roosting and Foraging Bats in the region roost in a variety of habitats including tree crevices or cavities, underneath loose tree bark, and sometimes in buildings or other structures. Specifically, during the summer, Indiana bats, NLEBs, and tri-colored bats prefer roost trees located in forested areas (Whitaker and Hamilton 1998, Foster and Kurta 1999, Cryan et al. 2001, USFWS 2007b). Reproductive females of Myotis species, tri-colored bat, and evening bat typically form maternity colonies of many adult female bats and their offspring in suitable roosts, occasionally switching among various roosts. Males and non- reproductive females of these species are typically solitary during the spring and summer, but also use trees, buildings, or other suitable structures for roosting habitat (England et al. 2001). Migratory tree-roosting bats include silver-haired bats (Lasionycteris noctivigans), eastern red bats (Lasiurus borealis), hoary bats (Lasiurus cinereus), Seminole bats (Lasiurus seminolus) and evening bats. Of these four species, the silver- haired bat is the most selective, dependent upon old-growth forest for roosting (BCI 2018). Rafinesque’s big-eared bat form colonies that roost in hollow trees or caves, while eastern small-footed bats typically roost in rock crevices year-round. Ohio’s bats are all insectivorous, though foraging habitat is also somewhat variable depending upon the species. Some bats, particularly big brown bats and evening bats, may occasionally forage over cropland within Ohio and the Permit Area. However, most species in the region are more likely to use forested and open water habitats (BCI 2018). Little is known regarding bat use of agricultural areas in the Midwest. Bat species likely to occur in the Ohio and the Permit Area forage in a variety of habitats and include species adapted to foraging in cluttered and open habitats. Foraging habitat preference varies among species, likely driven by distribution and abundance of suitable insect prey and morphology of each bat species.
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Hibernation and Seasonal Migration The twelve species potentially present in the Plan Area have varying winter habitat. Big brown bats and little brown bats hibernate in buildings, caves, or mines. Indiana bats, NLEBs, tri-colored, and Rafinesque’s big-eared bats hibernate in caves and mines. Eastern small-footed bats use rock crevices year-round. As noted above, the remaining five species in the Plan Area (silver-haired bats, red bats, hoary bats, Seminole bats, and evening bats) roost in trees year-round; however, they migrate out of the Permit Area and Plan Area during the fall and spend winter in warmer areas (Whitaker and Hamilton 1998, Cryan 2003, Cryan and Veilleux 2007, USFWS 2007b). Because the Permit Area is predominantly agricultural and open land with small patches of trees, it does not appear to possess unique or otherwise high-quality winter habitat for any of the ten species of bats potentially present. While carbonate rock is present beneath the surface in the south and southeastern part of the Permit Area, no records or observed evidence of karst topography (e.g., sinkholes, solution cavities) in the Permit Area would suggest the presence of caves. Nor are there nearby sensitive areas, such as natural areas, nature preserves, state parks, wilderness areas, wildlife refuges, or wildlife management areas that may provide high quality habitats for bats. The nearest known bat hibernacula in the Plan Area are in Preble County, Ohio approximately 75 miles south of the Permit Area (BHE Environmental 2010) and northern Champaign County approximately 70 miles southeast of the Permit Area (BHE Environmental 2010). For these reasons, as noted earlier, none of the bat species potentially present in the Permit Area are anticipated to be in the area during winter. Many bats migrate between winter and summer habitat in the spring (typically early April to late May) and return in the fall (typically late August to mid-October). Migrating bats may travel several hundred kilometers between these areas. In addition to migration, mating activity occurs during fall (fall swarming). Bats found in Paulding and Van Wert counties in the spring and fall may be summer residents or migrants. Of the species potentially present in the Permit Area, big brown bats move short distances between summer and winter habitat; Whitaker and Hamilton (1998) report local migrations of 48 kilometers or less. Similarly, NLEBs and tri-colored bats migrate about 48 to 64 kilometers (Whitaker and Hamilton 1998). Indiana bats, silver-haired bats, red bats, hoary bats, and evening bats are thought to migrate long distances (i.e., greater than 100 kilometers; Cryan 2003; Winhold and Kurta 2006) between summer and winter habitat. Hoary bats have been observed traveling in large migratory groups (Whitaker and Hamilton 1998). Seminole bats are considered a southern species whose typical range does not include Ohio, however mortality of this species has been documented during fall migration in the Permit Area (Project HCP Appendix A). Seasonal timing and species composition of bat mortality at wind farms indicate bats are at increased risk of collision during migration, particularly during fall migration. This increased risk of mortality may be related to an attraction to tall structures, mating or courtship behavior, increased flight height, or failure to detect turbines during migratory flight (Kunz et al. 2007a, Kunz et al. 2007b, Cryan 2008).
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3.4.3.2 Threatened and Endangered Bats Indiana Bat Section 3.2 of the HCP provides an in-depth discussion of the Indiana bat, incorporated here by reference. A brief description of Indiana bat status, biology, behavior, and habitat requirements relevant to this EA and its analysis is provided below. A more detailed description of the species is contained in the draft recovery plan for the Indiana bat (USFWS 2007b), also incorporated here by reference.
Status and Threats The Service listed the Indiana bat as in danger of extinction on the first endangered species list published March 11, 1967 (32 FR 4001), under the Endangered Species Preservation Act of 1966. The species remains listed as endangered under the ESA of 1973, as amended. The estimated range- wide Indiana bat population in 2019 was 537,297, down 19 percent since the onset of WNS in 2007 (USFWS 2019d). As of 2019, the USFWS had records of extant winter populations within 344 hibernacula in 17 states (USFWS 2019d). The Indiana bat is listed as state endangered in Ohio. Forty-nine counties in Ohio (out of 88 total counties) have records of summer maternity colonies and an additional four counties had summer records that did not include maternity colonies. Maternity colonies are known to occur in Paulding County, but there are no summer records in Van Wert County (USFWS 2007b). A Priority (P)2 hibernaculum (P2, a hibernaculum supporting more than 1,000 but less than 10,000 Indiana bats) in Preble County, Ohio, is the nearest known Indiana bat hibernaculum, approximately 75 miles south of the Permit Area. The species’ recovery plan defines 4 Recovery Units based on “evidence of population discreteness and genetic differentiation, differences in population trends, and broad-level differences in macrohabitats and land use” (USFWS 2007b). The Permit Area is within the Midwest Recovery Unit (MRU), which includes the Indiana bat’s range in Indiana, Kentucky, Ohio, Tennessee, Alabama, southwest Virginia, Michigan, and Georgia. The overall Indiana bat population in Ohio based on winter hibernacula counts was approximately 2,890 in 2019 (Table 3-3; USFWS 2019d). This represented approximately 1.2 percent of the 2019 MRU population (245,474) and about 0.5 percent of the overall 2019 population (537,297; USFWS 2019d). The total Indiana bat population in the MRU has shown declines from 2011 through 2019. (Table 3-3). The population in Ohio has declined approximately 71 percent since the onset of WNS in the state in 2011 (Table 3-3).
Table 3-3. Indiana Bat Population Estimates for the Midwest Recovery Unit % Change State 2011 2013 2015 2017 2019 from 2017- 2019 Indiana 225,477 226,572 185,720 180,611 184,848 2.3%
Kentucky 70,626 62,018 64,599 58,057 55,946 -3.6%
Ohio (Plan Area) 9,870 9,259 4,809 2,890 2,890 0.0%
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% Change State 2011 2013 2015 2017 2019 from 2017- 2019 Tennessee 1,791 2,369 2,401 1,587 1,561 -1.6%
Alabama 261 247 90 85 90 5.9%
SW Virginia 307 214 137 70 119 70%
Michigan 20 20 20 20 20 0.0%
Georgia 0 0 0 1 0 --
Total 308,352 300,699 257,776 243,321 245,474 0.9%
Source: USFWS 2019d.
Threats to Indiana bats have included modification to hibernacula that change the airflow and alter the microclimate, human disturbance and vandalism causing direct mortality during hibernation, natural events during winter affecting large numbers of individuals, disease, and loss and degradation of summer habitat (USFWS 2007b). WNS is a new, potentially devastating threat to Indiana bats throughout their range. WNS causes bats to arouse more frequently during hibernation, with reductions in the length of bouts of torpor associated with increased mortality rates (Reeder et al. 2012). The Service estimates that the fungus has killed over 6 million bats of various species in the Northeast and Canada, with some sites experiencing a 90 to 100 percent loss (USFWS 2018b). WNS affects most species of bats that hibernate in the northeast, with the little brown bat, NLEB, and Indiana bat among the most impacted. WNS was first documented in the MRU (in southwest Virginia) during the winter of 2008-2009 and confirmed in Indiana (Crawford, Washington, and Monroe counties) and Ohio (Lawrence County) in the winter of 2010-2011 (USFWS 2019e). In Ohio, it has been confirmed in a total of 16 counties and suspected in two additional counties since the winter of 2011-2012 (USFWS 2019e). As noted and shown above in Table 3-3, the Indiana bat population in Ohio has significantly declined.
Hibernation and Seasonal Migration Indiana bat maternity colonies begin to disband in the first 2 weeks of August, with most bats leaving their summer ranges by mid-September. Indiana bats are highly mobile during fall, eventually congregating near hibernacula between August and October and swarming on a nightly basis for up to several weeks. Although swarming occurs near cave entrances, bats roost in trees during swarming rather than in the caves and occasionally move between hibernacula (USFWS 2007b). Bats mate near the end of the swarming period, with females entering hibernation soon after mating and males remaining active until later in fall. Indiana bats typically begin hibernation between mid-October and mid-November, concentrating in a limited number of caves or abandoned mines with suitable characteristics. The extant population of hibernating Indiana bats in Ohio is known from two underground mines: one in Preble County (P2) and one in in Lawrence County (P3, a hibernaculum supporting more than 50 but less than
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1,000 Indiana bats). Four other hibernacula in three counties (Hocking, Brown, and Highland) have been designated as P4 (i.e., current or observed historic populations of fewer than 50 Indiana bats), but currently have no known hibernating Indiana bats (USFWS 2007b). Spring emergence varies with latitude and weather conditions. Studies in Indiana and Kentucky document peak emergence of females in mid-April and males in early May (Cope and Humphrey 1977). In Ohio, spring emergence may start as early as March 15; Indiana bats in Ohio and Indiana have been documented at their summer maternity roost trees in the first week of April. After emerging from hibernacula in spring, Indiana bats travel up to several hundred miles to their summer range, with females typically traveling greater distances than males (USFWS 2007b). Behavior and habitat needs of Indiana bats during spring migration are poorly understood, although they appear to move quickly to summer ranges. There is also evidence that Myotis bats will cease flight activity in cold temperatures (Roby and Gumbert 2016a, Brooks et al. 2017). Roby and Gumbert (2016a, 2016b) found that Indiana bats did not forage or migrate when the ambient air temperature was below 10°C (50 degrees Fahrenheit [°F]) in the spring (number of bats in the sample [n] = 13) or fall (n = two). Roby and Gumbert (2016b) further reported that the mean migration temperature for four Indiana bats ranged from 13°C – 22°C (56°F – 72°F).
Summer Roosting Habitat Requirements and Foraging Behavior Indiana bats roost primarily in trees during summer, usually under exfoliating bark and occasionally using narrow crevices or cracks in trees located in semi-open areas of forest with greater solar exposure (USFWS 2007b). Indiana bats switch among primary and secondary roosts throughout the summer, with maternity colonies focusing use on a small number of primary roosts but using up to 10–20 total trees throughout the summer (USFWS 2007b). Indiana bats are nocturnal insectivores, feeding exclusively on flying insects. They typically forage from 6–100 feet above the ground and hunt primarily around, not within, the canopy of trees (USFWS 2007b). Indiana bats preferentially forage in wooded areas, with forest type varying among studies, including closed to semi-open forests and forest edges (USFWS 2007b). Foraging studies in Illinois indicate floodplain forest is the most preferred habitat, followed by ponds, old fields, row crops, upland woods, and pastures (USFWS 2007b). Telemetry studies have documented nightly foraging distances for female Indiana bats ranging from 0.3–5.8 miles from nightly roosts, with mean distances from 1.6–3.0 miles (Murray and Kurta 2004, Sparks et al. 2005, USFWS 2007b). The size of foraging areas likely depends on extent of suitable habitat, interspecific competition, and prey availability. Rather than crossing large areas of unsuitable habitat, Indiana bats tend to follow corridors of suitable habitat, even if it means flying a greater distance (USFWS 2007b). Northern Long-eared Bat The Project HCP provides an in-depth account of the NLEB (see Section 3.3), incorporated here by reference. A brief description of NLEB biology, behavior, and habitat requirements relevant to this
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EA and its analysis is provided below. A more detailed description of the species is contained in the Service’s final rule for listing the NLEB (USFWS 2016f), incorporated here by reference.
Status and Threats The Service listed the NLEB as threatened on April 2, 2015 (USFWS 2015). On January 14, 2016, the Service published a final 4(d) rule that removes or exempts prohibitions for incidental take of NLEBs for certain types of activities in certain areas (USFWS 2016f). The Service found listing is warranted due to the recent severe and ongoing decline of the species due primarily to WNS. The finding lists other threats to NLEBs but recognizes that WNS is the primary threat to the species continued existence (USFWS 2015). NLEB is listed at state threatened in Ohio. Within the Plan Area of Ohio, NLEBs were captured in approximately 40 percent of all summer mist-netting surveys and comprised approximately 14 percent of all bats captured in summer mist-netting surveys prior to WNS impacts (Project HCP Section 3.6.1; K. Lott, USFWS, pers. comm.). There are summer records for NLEBs in 70 of Ohio’s 88 counties, and maternity colonies are known from VanWert County. There are 34 known hibernacula in Ohio (USFWS 2016g). The NLEB is a relatively wide-ranging bat, but it appears to be patchily distributed and found in low numbers in both roosts and hibernacula (Griffin 1940, Barbour and Davis 1969, Caire et al. 1979, Amelon and Burhans 2006, ASRD and ACA 2009). While there is currently no indication of distinct regional populations, for purposes of discussion the Service categorizes the U.S. range of the species in four parts: Eastern, Midwest, Southern, and Western ranges, and estimates a rangewide population of 6.5 million adults (USFWS 2016g). In the Biological Opinion for the 4(d) rule (USFWS 2016g), the USFWS estimated summer adult populations for each state. These estimates were based on total forested acres in each state and occupancy rates using the proportion of sites occupied by NLEBs in the total number of sites sampled (typically using mist-net surveys). The Service estimated there were 240,240 NLEBs in Ohio and roughly 2.8 million in the Midwest region (USFWS 2016g). Since the Biological Opinion was drafted, data indicate that WNS has caused significant population declines in Ohio and elsewhere. Two hibernacula in Ohio contained approximately 90 percent of the state’s winter bat population prior to WNS detection (USFWS 2015). Declines of NLEB populations from pre-WNS numbers of 96.3 percent occurred in one hibernaculum and 100 percent in the other by 2016 (ESI 2016). Overall, it is possible the Midwest region has seen a NLEB population reduction by as much as 98 percent as a result of WNS (the population loss reported in the northeast by Turner et al. 2011), resulting in a post-WNS Midwest population estimate of 56,000 NLEBs (down from 2.8 million as reported in USFWS 2016g).
Hibernation and Seasonal Migration NLEBs share hibernacula with other bat species (USFWS 2015) throughout their range, and Barbour and Davis (1969) did not find any in concentrations over 100 individuals in a hibernaculum. Individuals may rouse and switch hibernacula throughout the winter, which makes it difficult to accurately estimate winter population numbers (Griffin 1940, Whitaker and Rissler
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1992, Caceres and Barclay 2000). Mine and cave sites have been most often reported as hibernacula for NLEBs (Griffin 1940, Whitaker and Winter 1977, Stones 1981). There is little information available regarding spring emergence and dispersal of NLEBs from hibernacula. However, the length of hibernation period can change with different regions and climates (Caceres and Barclay 2000). Depending on the specific climate patterns and which region the bats are hibernating in, spring emergence may occur from March to May (Fenton 1969, Caire et al. 1979, Whitaker and Rissler 1992, Nagorsen and Brigham 1993). Shortly after emergence, NLEBs migrate to their summer habitat (USFWS 2014). NLEBs begin arriving at hibernacula in August, and by mid-September large numbers of individuals can be seen flying about the entrances to certain caves and mines (Boyles et al. 2009). The majority of breeding occurs during this fall swarming period. Little is known about the migration patterns of NLEBs, particularly how and where they disperse across the landscape during migration. Spring migration direction of NLEBs may be similar to little brown bats, which have been shown to radiate outward from hibernacula during migration, with the bats migrating directly to the natal sites, rather than moving primarily north or south (Davis and Hitchcock 1965, Fenton 1970, Griffin 1970, Humphrey and Cope 1976). Late summer swarming behavior and relatively high concentrations at some caves indicate that there is some degree of local or regional movement prior to reproduction. Short migratory movements between 56 kilometers and 89 kilometers from hibernacula to summer habitat are most common (USFWS 2013; Griffin 1945), suggesting NLEBs are regional migrants. The longest recorded migration distance for the species is 97 kilometers, reported in Griffin (1945).
Summer Roosting Habitat Requirements and Foraging Behavior During the summer, NLEBs inhabit forests and roost singly or in colonies in the cracks, crevices, and bark of both live and dead trees (Lacki and Schwierjohann 2001). They have been found roosting in structures such as buildings, barns, sheds, and cabins. Foster and Kurta (1999) have indicated that NLEBs do not depend on any particular species of tree for roosting but tree characteristics, such as structure and decay, are important. NLEBs have been found roosting below the canopy in forests with a variety of canopy cover percentages, but Perry and Thill (2007) found relatively open forests in Arkansas to be important for female roosts as compared to male roosts. Maternity colonies generally consist of 30 to 60 individuals, though maternity colonies of up to 100 individuals have been observed (USFWS 2013). The NLEB forages on a variety of insects. The most common are moths, beetles, and spiders (Brack and Whitaker 2001, Feldhamer et al. 2009). NLEBs forage and commute primarily in forested interiors (Jung et al. 1999, Owen et al. 2003, Carter and Feldhamer 2005, Broders et al. 2006). Foraging techniques include hawking (catching insects in flight) and gleaning (catching insects from vegetation and water surfaces) (Ratcliffe and Dawson 2003, Feldhamer et al. 2009). NLEBs show preference for forested hillsides and ridges, as opposed to riparian areas (LaVal et al. 1977, Brack and Whitaker 2001). This preference corresponds with the suggestion expressed in Caceres and Pybus (1997) that mature forests are important foraging habitat for NLEBs. Recent capture
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efforts have found NLEBs in young stands and disturbed forests (Crampton and Barclay 1998, Foster and Kurta 1999, Cryan et al. 2001, Menzel et al. 2002, Henderson and Broders 2008, Henderson et al. 2008, ASRD and ACA 2009). In agricultural areas such as the Permit Area, NLEBs may have to move across open habitat to reach nearby forest (Blue Creek Wind 2019). 3.4.3.3 Existing Conditions in the Permit Area For the Project, pre-construction and post-construction surveys for bats were conducted, and are summarized below (also See Project HCP Appendix A). For additional information on habitat conditions applicable to bats in the larger Plan Area, see Section 3.2. Pre-Construction Between March 5 and November 15, 2009, a total of 541 bat calls, including 11 Myotis calls, were identified using two ultrasound detectors placed on one meteorological tower associated with the Project. Of the 11 Myotis calls, six occurred during August through October, corresponding to the approximate fall migration period. Calls were not identified to species in 2009, as the current technology did not allow definitive species identification. However, bat calls recorded during the 2009 study were re-analyzed in 2015, and no Covered Species calls were identified. A 2009 assessment of habitat suitability within the Permit Area determined that while two woodlots provided potential foraging and roosting areas for Indiana bats, they were of limited size (approximately 24 acres) and isolated in a landscape dominated by tilled agriculture (WEST 2009). This overall lack of forest cover and highly fragmented forested areas on the landscape corresponds to limited potential use by Indiana bats (see Section 3.4.3.2). Post-Construction Initial Project monitoring was conducted from October 24 to November 14, 2011 during turbine testing. Searches were conducted at the first 10 turbines that became operational, followed by one additional turbine search after each subsequent set of five turbines became operational. One hoary bat carcass was found, and no Covered Species were detected. From April 1 to November 15 in 2012, 2013, and 2015, fatality searches and acoustic monitoring were conducted to monitor bat mortality and activity in the Permit Area. A mist-netting study was conducted between July 18 and 25, 2016 to determine presence or probable absence during the summer maternity season. The results from these surveys are summarized below.
Fatality Monitoring Fatality searches were conducted in accordance with ODNR’s On-Shore Bird and Bat Pre- and Post- Construction Monitoring Protocol for Commercial Wind Energy Facilities in Ohio, Option B protocol (ODNR 2011) in 2012, 2013, and 2015. In 2012, one Indiana bat and no NLEBs were found among a total of 850 recorded fatalities representing eight species. In 2013 and 2015, no Covered Species were found in a total of 728 bats representing six species (2013) and 363 bats representing five species (2015). In 2016, post-construction fatality monitoring was conducted with less Project site coverage than in prior years. Thirty-seven turbines were searched within 60 meters, weekly during
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the spring and twice weekly during the fall. No Covered Species were found in a total of 97 bats representing six species. Table 3-4 summarizes the results of post-construction bat fatality monitoring at the Project in 2012, 2013, 2015, and 2016. Immediately following the discovery of an Indiana bat carcass on Oct. 3, 2012, the Project implemented raised cut-in speeds from October 5 to November 15, 2012 to prevent further impacts to Indiana bats. During the 2013 fall migration period, August 1 to October 15, 68 of the Project’s 152 turbines were feathered at wind speeds below 4.5 m/s from one hour after sunset to one hour before sunrise while the rest were feathered below the manufacturer’s cut-in speed of 3.0 m/s. Bat mortality was 40 percent lower at the turbines feathered below 4.0 m/s than at the 3.0 m/s turbines. In 2015 and 2016, all turbines were feathered at wind speeds below 6.9 m/s one half- hour before sunset to one half-hour after sunrise from March 15 to May 15 (spring migration) and from August 1 to October 31 (fall migration) to avoid impacts to Covered Species. No Covered Species carcasses were found during post-construction monitoring in 2013, 2015 or 2016. All-bat fatality rates were calculated each year using the Huso estimator (Huso et al. 2015). In 2012, to avoid biasing the estimates low due to the change in turbine operation, the fall fatality rates were calculated by extrapolating the August 1 to October 3 rates through the end of the study period on November 15. The resulting estimated annual bat fatality rate was 15.51 bats per MW per study period. In 2013, the fatality rate was 7.01 bats/MW/study period at turbines curtailed below 4.5 m/s in fall and 11.76 bats/MW/study period at turbines feathered below 3.0 m/s in the fall. In 2015, when all turbines were curtailed below 6.9 m/s in spring and fall, and monitoring occurred from April 1-Nov. 15 the annual bat fatality rate was 7.83 bats/MW/study period. In 2016, when all turbines were curtailed below 6.9 m/s in spring and fall, and monitoring occurred only in spring and fall (no monitoring in summer), the bat fatality rate was 1.62 bats/MW/combined spring and fall migration period.
Acoustic Monitoring Acoustic monitoring employed four ultrasound detectors at two permanent meteorological towers during the same study period, April 1 to November 15, in 2012, 2013, and 2015. The detectors were placed at 45 meters (148 feet) and 5 meters (16 feet) above the ground on each meteorological tower. The number of bat passes was 7,724, 3,146, and 3,960 in 2012, 2013, and 2015, respectively. Analysis of the 14,830 calls, recorded over a total of 2,648 detector nights in three years, did not identify any calls by Covered Species. Data from 2012, 2013, and 2015 fatality and acoustic monitoring were evaluated to examine how bat mortality risk may vary with weather in the Permit Area. Statistical correlation analysis found that bat activity and fatalities were positively correlated with temperature, and all measures of bat activity and fatality had a negative correlation with wind speed. In other words, bat activity and fatalities increased with higher temperatures and decreased with higher wind speeds. Based on 2012 and 2013 data, 99 percent of bat activity occurred when average temperature exceeded 10°C (50°F).
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Table 3-4. Post-Construction Monitoring 2012, 2013, 2015, and 2016 – Bat Fatalities Species Bats/MW/
year - Survey Year Total Monitoring/Cut-in speed
ed (Huso et Period - color oary B ig R vening H Silver haired brown
Indiana al. 2015) E Tri Seminole Unknown
ODNR Option B protocol (ODNR Apr 1- 2012 149 120 468 105 3 1 2 1 1 850 15.51 2011); 6.9 m/s cut-in starting in mid Nov 15 Oct. when Indiana bat found
11.76 (at ODNR Option B protocol (ODNR normally Apr 1- 2011); 4.5 m/s cut-in on 68 turbines 2013 270 152 234 63 4 0 2 3 0 728 operating Nov 15 from Aug-1-Oct 15, 84 turbines turbines) operated normally ODNR Option B protocol (ODNR Apr 1- 2011); Cut-in of 6.9 m/s applied to 2015 106 90 156 22 0 0 1 0 0 375 7.83 Nov 15 all turbines from March 15-May 15 and from Aug. 1-Oct. 31 Monitoring in spring and fall only, 37 turbines searched within 60 April 1- meters, weekly during the spring 1.62 (spring May 15; 2016 23 29 36 7 1 0 1 1 0 98 and twice weekly during the fall; and fall only) Aug 1- Cut-in of 6.9 m/s applied to all Oct 31 turbines from March 15-May 15 and from Aug. 1-Oct. 31.
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Mist-Net Study Bat mist-net surveys were completed at five sites in the Permit Area between July 18 and 25, 2016. The study was designed to determine the presence or probable absence of Covered Species during the summer maternity season, following the 2016 Rangewide Indiana Bat Summer Survey Guidelines (USFWS 2016h) and ODNR wind project-specific bat survey protocols (ODNR 2009). Eleven bats were captured at three sites, including: eight big brown bats, two eastern red bats, and one hoary bat. No Covered Species were captured during the surveys, which confirmed their probable absence from the Permit Area in the summer (Project HCP Appendix A). 3.4.3.4 Covered Species Mortality at Wind Projects in the Plan Area To date in the Plan Area five wind projects (including Blue Creek) have completed one or more year of post-construction monitoring for birds and bats, according to ODNR protocol (ODNR 2011). Three Indiana bat mortalities have been documented at a total of two sites in the Plan Area, including one at Blue Creek in 2012 (Appendix E, Table E-1). Two of these mortalities occurred during fall migration and one occurred during spring migration. No NLEB mortalities have been detected at any site in the Plan Area (Appendix E, Table E-2). 3.4.3.5 Bat Resources Summary The Plan area may support 12 bat species during spring migration, summer, and fall migration. Most of the Plan Area bat species occur in forests and roost in trees in the summer, but some may roost in rock crevices or human-made structures. All the Plan Area bats are insectivorous, and may forage in forested areas or over open areas. Approximately half of the Plan Area bat species winter in caves or mines in the Plan Area, and half migrate out of the plan area in the winter. Based on Covered Species fatalities recorded at wind energy facilities in the Permit Area, Plan Area, and Midwest to date and the results of the post-construction monitoring studies, take of Covered Species may occur within the Permit Area during the spring (April 1 – May 15) and fall (August 1 – October 15) migration seasons, with the fall migration season (August 1 – October 15) being the period of highest documented risk. Covered Species are not expected to occur in the Permit Area during the summer maternity season (May 16 – July 31) based upon the lack of suitable habitat for maternity colonies, the absence of documented fatalities at the Project during this time period, and the negative results of the post-construction summer mist-netting survey completed in 2016. The spring emergence and early migration period includes March 15-April 1, and fall migration may occur through the end of October, with swarming around hibernacula occurring until November 15. It is possible that Covered Species could be migrating through the Permit Area during these early spring and late fall periods. However, no hibernacula for either Covered Species are located in proximity to the Permit Area, so large numbers of Covered Species are not likely to occur during these periods. It is possible that small numbers of individuals of Covered Species may migrate through the Permit Area during these times, though peak migration is likely to occur April 1-May 15 and August 1-October 15.
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3.4.4 Climate Change
This section describes existing conditions in Ohio (Plan Area) related to climate change, including greenhouse gas (GHG) emissions, with national data provided for context. 3.4.4.1 Existing Conditions According to the U.S. Environmental Protection Agency (USEPA) (2000), climate change refers to the long-term fluctuations in temperature, precipitation, wind, and other climate elements. This change can occur due to natural processes (e.g., solar-irradiance variations, volcanic activities) and is also influenced by changes in concentrations of various gases (i.e., GHGs) in the atmosphere, which affect the absorption of radiation. The United Nations Framework Convention on Climate Change defines climate change as “a change of climate which is attributed directly or indirectly to human activity that alters the composition of the global atmosphere and which is in addition to natural climate variability observed over comparable time periods.” According to the USEPA (2000), scientists know that increasing GHG concentrations are warming the planet, and rising temperatures may, in turn, produce changes in precipitation patterns, storm severity, sea level, and acidity, commonly referred to as “climate change.” GHGs are gases that warm the earth’s atmosphere by absorbing solar radiation reflected from the earth’s surface. The most common GHGs are carbon dioxide (CO2), methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. According to the USEPA (2019), human activities are responsible for almost all of the increased GHGs in the atmosphere over the last 150 years, and the largest sources of GHG emissions in the United States are from: transportation (29 percent of 2017 emissions), electricity production (28 percent), industry (22 percent), commercial and residential (12 percent), and agriculture (9 percent). Land use (e.g., minimizing the conversion of forest land to other land uses), land use practices (e.g., utilizing reduced tillage on cropland or improved grazing management), and existing forests offset 11.1 percent of the 2017 GHG emissions by acting as a sink, absorbing carbon dioxide from the atmosphere (USEPA 2019). The electricity sector emitted 28 percent of GHG emissions in 2017, and fossil fuel combustion accounted for 68 percent of this, while only generating 31.2 percent of the electricity (USEPA 2019). GHG emissions from electricity generation have decreased by approximately 5 percent since 1990 due to a shift in generation to lower- and non-emitting sources of electricity generation and an increase in energy efficiency (USEPA 2019). Most of the energy in the United States is generated using fossil fuels, including natural gas (35 percent of electricity generation in 2018) and coal (27 percent of electricity generation in 2018; USEIA 2019a). Ohio relies heavily upon natural gas and coal for its electrical generation, representing 46 percent and 37.6 percent, respectively, of net electricity generation in the state (USEIA 2019b). Conversely, renewables account for 1.6 percent of net electricity generation in Ohio, although wind energy generation has increased nearly 8-fold from 2011 to 2018 (USEIA 2019b). Nationwide, wind energy accounts for approximately 7 percent of energy generation (USEIA 2019a).
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4.1 Overview of the Effects Analysis This section describes the environmental effects of each of the four alternatives retained for detailed analysis. It evaluates direct and indirect effects of the alternatives to general wildlife, avian, and bat resources, followed by a cumulative effects analysis for avian and bat resources. Each of the action alternatives includes the modified operation of a wind project, implementation of the HCP, mitigation measures, and monitoring and adaptive management, as described in Section 2.2. The alternatives differ with respect to operational adjustments, number of taken Covered Species, monitoring requirements, and the extent of mitigation to be implemented to offset the impact of taking Indiana bat and NLEB. The following analysis is commensurate with the estimated impacts associated with Project operations.
4.2 Biological Environment
4.2.1 General Wildlife Resources
4.2.1.1 Impact Evaluation Criteria Significant impacts to wildlife resources are those that substantially affect a species’ population (locally, regionally, or range-wide) or reduce its habitat quality or quantity. Impacts to species can be both direct and indirect. Examples of direct effects include disturbance, injury, mortality, and habitat alteration. Examples of indirect effects include habitat loss or degradation over time or effects to resources used by wildlife in different life stages (i.e., alterations to surface water or alterations to plant composition). Another indirect effect may be the creation of habitat such as edges and openings that favor a different mix of species and, in some cases, increase predation pressure, thereby causing displacement or avoidance. 4.2.1.2 Direct and Indirect Effects Common to All Alternatives Operation of the Project under any of the four alternatives is expected to have similar effects to non-volant wildlife. Potential direct and indirect effects from operations, post-construction monitoring, and proposed mitigation for taking Covered Species are described below. Project Operation Because the Project is already constructed and operating, no additional impacts from habitat loss, disturbance, or displacement are anticipated for the No Action or any action alternative. Common species such as white-tailed deer, raccoon, and striped skunk can become habituated to human activity and habitat modification. It is expected that other wildlife that may use the Permit Area would continue to occur under any alternative, including common mammals, a few common reptiles, and insects. Ongoing Project operations may attract terrestrial wildlife if they are drawn to investigate downed carcasses while searching for food. If consistent carcass presence is a regular
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event, carcasses may become a regular food source for some mammal species including coyote, raccoon, and red fox. This would be anticipated with or without issuance of an ITP, though with fewer downed bat carcasses under the No Action alternative than the action alternatives with lower turbine cut-in speeds (see Section 4.2.3 for an analysis of bat mortality). Aside from the variance in downed carcasses, there is no data to suggest that maintaining or modifying the current turbine cut-in speeds as defined under the alternatives would have any effect on non-volant wildlife. As there are only potentially minor impacts anticipated from Project operations under any alternative, as discussed above, population level effects from operation of the Project under any of the four alternatives are not expected for any species of terrestrial wildlife. Post-Construction Monitoring As no take of Covered Species is likely under the No Action Alternative, the Applicant would not conduct fatality monitoring under that alternative, and there would be no effects related to monitoring. All three action alternatives include post-construction monitoring to be implemented similar to that described in Section 2.2, though the level of effort needed to document permit compliance varies between alternatives and is discussed below. Effects to terrestrial wildlife resulting from post-construction monitoring may include disturbance or mortality due to increased vehicle traffic and human presence. Furthermore, any vehicle-induced fatalities may attract scavengers. Post-construction monitoring also would include searcher efficiency and carcass persistence trials, in which carcasses are placed in the Permit Area to assess searcher success and carcass removal by scavengers (i.e., mammals and birds). Local wildlife such as coyote, raccoon, and red fox may be attracted to the Permit Area during these trials. Cleared turbine pads would make fatalities easily detectable to scavengers. Smallwood (2013) estimates that on average, 74 percent of bird carcasses and 70 percent of bat carcasses are taken by scavengers within 30 days at wind projects in North America. Non-volant wildlife would not be susceptible to turbine collisions, but may be susceptible to vehicle collisions while moving between turbine plots to scavenge. Mitigation for Taking Covered Species In the long term, with issuance of an ITP, any mitigation measures to preserve and/or restore summer or fall swarming habitat for bats will benefit forest-dwelling mammals, reptiles, and amphibians in the Plan Area that occur at the mitigation site(s). Some native wildlife may be disturbed and potentially displaced during tree planting (if part of the selected mitigation project) due to the presence of humans and disturbing soils. However, these disturbances will be temporary, minor, and have little lasting effect. Reforestation, if required for the summer or fall habitat mitigation project, will expand woodland in the watershed providing cover for species at the site for feeding, drinking, and traveling. Gating of a winter hibernaculum would benefit the bats and other organisms that use that structure by preventing disturbance by humans, but would not directly benefit other forest-dwelling mammals, reptiles or amphibians. Overall, mitigation for Covered Species under any of the action alternatives is not expected to result in significant adverse impacts to general wildlife that would substantially affect a species’
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population (locally, regionally, or range-wide) or significantly reduce its habitat quality or quantity. Conversely, the summer or fall swarming habitat mitigation project will have long-term beneficial effects to general wildlife at the local scale, including forested habitat preservation and enhancement, while gating of a hibernaculum would benefit bats and other species using the structure. No mitigation plan would be approved by the Service if it would result in adverse effects to or take of any other federal or state-listed species or bald or golden eagles. 4.2.1.3 Summary of Effects to General Wildlife None of the alternatives are expected to result in impacts to non-volant wildlife that would affect a species’ population (locally, regionally, or range-wide) or significantly reduce its habitat quality or quantity. Among the four alternatives, the Service does not expect modified Project operations to have significantly different effects to terrestrial wildlife. Similarly, significant differences in effects to general wildlife resulting from the monitoring and mitigation measures for Covered Species among the three action alternatives are not expected. Impacts to general wildlife resources under all four alternatives will be minor.
4.2.2 Avian Resources
4.2.2.1 Impact Evaluation Criteria Birds can be affected at the individual and population level. Impacts to avian resources would be considered significant should implementation of an alternative result in a
• Naturally occurring population reduced in numbers below levels for maintaining viability at local or regional level;
• Substantial loss or degradation of habitat for a rare, threatened, or endangered bird species; or
• Substantial change in habitat conditions producing indirect effects that cause naturally occurring populations to be reduced in numbers below levels for maintaining viability at local or regional levels. 4.2.2.2 Direct and Indirect Effects Common to All Alternatives Project Operations The operation of the Applicant’s Proposed Project, whether as continued operations under the No Action alternative, or operation of the other action alternatives is expected to have similar effects to avian resources. For the purposes of our analysis and based on what the currently available information suggests, the Service assumed operational differences among alternatives (i.e., turbine cut-in speeds, see Section 2.2) would not result in different potential direct or indirect impacts to avian resources. To date, there have been very few studies in the U.S. that focused on effects of turbine operational adjustments on bird mortality, and most of the studies that are available targeted raptors (Smallwood 2010). The effectiveness of turbine curtailment and feathering for reducing bird mortality have been found to be inconclusive and would likely be site- and species-
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specific. Furthermore, the only technique with evidence of minimizing impacts to bird mortality is turbine shutdown during high-risk periods triggered by real-time field observations and/or automated detectors (Marques et al. 2014), which is not under consideration for any of the alternatives. Impacts to avian species due to operations of a wind project can be both direct and indirect. Examples of direct effects include mortality, injury, disturbance, and habitat loss and degradation. Examples of indirect effects include avoidance or displacement due to habitat alterations and decreased survival or breeding success due to the presence of operating Project structures or increased human presence or vehicle traffic. Indirect effects due to habitat alteration can result in changes in species abundance and diversity; these types of indirect effects can be complex and change over time. This EA considers the Applicant’s best management practices and minimization efforts related to birds during Project operations, which are the same under all alternatives. Prior to Project construction, the Applicant consulted with the Service and ODNR regarding rare bird species and conducted surveys as described earlier in Section 3.4.2.2. The Project is located primarily in active agricultural fields, and the Project does not contribute to impacts associated with forest fragmentation. Additional operational minimization measures for birds include but are not limited to the following: 1) apply Avian Power Line Interaction Committee best practices for electrocution, 2) minimize lighting at the O&M building and substation at night, using least amount required for safety or red lights that don’t attract insects, 3) limit use of herbicides, pesticides, and rodenticides, and 4) utilize red LED aviation obstruction lighting (as opposed to white or steady-burning light) set to the minimum flash frequency (M. Becker, Blue Creek Wind LLC, pers. comm.). Disturbance and Displacement Avian species in the Permit Area may be susceptible to disturbance and displacement-related impacts during continued Project operations. Potential sources of disturbance include the presence of Project structures (particularly operating turbines and meteorological towers), human presence, vehicle traffic during operations activities, and noise associated with spinning turbines. The level of disturbance associated with habitat impacts at wind projects relates to the topography, the baseline condition of habitat(s) present, the amount of existing roads or infrastructure, and turbine layout (National Research Council of the National Academies [NRC] 2007). Potential habitat disturbances are species-specific and would depend on the condition and availability of habitat prior to construction (NRC 2007). The Permit Area primarily consists of active agricultural fields, with a small amount of developed lands, including the existing operational Project and its associated infrastructure. The majority of birds documented during pre- and post-construction surveys were members of common, disturbance-tolerant species, indicating that displacement effects are unlikely for most of the birds occurring at the Project. Furthermore, as no changes to Project operations other than turbine cut-in speeds are proposed at this time (see Turbine-Related Mortality below) and no current data indicates that implementing cut-in speeds affects disturbance and displacement of birds, none of the four alternatives would change the existing level of disturbance and displacement of avian
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species caused by Project operations. Therefore, no significant impact to avian resources from disturbance and displacement is anticipated under any alternative. Turbine-Related Mortality The operating turbines pose a risk of mortality from collisions for birds. Although the Project does not exhibit any environmental characteristics indicating a high level of collision risk, virtually every wind-energy project in the U.S. results in bird mortality. Avian collision mortality at wind projects is well documented. In the U.S. and Canada, wind turbines are responsible for approximately 214,000 to 368,000 bird collisions each year, comprising a small proportion of the human causes of mortality (0.01 percent; Erickson et al. 2014, Erickson and Rabie 2014). According to the American Wind Wildlife Institute (AWWI; 2019a, AWWI 2019b), median avian mortality rates were highest at wind farms in the USFWS Midwest and Northeast regions and lowest in the Mountain-Prairie regions. Publicly-available estimates for the Midwest currently range from 1.3 to 7.2 birds/MW/year and have a median of 2.63 birds/MW/year (AWWI 2019a, 2019b). As described in Section 3.4.2.3, standard post-construction mortality monitoring was completed at the Project in 2012, 2013, and 2015. Table 3-1 in Section 3.4.2.3 provides a summary of the bird fatalities documented during post-construction fatality monitoring at the Project. The overall bird fatality rate ranged from 1.43 birds/MW/year in 2012 to 6.25 bird fatalities/MW/year in 2013, with 3.41 bird fatalities/MW/year in 2015. The three-year average is therefore approximately 3.7 bird fatalities/MW/year. Based on the Project nameplate capacity of 304 MW and applying the average and range of fatality rate estimates, an average of 1,125 birds (ranging between 435 and 1,900 birds) could be killed annually, for a total of approximately 39,368 bird fatalities (ranging from 15,215 to 66,500 fatalities) over the life of the Project under all Alternatives. As noted above, there is no current research to indicate that avian mortality would differ based on changes to turbine cut-in speeds. Among bird species, nocturnal migrating passerines represent the bird group most commonly involved in fatalities at wind-energy facilities (NRC 2007, Erickson et al. 2014), likely due to their abundance and migratory behaviors. Small passerines as a group comprised approximately 51.5 percent of the bird mortality at wind energy facilities in the Midwest (AWWI 2019a). At the Project, both resident and migrant passerines accounted for 82 percent of birds found during post-construction surveys (see Section 3.4.2.3). Large-scale mortality events documented at wind energy facilities were all determined to be due to improper lighting, and minimization measures for facility lighting have since been developed (Kerns and Kerlinger 2004, Stantec 2013, Steelhammer 2011). Measures to reduce the risk of bird collision from facility lighting have been implemented at the Project, including, as noted above, minimizing lighting at the O&M building and substation at night, as well as using red LED aviation obstruction lighting set to the minimum flash frequency (as opposed to white or steady-burning light) (M. Becker, Blue Creek Wind LLC, pers. comm.). Although waterbird (waterfowl, shorebirds, and seabirds) mortality at wind energy facilities has been highly variable, national research has demonstrated that waterbirds rarely collide with inland turbines (Kingsley and Whittam 2005). Low to no waterbird mortality has been observed at Midwest wind facilities, including those with high waterbird use in the site or vicinity (Jain 2005).
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Killdeer, a common species within this region accounted for approximately 4.8 percent of the overall avian mortalities at the 27 windfarms assessed (AWWI 2019a). Killdeer was the primary shorebird species found during post-construction fatality monitoring at the Project, representing approximately 10 percent of total bird fatalities (Section 3.4.2.3). Similarly, raptor fatality rates at Midwest sites have been very low. Among 27 wind farms assessed within the prairie biome, 8.2 percent of the fatalities recorded, or an estimated 0.3 percent of the North American raptor population, were those of diurnal raptors (AWWI 2019a). Within this group, turkey vultures (5.2 percent of total avian fatalities) and red-tailed hawks (1.5 percent of total avian fatalities) had the highest number of fatalities (AWWI 2019a). As noted above, approximately 4 percent of total bird fatalities during Project post-construction monitoring were raptors, species including the turkey vulture, red-tailed hawk, Cooper’s hawk, and sharp-shinned hawk. Population-Level Impacts Species considered at risk from population-level effects would include those with relatively small or unstable populations. To date, no significant population-level impact to any one bird species has been documented as a result of mortality from wind projects in the U.S. This is largely because most of the nocturnal migrant passerines, which are at the greatest risk of collision, are considered abundant wherever they occur (NRC 2007, Arnold and Zink 2011). Available data suggest the species most at risk of collision are those that are regionally abundant and engage in flight behaviors leading to risk of collision and those that migrate through the area at night at lower altitudes. The summary by Erickson et al. (2014) indicates that the four species most frequently involved in collisions at wind projects in the U.S. and Canada include the horned lark, red-eyed vireo, western meadowlark (Sturnella neglecta), and golden-crowned kinglet. In the Plan area of Ohio, Service data indicate horned lark, golden-crowned kinglet, and killdeer are the top three species detected when considering all post-construction studies over all available years and sites (M. Seymour, USFWS, pers. comm). The Partners in Flight (PIF) land bird population database estimates for the North American populations of these species are 100 million (horned lark), 130 million (red-eyed vireo and golden-crowned kinglet), and 95 million (western meadowlark; PIF 2019a). The PIF database does not include killdeer. Andres et al. (2012) estimated the North American killdeer population at 2 million, acknowledging that the estimate may be conservative. The global populations of red-eyed vireo and golden-crowned kinglet appear to be stable. However, the PIF species assessment database (PIF 2019b) shows horned lark and western meadowlark have experienced decreases in populations. The killdeer population is also generally considered stable, with potential long-term decline (Andres et al. 2012). Fatality monitoring completed at the Project found that, of all bird mortality over 3 years, horned larks comprised 37 percent killdeer comprised 10 percent, golden-crowned kinglets comprised 8 percent, and red-eyed vireos comprised 1 percent (Section 3.4.2.3). Based on the average bird mortality rate observed at the project to date (3.7 birds/MW/year), and assuming these species-specific mortality rates carry throughout the 35- year permit term, approximately 14,566 horned larks, 3,936 killdeer, 3,149 golden-crowned kinglets, and 393 red-eyed vireos may be killed over the life of the Project. No western
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meadowlarks were observed. Given Project-related mortality represents such a small portion of the estimated populations, this level of mortality is not considered a population-level impact. Listed Species As described in Section 3.4.2, no federally threatened or endangered avian species were found during pre-construction surveys or post-construction monitoring, nor were there any listed avian species records found within 0.25-mile of the Permit Area. During pre-construction surveys of the Project, one state endangered bird species (northern harrier) was documented; however, no northern harriers were found during post-construction fatality monitoring (M. Becker, Blue Creek Wind Farm, LLC, pers. comm.). The habitat available, records search, and results of pre- and post-construction field surveys indicate a low likelihood of federal or state-listed avian species breeding in the Permit Area. However, these species could occur within the vicinity of the Project during migration. The potential occurrence of listed species within the Permit Area is expected to be infrequent and for short durations, so displacement and disturbance effects would be minimal. The Project was designed with impact minimization measures to reduce the risk of avian collision. The new generation turbines have tubular support structures instead of lattice structures, which eliminate perching by avian species such as raptors. Newer turbines also have larger blades, which reduces motion blur. The turbines are adequately spaced within crop fields, allowing birds greater reaction times to avoid turbines when approaching them. Risk to state-listed species is expected to be low based on the observation of only one state-listed bird during pre-construction monitoring (Northern harrier), no detections of state-listed bird mortality during post-construction monitoring, and the Northern harrier’s behavior patterns. Northern harriers are fairly common in northern Ohio and the Midwest during the spring and fall migrations and also during the winter (Smith et al. 2011). Observations of northern harrier at the Project likely represent individuals migrating through the area. Northern harriers require large undisturbed wetlands, pastures, old fields, marshes, and upland habitats for breeding. There is limited potential nesting habitat for northern harriers at the Project. The hunting habits of northern harriers typically involve low, coursing flights over grassland habitats (Smith et al. 2011), which likely decreases the potential for this species to collide with a wind turbine. Northern harriers may fly higher and within the rotor-swept area when conducting aerial courtship displays, and this species may occasionally fly within the rotor-swept area during migration. Service Birds of Conservation Concern Seven Service BCC species in BCR 23 were documented during post-construction mortality monitoring surveys: black-billed cuckoo, bobolink, brown thrasher, cerulean warbler, dickcissel, golden-winged warbler, and marsh wren (Section 3.4.2.5). Of these seven species, the PIF species assessment database (PIF 2019b) shows black-billed cuckoo, bobolink, cerulean warbler, and golden-winged warbler have experienced a significant decrease in population, but this decline cannot be directly attributed to mortality at wind projects given that wind farms contribute to less than one percent of anthropogenic sources of avian mortality (see Section 4.3.2.2).
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Other Sources of Mortality Associated with Project Operations Birds are susceptible to other sources of mortality at wind projects beyond turbine collision, such as from collision with vehicles, collision or electrocution from transmission lines, and collisions with other project structures such as meteorological towers. Additionally, nighttime lighting that is improperly installed or operated at wind facility substations or O&M buildings can increase the risk of collision with project structures or nearby turbines. However, no bird mortality events from these other sources has been identified at the Project since operations began in 2012, and no change to relevant Project operations is proposed under any of the alternatives. Therefore, the Service does not expect avian mortality from these other components of the Project. Post-Construction Monitoring Except for the No-Action alternative, all alternatives would include post-construction monitoring for bats to be implemented as described in Section 2.2. Effects to birds resulting from post- construction monitoring may include disturbance or fatality due to increased vehicle traffic and human presence. Post-construction monitoring would include searcher efficiency and carcass persistence trials, in which bat carcasses are placed in the Permit Area to assess searcher success and carcass removal by scavengers (i.e., mammals and birds) (see Section 6.0 of the Project HCP for additional details). Local scavenging birds, such as vultures, raptors, and crows may be attracted to the Permit Area during either of these types of trials. Cleared turbine pads would make fatalities easily detectable to birds. Avian scavengers could collide with spinning turbine blades while searching for carcasses. However, carcasses are collected when found and trial carcasses are removed after trials and the risk of this impact would be temporary. The results of monitoring could indicate that adaptive management of cut-in speeds is warranted. Cut-in speeds may be increased to reduce bat mortality or reduced to allow greater operations while keeping take within permitted limits. Either of these changes to cut-in speeds is not likely to change the projected impact on birds. Mitigation for Taking Covered Species While the goal of the Covered Species mitigation is to preserve and/or restore Indiana bat and NLEB habitat to fully offset the impact of estimated incidental take the mitigation project(s) also could provide benefits to forest-dwelling birds. If the mitigation preserved and/or restored forest on lands in Ohio, then forest-dwelling birds may benefit. Such benefits would potentially include supporting migration habitat for the state-endangered Kirtland’s warbler as well as the six avian state species of concern that use forests in Ohio (see Section 3.4.2.6). Protected and/or restored forest lands would also benefit the 96 avian species identified by the State Wildlife Action Plan that could occur in forested mitigation sites (Section 3.4.2.6). These parcels would be protected in perpetuity and over the long term, these forested parcels would offer enhanced habitat for breeding birds, and also may provide high-quality stopover habitat for migrants. Adaptive management would ensure that the forest is maintained in native Ohio trees. If the mitigation project was to gate a cave, then there would not be any notable benefit or adverse impact to birds.
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4.2.2.3 Summary of the Effects on Avian Resources No significant adverse effects to the local bird community are anticipated under any of the four alternatives due to habitat loss or degradation because similar habitat is available adjacent to all existing permanently disturbed areas, and no additional habitat disturbance will occur under any alternative. Implementation of any of the four alternatives is not expected to result in any loss or degradation of habitat for a rare, threatened, or endangered bird species. Pre- and post-construction surveys indicate bird use within the Project consists mostly of common, disturbance-tolerant species. During each year of operation, under any of the Alternatives the Service anticipates that the bird fatality rate will be approximately 3.7 bird fatalities per MW per year (based on the average estimated bird fatality rate generated from the 3 years of mortality monitoring results), or approximately 1,125 birds per year. Likely affected species will be those already discovered during post-construction monitoring at the Project. Based on the range of estimated fatality rates from 2012, 2013, and 2015 of 1.43 to 6.25 birds per MW per year, the Project would kill between approximately 15,215 and 66,500 birds over the remaining life of the Project. This mortality is expected to occur under any of the four alternatives. We do not anticipate the issuance of the ITP would have adverse population-level impacts to individual species under any of the alternatives. Implementation of any of the four alternatives would not result in reducing any naturally occurring population to numbers below that for maintaining viability at the local or regional level. None of the four alternatives would result in substantial changes in habitat conditions producing indirect effects that cause naturally occurring populations to be reduced in numbers below levels for maintaining viability at local or regional levels. Any potential cumulative impacts to bird populations from wind energy development are addressed in Section 4.3.2. Mitigation could permanently protect several hundred acres of forest in Ohio that would be habitat for forest dwelling birds, though the exact quantity of forest habitat mitigation is uncertain. In summary, among the four alternatives it is not expected that Project operations, post-construction monitoring, and mitigation would have significantly different effects on avian resources.
4.2.3 Bat Resources
4.2.3.1 Impact Evaluation Criteria The following sections analyze potential impacts of each alternative on listed and unlisted bats. Indiana bat and NLEB are listed under the federal ESA as well as Ohio’s ORC. Each of the unlisted bat species potentially in the Permit Area are identified as an Ohio species of concern or special interest (see Table 3-2). While this status denotes a species might become threatened in Ohio, or is currently at low breeding densities in the state, take of species of concern and species of interest is not restricted by Ohio statute (ORC 1531.25). With the exception of the Indiana bat, population-
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level counts for bat species in Ohio are currently limited.9 The Service has estimated regional populations of NLEB using documented occurrences and forest cover. Impacts to all potentially affected bat species from each Alternative are discussed; however, an assessment of the effects of the alternatives at the population level is only provided for Indiana bat and NLEB because population data for non-listed bats is not available. Significant impacts may occur to bats should implementation of an alternative result in Project fatality rates that greatly exceed the typical rate for wind projects in the region, or bat fatalities at the Project lead to a reduction in naturally occurring populations below levels sufficient for maintaining viability at the local or regional levels. Habitat-related impact criteria are not applicable to this Project, because no adverse changes to habitat conditions are proposed under any alternative (Section 4.2.3.5). 4.2.3.2 General Bat Mortality Patterns at Wind Projects Mechanisms for bat mortality at wind turbines include trauma associated with direct collision with spinning turbine blades and barotrauma (i.e., tissue damage to lungs and respiratory organs that occurs when bats fly through a wake of low pressure that follows immediately behind fast-moving turbine blades). However, more recent research found that the majority of turbine-associated bat deaths are attributed to impact trauma (Houck et al. 2012, Rollins et al. 2012). Turbine impact fatalities are also generally distributed within facilities; studies worldwide have failed to detect specific turbines responsible for most fatalities at any given facility (Arnett et al. 2016). Bats do not appear to be at risk of mortality when turbines are fully feathered (blades pitched to rotate at less than 2 revolutions per minute when wind speeds are below the indicated cut-in speed). The primary bat species affected by wind facilities are migratory, foliage- and tree-roosting species (Kunz et al. 2007b). Migratory tree-roosting bats consistently account for the majority of fatalities in studies of wind farm mortality in the U.S. (Arnett and Baerwald 2013). This pattern also occurred during post-construction monitoring at the Project (See Project HCP Appendix A). Arnett and Baerwald (2013) compiled data from 122 studies from 73 wind facilities in the United States and Canada and found that mortality has been reported for 21 of the 47 bat species known to occur in the U.S. and Canada. Of the 21 species, 78 percent were the migratory, foliage-roosting hoary bat, eastern red bat, and silver-haired bat. Appendix E, Table E-3 provides a summary of bat carcasses identified at wind projects in the Midwest prior to the implementation of general operational curtailment (cut-in speeds), including the Project, comparing the percent of migratory tree-roosting and cave-hibernating species identified in fatality surveys.
Some researchers have suggested that bats that roost in foliage of trees for most of the year may be attracted to wind turbines because of their migratory and mating behavior patterns (Kunz et al. 2007b). Recent studies utilizing thermal imagery have shown that once they are in the vicinity of turbines (e.g., within 50 meters [164 feet]) bats may be attracted to turbines, as most bats appeared
9 Efforts are underway by ODNR to improve data available for Ohio bat populations through their Ohio Bat Roost Monitoring Project: http://wildlife.ohiodnr.gov/species-and-habitats/fish-and-wildlife-research/bat-roost- monitoring. Additionally, during Indiana bat winter surveys in Ohio’s two hibernacula, other bats are also counted, however these counts are not used to generate population estimates.
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to alter course towards turbines during video observation (Cryan et al. 2014). The reasons for attraction are still not fully understood and the proportion of passing bats that approach turbines remains to be determined, but these findings indicate that migratory bats may be more attracted to wind turbine sites after the turbines are erected. Migratory bats are thought to navigate across large landscapes using vision rather than echolocation, possibly resulting in the bats being attracted to visual landscape features, such as wind turbines, during migration (Cryan and Brown 2007). Migratory bats also may respond to streams of air flowing downwind from trees at night (similar to streams produced downwind from turbines, particularly during low-wind conditions) while searching for roosts, conspecifics, and insect prey (Cryan et al. 2014). As further support for these hypotheses, the majority of bat fatalities occur beginning in late July or early August and continuing through fall, during approximately the same timeframe as southward migration of migratory bats (“fall migration”) (Arnett et al. 2008). At the Project, 49 and 77 percent of recorded bat mortality occurred between August 1 and October 15 during 2012 and 2013, respectively (Project HCP Appendix A). Typically, wind farm mortality records do not show a comparable spring peak in collision mortality despite the fact that bats also migrate during spring. Although reasons for this remain unclear, factors may include differing flight height during spring and fall migration, different spring and fall migration routes, or mating behavior and courtship flight during fall migration (Cryan 2008, Cryan and Barclay 2009). Given the general and Project- specific evidence as discussed above, fall migration mortality of migratory tree-roosting bats is expected to account for the majority of bat mortality under any of the alternatives. While species composition and seasonal timing of bat mortality have been consistent across wind projects, the magnitude of bat mortality, usually expressed as the estimated number of bats killed per MW or per turbine, has varied among projects and across regions. Estimated bat fatality rates in the Midwest ranged from 1.7 to 50.5 bats per MW per survey period for studies conducted between 1996 and 2015 (Appendix E, Table E-4). The average among studies listed in Appendix E, Table E-4 is approximately 19 bats per MW per study. To date, post-construction studies have documented 13 Indiana bat mortalities, 9 of which were within the Indiana bat MRU (Appendix E, Table E-1). Due to the infrequency of Indiana bat mortality, risk factors for this species at wind projects are poorly understood. Of the 13 documented Indiana bat mortalities, eight occurred during fall (Aug.-Oct.), three in summer (June- July), and two in spring (Apr.-May). To date, post-construction studies have documented 48 NLEB mortalities, 8 of which were in the former Service Region 3 (IA, IL, IN, MI, MN, MO, OH, WI)10 (Appendix E, Table E-2). Like the Indiana bat, due to the rarity of northern long-eared bat fatalities, risk factors for this species at wind projects are poorly understood. Of the 48 NLEB mortalities, 37 occurred during fall, 10 in summer, and one in spring. Of the NLEB fatalities in the former Service Region 3, six occurred in fall, one in summer, and one in spring.
10 The Service formerly identified these eight states as being in Region 3. Recently, the U.S. Department of the Interior has created new “unified regions” for consistency across its bureaus. The analysis within this EA uses the Service’s former Region 3, not the new unified Region 3, which has fewer states (6 instead of 8). Further information is available at: https://www.doi.gov/employees/reorg/unified-regional-boundaries.
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4.2.3.3 Effectiveness of Turbine Curtailment at Reducing Bat Mortality Wind turbine blades can be automatically feathered, or pitched, such that turbines spin very slowly, or not at all, under specific weather conditions. Under normal operation, turbine blades usually remain pitched so that the turbine spins, or freewheels below “cut-in speed,” the wind speed at which the turbines begin to generate electricity. Turbine curtailment refers to increasing cut-in speed and feathering turbines so they spin very slowly or not at all, below this increased cut-in speed. Studies conducted at wind projects in a variety of landscapes have demonstrated that curtailment effectively reduces bat mortality and that an inverse relationship exists between cut-in speed and bat fatality rates (Table 2-2). A recent synthesis of curtailment studies reported at least a 50 percent reduction in bat fatalities when turbine cut-in speed was increased by 1.5 m/s above the manufacturer’s rated cut-in speed (Arnett et al. 2013). Based on curtailment studies, feathering below the manufacturer’s cut-in speed or 3.5 m/s and 4.0 m/s has been shown to reduce all bat mortality by 36 percent and 58 percent respectively (Table 2-2). As is clear from Table 2-2, the effectiveness of cut-in speeds vary between sites, and between years at the same sites so our ability to predict bat mortality rates accurately based on application of cut-in speeds is limited. Table 2-2 summarizes the results of curtailment studies conducted to date. Three additional studies have looked at the effectiveness of raising the cut-in speed to 6.9 m/s, as considered in the No-Action Alternative (NAW 2017, Tidhar et al. 2013, Stantec 2015). The average percent reduction across these three studies in all-bat mortality from implementing a cut-in speed of 6.9 m/s is 88 percent (ranging from 83 percent [NAW 2017] to 92 percent [Stantec 2015]). Project-specific monitoring data shows a similar rate of effectiveness in reducing bat mortality. As noted in Section 4.11 of the HCP, data from turbines with no cut-in speed or feathering applied in 2012 and 2013 yielded an all-bat take number of 12.55 bats per MW (spring and fall only). In 2016, monitoring data showed that using a 6.9 m/s cut-in speed during the spring and fall resulted in an all-bat take number of 1.62 bats per MW in the spring and fall combined, for a morality reduction of approximately 87 percent. 4.2.3.4 Estimating Bat Mortality As discussed in Section 3.4.3.3 (with more detail in Section 3.5.3 and Appendix A of the Project HCP), post-construction fatality monitoring at the Project allowed for the development of annual bat fatality rates. All bat fatality rates were calculated each year using the Huso estimator (Huso et al. 2015). In 2012, to avoid biasing the estimates low due to the change in turbine operation, the fall fatality rates were calculated by extrapolating the August 1 to October 3 rates through the end of the study period on November 15. The resulting estimated annual bat fatality rate was 15.51 bats per MW per study period (April 1- Nov. 15). In 2013, the fatality rate was 7.01 bats/MW/study period (April 1-Nov. 15) at turbines feathered below 4.5 m/s in the fall and 11.76 bats/MW/study period (April 1- Nov. 15) at turbines feathered below 3.0 m/s in the fall. In 2015, when all turbines were feathered below 6.9 m/s in spring and fall, the annual bat fatality rate was 7.83 bats/MW/study period (April 1-Nov. 15). In 2016, when all turbines were feathered below 6.9 m/s in spring and fall and monitoring occurred only in spring and fall, the bat fatality rate was 1.62 bats/MW/combined spring and fall migration period.
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As indicated previously, migratory tree-roosting bats account for most bat fatalities at wind projects. These fatalities tend to be much higher during the fall migration; however, bat mortality at wind projects occurs throughout the bat-active season. Hence, the results of post-construction monitoring from spring, summer, and fall at the Project can be used to inform our unlisted bat mortality estimates for the alternatives analyzed in Section 4.2.3.6. As turbines were curtailed below 6.9 m/s at the Project in 2015 and 2016, and below 4.5 m/s at a subset of turbines in 2013, the estimates from turbines operating without feathering or cut-in speeds 2012 and 2013 provide a comparable baseline across alternatives. Averaging the estimated annual all bat fatality rate of 15.51 bats/MW/year (2012) and 11.76 bats/MW/year (2013) equates to an average annual fatality rate of 13.64 bats/MW/year with no cut-in speeds applied. Estimated bat mortality for Covered Species is discussed by alternative in Section 4.2.3.6. 4.2.3.5 Habitat Impacts Land use within the Permit Area is primarily agricultural crops (92.5 percent), with deciduous forest accounting for less than 1 percent of the total land cover (Figure 3-1). Because the Project is already constructed, no impacts to roost habitat are anticipated for any alternative. Similarly, potential impacts to foraging habitat within the Permit Area (i.e., behavioral displacement of foraging bats) are not anticipated and would be expected to be identical among alternatives. Effects from mitigation are described below for each alternative. 4.2.3.6 Direct and Indirect Effects Presented by Alternative This section analyzes the potential effects to listed and unlisted bat species anticipated for each alternative (see Section 2.3 for a summary of operational measures under each alternative). Table 4-1 identifies direct effects of each alternative, indicating the potential impacts unique to each alternative (italicized). Project operations are the only activity anticipated to cause bat mortality; no take is expected to occur during maintenance or mitigation activities. Take in the form of collection of Covered Species carcasses during Intensive and Operations Wildlife Monitoring would be covered by any ITP issued. Predicted mortality for unlisted bats under each action alternative starts at an average annual fatality rate of 13.64 bats/MW/year based on Project post-construction monitoring, as discussed in Section 4.2.3.4. Predicted reductions in bat mortality are based on results of curtailment studies (Table 2-2) that tested the fall cut-in speed specified under each alternative, and from Project monitoring data for applying a cut-in speed of 6.9 m/s. The Applicant’s methods for estimating take of Indiana bat and NLEB for the Proposed Project are explained in detail in the HCP (see Project HCP Section 4.1 and 4.2). The Service applied the same methodology to estimate take for the action alternatives, with the exception of using the percent reductions in bat mortality summarized in Table 2-2 (versus those presented in Table 5.2 of the Project HCP11). As described in Section 2.2, for each action alternative evaluated we started with the annual predicted take amount without cut-in speeds and then applied a reduction in take that was
11 Table 2-2is different than Table 5.2 in the HCP because the Service has deleted references to studies that did not provide a site-specific within-year control and those that included unusual components that may have influenced the study results.
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equal to the mean percent reduction associated with the fall cut-in speed shown in Table 2-2. Take predictions are generated by models that have multiple inputs with variability and error. While they are estimates based on best available data, the Service recognizes they contain inherent error. The estimates generated are intended to provide a relative scale for comparison among alternatives. Alternative 1: No-Action Alternative Under Alternative 1, turbines would be feathered at night, until wind speeds reach 6.9 m/s from a half-hour before sunset to a half-hour after sunrise during the fall migratory period (August 1 through October 31) and spring migratory period (March 15 through May 15). The Service predicts that take of either Indiana bat or NLEB is unlikely with implementation of this curtailment strategy. All-bat mortality is estimated to be 1.77 bats/MW/year, or 538 bats per year under this alternative. This yields a total of approximately 18,833 bat fatalities over the 35-year life of the Project. These estimates include Project-related mortality alone and do not attempt to account for lost reproductive potential. The No-Action Alternative is not expected to result in take of listed bats; therefore, mitigation would not be required. Alternative 2: Applicant’s Proposed Project
Predicted Indiana Bat Take and Impact of the Taking The Applicant predicts that the Project could take approximately 6.27 Indiana bats per year in the absence of the proposed operational minimization (HCP Section 4.1). As discussed in Section 4.2.3.3, existing curtailment studies indicate that feathering below manufacturer’s cut-in speeds can reduce all-bat mortality by 36-57 percent, and feathering below 5.0 m/s during the fall migration period is likely to reduce all-bat fatalities by an average of 61 percent (range 47-82 percent). For our analysis we assume that these all-bat reductions in mortality also apply to Indiana bats. As described in Section 2.2, we also apply the average fall cut-in speed reduction of 61 percent to the annual predicted mortality rate. Applying this percentage, the Service predicts an annual take of 2.5 Indiana bats per year, with a total of approximately 87.5 Indiana bats over the life of the Project. As discussed in Section 2.2.2, the Applicant’s HCP requests a higher level of authorized take based on the Applicant’s assumption that the minimization measures may be less effective at the Project in order to avoid underestimating the level of take; the Applicant’s predicted and requested take authorization is 4.39 Indiana bats per year, for a total of 154 over the Permit Term. The Applicant’s requested take authorizations are presented in italics in Section 4.2.3.7, Table 4-2. In order to allow a meaningful comparison of the alternatives, the Service is evaluating both its own take predictions and the Applicant’s take predictions in this EA.
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Table 4-1. Comparison of Direct Effects to Bats for Each Alternative Alternative Indiana Bat Northern Long-eared Bat Unlisted Bats1 • No mortality anticipated • No mortality anticipated No Operational • Bat morality more than projects in region applying cut-in speeds during summer during summer Curtailment (not • Migratory tree-roosting species primarily affected 2 • Mortality of ~6.3 Indiana • Mortality of ~4.2 NLEBs an alternative) • bats annually annually Mortality of ~4,147 bats annually
• No mortality anticipated • Bat mortality during summer comparable to projects in region • No mortality anticipated Alternative 1: during summer or either • Migratory tree-roosting species primarily affected during summer or either spring No-Action spring or fall migration or fall migration periods • Mortality of ~538 bats annually (87% reduction from no periods operational curtailment)
• No mortality anticipated • No mortality anticipated • Bat mortality during spring migration and early-summer Alternative 2: during summer during summer comparable to projects in region Applicant’s • Migratory tree-roosting species primarily affected Proposed • Mortality of ~2.5 Indiana • Mortality of ~1.6 NLEBs Project3 bats annually (4.39 annually (2.96 Applicant • Mortality of ~1,617 bats annually (61% reduction from no Applicant requested take) requested take) operational curtailment) • Bat mortality during spring migration and early-summer • No mortality anticipated • No mortality anticipated Alternative 3: comparable to projects in region during summer during summer More Restrictive • Migratory tree-roosting species primarily affected • Mortality of ~1.4 Indiana • Mortality of ~1 NLEB Operations • bats annually annually Mortality of ~955 bats annually (77% reduction from no operational curtailment) • Bat mortality during spring migration and early-summer • No mortality anticipated • No mortality anticipated Alternative 4: comparable to projects in region during summer during summer Less Restrictive • Migratory tree-roosting species primarily affected • Mortality of ~2.6 Indiana • Mortality of ~1.8 NLEBs Operations • bats annually annually Mortality of ~1,742 bats annually (58% reduction from no operational curtailment) Note: Italics indicate effects are unique to that alternative. 1. No curtailment applies annual fatality rate of 13.64 bats/MW/year (see Section 4.2.3.4), and estimated reductions in bat mortality are based on fall cut-in speed by alternative (Sections 4.2.3.3, 4.2.3.4). 2. The take predictions for operations without curtailment are presented for general comparison only. It is not an action alternative for the Project. 3. The difference between the Service’s predicted take of Covered Species and the Applicant’s predicted and requested take levels is explained in Section 2.2.2.
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The Service has assumed more female Indiana bats than male Indiana bats will migrate through the Permit Area based on the distance between the Permit Area and the nearest hibernaculum (approximately 75 miles to the south in Preble County, Ohio) (USFWS 2007b). Evidence suggests female Indiana bats may occur more frequently than males as distances from hibernacula increase (Gardner and Cook 2002, Whitaker et al. 2002). The Service assumes a 3:1 ratio of female to male Indiana bats migrate through the Permit Area each spring and fall. Consequently, approximately 75 percent of the 87.5 Indiana bats that the Service predicts will be taken under this Alternative are expected to be female leading to an estimated take of 1.9 female bats per year, or roughly 65.6 female bats over the expected 35-year operational life of the Project. The loss of 65.6 female bats is likely to result in lost reproductive potential in the population. For a declining population, the total predicted lost reproductive capacity during the ITP term is 106 female pups, resulting in a total predicted impact of 171.6 Indiana bats over the 35-year ITP term (USFWS 2016a). The take of 171.6 bats represents an annual impact take of approximately 4.9 Indiana bats per year, which represents 0.002 percent of the estimated 2019 population of the MRU Unit (245,474 Indiana bats, USFWS 2019d), in which the Project is located. This take would be distributed over 35 years and mitigated by the Applicant as described in Section 5.2.3 of the Project HCP and discussed below. Using the Applicant’s predicted take numbers, 115 total female Indiana bats would be taken over the life of the Project, resulting in loss of 183 female pups. This would result in a total predicted impact of 299 Indiana bats over the 35-year ITP term (USFWS 2016a). The take of 299 Indiana bats represents an annual impact take of approximately 8.5 Indiana bats per year, which represents 0.003 percent of the estimated 2019 population of the MRU Unit (245,474 Indiana bats, USFWS 2019d), in which the Project is located. This take would be distributed over 35 years and mitigated by the Applicant as described in Section 5.2.3 of the Project HCP and discussed below.
Predicted Northern Long-Eared Bat Take and Impact of the Taking The Applicant predicts that the Project could take approximately 4.23 NLEBs per year in the absence of the proposed operational minimization (HCP Section 4.2). As noted for Indiana bats and discussed in Section 4.2.3.3, existing curtailment studies indicate that feathering below manufacturer’s cut-in speeds can reduce all-bat mortality by 36-57 percent, and feathering below 5.0 m/s during the fall migration period is likely to reduce all-bat fatalities by an average of 61 percent (range 47-82 percent). For our analysis we assume that these all-bat reductions in mortality also apply to NLEB. As described in Section 2.2, we also apply the average fall cut-in speed reduction of 61 percent to the annual predicted mortality rate. Thus, the Service predicts an annual take of 1.6 NLEBs per year, with a total of approximately 57.7 NLEBs over the life of the Project. As discussed in Section 2.2.2, the Applicant’s HCP requests a higher level of authorized take based on a more conservative assumption of curtailment effectiveness. The Applicant’s predicted and requested take authorization is 2.96 NLEBs per year, for a total of 103 over the Permit Term. These values are presented in italics in Table 4-2 in Section 4.2.3.7. In order to allow a meaningful
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comparison of the alternatives, the Service is evaluating both its own take prediction and the Applicant’s take prediction in this EA. The Service has assumed the same number of female NLEBs as male NLEBs will migrate through the Permit Area. This is based on the lack of any known NLEB hibernacula in the vicinity, as well as evidence that suggests their use of smaller hibernacula that are more distributed on the landscape (Barbour and Davis 1969), which taken together indicates male and female NLEBs may be equally likely to transit the Permit Area. Therefore, the Service assumes a 1:1 ratio of female to male NLEBs migrate through the Permit Area each spring and fall. Consequently, approximately 50 percent of the 57.7 NLEBs taken at the Project are expected to be female leading to a predicted take of approximately 0.8 female bat per year, or roughly 28.9 female bats over the expected 35-year operational life of the Project. The loss of 28.9 female bats is likely to result in lost reproductive potential in the population. For a declining population, the total predicted lost reproductive capacity during the ITP term is 45 female pups, resulting in a total predicted impact of 73.9 NLEBs over the 35-year ITP term (USFWS 2016b). The take of 73.9 bats represents an annual impact take of approximately 2.1 NLEBs per year, which represents 0.004 percent of the estimated post-WNS Midwest population of NLEBs (56,000 NLEB, see Section 3.4.3.2). This take would be distributed over 35 years and mitigated by the Applicant as described in Section 5.2.3 of the Project HCP and discussed below. Using the Applicant’s predicted take numbers, 52 total female NLEBs would be taken over the life of the Project, resulting in loss of 82 female pups. This would result in a total predicted impact of 134 NLEB over the 35-year ITP term (USFWS 2016b). The take of 134 NLEBs represents an annual impact of take of approximately 3.8 NLEB per year, which represents 0.006 percent of the estimated post-WNS Midwest population of NLEBs (56,000 NLEB, see Section 3.4.3.2). This take would be distributed over 35 years and mitigated by the Applicant as described in Section 5.2.3 of the Project HCP and discussed below
Unlisted Bat Mortality Unlisted bat mortality is predicted to be 5.32 bats/MW/year, or 1,617 bats per year, under this alternative. As described in Section 2.2, this reflects an estimated reduction in all bat mortality of 61 percent based on cut-in speeds. This yields a total of approximately 56,605 bat fatalities over the 35-year life of the Project. These predictions include Project-related mortality alone and do not attempt to account for lost reproductive potential.
Mitigation for Taking Covered Species The Project mitigation plan is summarized in Section 2.2.2.2 and described in detail in Section 5.2.3 of the Project HCP. The Applicant plans to offset the taking of Indiana bat and NLEB through summer habitat preservation, summer habitat restoration, fall swarming habitat preservation, fall swarming habitat restoration, or hibernacula gating.
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To support comparison of alternatives in this EA, the Service calculated example summer habitat preservation acres using the REA models and applying the 10 percent stacking adjustment where both Covered Species would be present, and assuming that mitigation would occur for the full predicted and permitted take upfront (see rationale for this in section 2.2.2.2). Under Alternative 2, 219.8 acres of summer habitat preservation would be needed to mitigate the impact of take predicted by the Service. For the impact of take predicted by the Applicant, 382.1 acres of summer habitat preservation would be needed for mitigation. Actual mitigation acreage would depend on the final mitigation project(s) selected and take that is estimated to have occurred based on results of Intensive Monitoring at the Project. Protecting forested habitat and restoring forested habitat also would benefit unlisted bat species. Studies on habitat use by bats in the Midwest show that bat activity is positively correlated with the amount of available forest habitat for Myotis species and tri-colored bat, and negatively correlated for big brown bat and eastern red bat, which frequently forage in more developed habitats (Duchamp et al. 2004). Because much of the landscape in Ohio is dominated by agricultural land use, creating and protecting any additional forested habitat would improve habitat diversity and would benefit all resident bats by increasing the extent and diversity of roosting and foraging habitat. Additional forest habitat in the region also would presumably provide stopover habitat for long-distance migratory species, possibly reducing mortality associated with migration. Hibernacula gating would provide benefit to those bats that hibernate in Ohio, including Covered Species as well as little brown bat, tricolored bat, and big brown bat. It would not provide benefit to the three migratory tree-roosting bats (silver-haired, hoary, and red bats) that are most often killed at wind projects. Alternative 3: More Restrictive Operations
Predicted Indiana Bat and Northern Long-Eared Bat Take and Impact of the Taking Under Alternative 3, the Project is predicted to take 1.4 Indiana bats annually, totaling 49 over the life of the Project, which is less than that expected for Alternative 2 (Table 4-2 in Section 4.2.3.7). The reproductive loss of 61 female pups associated with removal of 36.8 female Indiana bats over the permit duration also would be less than that estimated for Alternative 2, as would the impact of the combined take prediction and lost reproductive potential. Similarly, the NLEB take prediction of 1 bat annually, totaling 34.1 over the life of the Project, and the reproductive loss of 28 female pups associated with removal of 17 female NLEBs over the permit, and the combined take prediction and lost reproductive potential for this alternative would all be less than that predicted for the Applicant’s Proposed Project (Section 4.2.3.7).
Unlisted Bat Mortality Unlisted bat mortality is predicted to be 3.14 bats/MW/year, or 955 bats per year, under this alternative. As described in Section 2.2, this reflects an estimated reduction in all bat mortality of 77 percent based on cut-in speeds. This yields a total of approximately 33,410 bat fatalities over the
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35-year life of the Project. These predictions include Project-related mortality alone and do not attempt to account for lost reproductive potential.
Mitigation for Taking Covered Species Under Alternative 3, the Applicant would need to offset the impact of taking listed bats, as described for Alternative 2, but to a lesser degree because this alternative would result in less take of Covered Species. Following the same method as for Alternative 2, the Service predicts 128.4 acres of summer habitat preservation would be needed to mitigate the impact of take predicted by the Service. Actual mitigation acreage would depend on the final mitigation project(s) selected and take that is estimated to have occurred based on results of Intensive Monitoring at the Project. Listed and unlisted bats would benefit from any summer or fall swarming habitat mitigation carried out by the Applicant, as described in Alternative 2. Alternative 4: Less Restrictive Operations
Predicted Indiana Bat and Northern Long-Eared Bat Take and Impact of the Taking Under Alternative 4, the Project is predicted to take 2.6 Indiana bats annually, totaling 91 over the life of the Project, which is greater than the Service’s predicted take for Alternative 2 (Section 4.2.3.7). The reproductive loss of 112 female pups associated with removal of 68.3 female Indiana bats over the permit duration also would be greater than the Service’s prediction for Alternative 2, as would the impact of the combined take prediction and lost reproductive potential. Similarly, the predicted take of 1.8 NLEB annually, totaling 62.2 over the life of the Project, and the reproductive loss of 50 female pups associated with removal of 31.1 female NLEBs over the permit, and the combined take prediction and lost reproductive potential for this alternative would all be more than the Service’s independent prediction for Alternative 2, the Applicant’s Proposed Project (Section 4.2.3.7).
Unlisted Bat Mortality Unlisted bat mortality is predicted to be 5.73 bats/MW/year, or 1,742 bats per year, under this alternative. As described in Section 2.2, this reflects an estimated reduction in all bat mortality of 58 percent based on cut-in speeds. This yields a total of approximately 60,967 bat fatalities over the 35-year life of the Project. These predictions include Project-related mortality alone and do not attempt to account for lost reproductive potential.
Mitigation for Taking Covered Species Under Alternative 4, the Applicant would need to offset the impact of taking listed bats, as described for Alternative 2, but to a greater degree because this alternative would result in more take of Covered Species. Following the same method as for Alternative 2, the Service estimates 233.9 acres of summer habitat preservation would be needed to mitigate the impact of take predicted by the Service. Actual mitigation acreage would depend on the final mitigation project(s) selected and take that is estimated to have occurred based on results of Intensive Monitoring at the
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Project. Listed and unlisted bats would benefit from any summer or fall swarming habitat mitigation carried out by the Applicant, as described under Alternative 2. 4.2.3.7 Summary of Effects to Bat Resources Table 4-2 provides a summary of mortality estimates under each alternative. Under Alternatives 2, 3, and 4, the Applicant would fully mitigate for the impact of the estimated take of Covered Species using EoA software through summer and fall swarming habitat protection/restoration or hibernacula gating. Under the No-Action Alternative, the Service assumes the Project would kill unlisted bats but at a significantly reduced rate than in the absence of any curtailment. Knowledge of populations is necessary to understand the implications of cumulative bat mortality. Recent research has shown that eastern red bat and hoary bat populations both have large, well- connected populations and have not yet started to show genetic evidence of population declines (Korstian et al. 2015). However, population numbers of tree bats are currently unknown, and therefore the impact of any of the alternatives on tree bat populations cannot be calculated and may or may not be significant. The ongoing monitoring required at the Project and other facilities would allow tracking of impacts, including the proportions of fatalities among the various species.
Table 4-2. Comparison of Estimates of Indiana Bat, Northern Long-Eared Bat, and Unlisted Bat Species Mortality Across Alternatives
Alternatives 2: 5.0 m/s Species Impact 3: 6.5 m/s More 4: 4.0 m/s Less 1: No- Applicant’s Restrictive Restrictive Action Proposed Operations Operations Project1 Predicted annual take 0.00 2.5 (4.39) 1.4 2.6 Total predicted take (annual x 35 0.00 87.5 (154) 49 91 years)
Take of females (75% of take) 0.00 65.6 (115) 36.8 68.3 Indiana bat Lost reproductive potential (lost female pups from every taken 0.00 106 (183) 61 112 female) (USFWS 2016a) Impact of take to be mitigated (taken females + female pups) (USFWS 0.00 171.6 (299) 97.8 180.3 2016a)
Predicted annual take 0.00 1.6 (2.96) 1.0 1.8 Total predicted take (annual x 35 0.00 57.7 (103) 34.1 62.2 years) Northern long- eared Take of females (50% of take) 0.00 28.9 (52) 17 31.1 bat
Lost reproductive potential (lost female pups from every taken 0.00 45 (82) 28 50 female) (USFWS 2016b)
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Alternatives 2: 5.0 m/s Species Impact 3: 6.5 m/s More 4: 4.0 m/s Less 1: No- Applicant’s Restrictive Restrictive Action Proposed Operations Operations Project1 Impact of take to be mitigated (taken females + female pups) (USFWS 0.00 73.9 (134) 45 81.1 2016b)
Unlisted Annual mortality 538 1,617 955 1,742 bat species Total mortality over 35 years 18,833 56,605 34,410 60,967
1. For Covered Species, the Service’s predicted take is provided first, followed by the Applicant’s predicted and requested take level in parentheses/italics. See Section 2.2.2 for discussion of Applicant’s estimate.
4.2.4 Climate Change
4.2.4.1 Impact Evaluation Criteria Direct effects contributing to climate change may include emitting GHGs from a stationary or non- stationary source or through the removal of an existing carbon sink (e.g., forest land). Indirect effects may include proposed activities that do not directly emit GHGs, but through their implementation lead to an increase in GHG emissions from a separate non-project source. 4.2.4.2 Direct and Indirect Effects Common to All Alternatives Project Operations Wind energy is a renewable form of energy production and wind turbines do not produce GHG emissions when generating electricity. Under all alternatives, the Project would continue to provide energy generation from this non-polluting, renewable source, with no direct GHG emissions from operating wind turbines. As discussed in Section 4.2.3.5, because the Project is already constructed, no impacts to forest land or other habitat type that may sequester carbon are anticipated for any alternative. Under all alternatives, Project operations and maintenance may require a small amount of vehicular traffic resulting in the release of GHGs. These emissions are not estimated to make a significant contribution to the amount of GHGs, and would not change from existing conditions under any alternative. Therefore, no direct adverse impacts to climate change are expected under any alternative. In general, existing wind projects are expected to have a long-term beneficial effect on climate change by replacing GHG-producing sources of energy with clean, renewable energy. The Project, under normal operations, can produce enough energy to offset approximately 1.6 billion pounds of CO2 emissions each year, the equivalent of avoiding the consumption of over 2.1 million barrels of oil (Project HCP Section 1.1).
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Under each of the alternatives, operational wind-speed curtailment would reduce the amount of energy produced by the Project as compared to no curtailment. The more energy produced by wind, the less that needs to be produced by burning fossil fuels, thereby lowering the amount of GHGs. Higher cut-in speeds result in less operational time and lost energy production potential (i.e., a cut-in speed of 6.9 m/s would result in less energy produced than a cut-in speed of 5.0 m/s, etc.). Energy production would be highest under Alternative 4, with less restrictive operational curtailment, followed by Alternative 2, the Applicant’s Proposed Project. As compared to Alternative 2, the Applicant estimates that Alternative 3 would result in approximately eight times more energy production loss (Project HCP Section 8.3). Alternative 1, the No Action Alternative, is estimated to result in more than 10 times the energy production loss as compared to Alternative 2 (Project HCP Section 8.2). Nevertheless, in the context of Ohio’s electricity sector where wind energy accounts for less than 1.6 percent of net energy generation (see Section 3.4.4.1), the amount of energy production loss under any alternative at the Project is unlikely to result in a significant increase in fossil fuel energy generation. Therefore, none of the alternatives under consideration would result in significant indirect adverse impacts to climate change. Mitigation for Taking Covered Species Mitigation for Covered Species would not occur under Alternative 1, the No Action Alternative; therefore, no climate change impacts would occur as a result. Mitigation for Covered Species would occur under the three action alternatives and may have a minor beneficial effect on climate change if the selected project entails preserving or restoring forested habitat, which acts as a sink, absorbing carbon dioxide from the atmosphere and partially offsetting GHG emissions (USEPA 2019). Other mitigation project types, such as gating of a winter hibernaculum, would have no effect on climate change.
4.3 Cumulative Effects Following the tiered approach recommended by the CEQ guidelines for analyzing cumulative effects, we focus our analysis on potential impacts to birds, Covered Species, and unlisted bat species, as these are the only resources on which Project operations would have potentially adverse effects. Furthermore, only bats would be affected to varying degrees by the alternatives considered in this EA as we have assumed, based on the available studies, that operational adjustments do not affect bird mortality. Similarly, this analysis largely focuses on cumulative effects of current and projected wind energy development on birds and bats. We also analyze impacts associated with WNS for bats and other mortality sources for birds.
4.3.1 Other Wind Energy Development
According to 2019 data compiled by the American Wind Energy Association, Lawrence Berkeley National Laboratory, and the U.S. Geological Survey, 13,858 turbines totaling 24,627 MW were installed as of July 2019 in the eight states (IA, IL, IN, MI, MN, MO, OH, WI) that make up the former Service Region 3 (Hoen et al. 2019). Based on the most recent information from the Ohio Power Siting Board (OPSB 2019), an additional 367 turbines with a total capacity of 716.1 MW are already
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under construction in Ohio, bringing the total for the Region to 14,225 turbines and 25,343 MW (Table 4-3). Growth in the wind sector has been rapid over the previous few years, and the U.S. Energy Information Administration’s (USEIA) energy forecasts recently indicated a nationwide growth rate of 2.7 percent annually for installed wind energy capacity between 2018 and 2050 (USEIA 2019c). Applying this growth rate to current capacity in the states in the Region over the 35 years of the permit term, we estimate a total capacity of 64,391 MW in the Region by year 2054. Wind energy development in the Indiana bat MRU is based on adding the estimates for Indiana, Michigan, Ohio, and Tennessee. Although the MRU includes Kentucky, northern Alabama, the southwest tip of Virginia, and Georgia, no wind projects occur in these areas. Currently, the MRU includes 3,152 turbines, totaling 5,851 MW of capacity. Applying the same 2.7 percent annual growth rate to the capacity in the MRU yields an estimate of 7,963 turbines and 14,792 MW of installed capacity by year 2054 (Table 4-3).
Table 4-3. Installed and Projected Wind Energy Capacity in former Service Region 3, MRU, and BCR 23 Projected Growth up to 2054 Current Installed State (35 years)2 # MW1 #Turbines # MW1 # Turbines Illinois 4,893 2,780 12,433 7,063 Indiana 2,314 1,264 5,880 3,212 Iowa 9,133 4,878 23,204 12,394 Michigan 2,063 1,113 5,242 2,828 Minnesota 3,801 2,485 9,658 6,314 Missouri 958 498 2,434 1,265 Ohio (Plan Area)3 1,445 757 3,670 1,923 Wisconsin 737 450 1,872 1,143 Region Total 25,343 14,225 64,391 36,142 Tennessee4 29 18 - - MRU Total4 5,851 3,152 14,792 7,963 BCR 235 3,622 2,032 9,202 5,163 1. Estimate developed from Hoen et al. 2019. 2. Assuming 2.7% annual growth, the nationwide trend estimated for wind energy (USEIA 2019c). 3. Data for wind projects currently under construction as of August 2019, available from the Ohio Power Siting Board (OPSB 2019), was added to the total for Ohio to more accurately estimate current and projected capacity for the state. 4. MRU total based on sums from Indiana, Michigan, Ohio, and Tennessee. Tennessee has two wind projects with 29 MW and 18 turbines. Currently, there are no proposals for new wind projects in Tennessee; therefore, growth projections include estimates from Indiana, Michigan, and Ohio only. 5. BCR 23 does not follow state boundaries. The total based on the sum from wind projects located within portions of Illinois, Indiana, Iowa, Michigan, Minnesota, Ohio, and Wisconsin.
BCR 23 does not follow state boundaries and includes portions of Illinois, Indiana, Iowa, Michigan, Minnesota, Ohio, and Wisconsin. Using the BCR 23 boundary, wind energy development in BCR 23 could be estimated using the spatial data provided by Hoen et al. (2019) to only include wind projects within BCR 23. Currently, BCR 23 has 2,032 turbines, totaling 3,622 MW of installed capacity. Applying the 2.7 annual growth rate to the installed capacity in BCR 23 yields an estimate of 5,163 turbines and 9,202 MW of installed capacity by year 2054.
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We recognize that wind development is likely to vary among states. Also, we derived these estimates using only one method among several that could be implemented. Nonetheless, our method represents a straightforward means of estimating reasonably foreseeable wind energy development in the region.
4.3.2 Avian Resources
Our cumulative effects analysis for birds focuses on mortality attributable to the Project in the context of other existing and future wind facilities in BCR 23. To consider region-wide variations in mortality rates, data from 27 Midwest energy facilities were used to calculate regional mortality estimates (AWWI 2019a, 2019b). This provides for a more complete metric to cover region-wide energy facilities, provides a larger sample size and therefore a greater range of mortality rates. This analysis also considers other anthropogenic sources of bird mortality. We briefly discuss on a national scale those elements that are known to cause avian mortality. Researchers typically use data at the national scale to provide estimates of bird mortality from an anthropogenic source. The analysis includes past and present actions and reasonably foreseeable future sources of impacts to birds during the remaining 35 operational years of the Project. Based on our analysis of direct and indirect effects to avian resources in Section 4.2.2, the Project could kill, disturb and displace birds due to Project presence and operations, though not at significant levels. We recognize that birds are unlikely to sustain these same effects at all wind projects in BCR 23. 4.3.2.1 Wind Energy Project Mortality Based on 2012, 2013, and 2015 post-construction mortality monitoring data conducted at the Project, mortality rates are anticipated to range between 1.43 and 6.25 birds/MW/year with an average of 3.7 birds/MW/year, resulting in roughly 435 to 1,900 annual avian fatalities, with an average of 1,125 fatalities within the Project each year. Of the birds killed, approximately 82 percent were passerines. Using these fatality rates, over the permit term the Project could kill between 15,215 and 66,500 birds, with a total of 39,368 birds applying the average rate. Table 4-4 summarizes the current and potential cumulative effects of the Project and wind energy in BCR 23. Using the results from 27 post-construction studies (AWWI 2019a, 2019b) and wind power projects in the Midwest, bird mortality rates ranged from 1.3 to 7.2 birds/MW/year and had a median rate of 2.63 birds/MW/year. We applied this Midwestern regional median avian fatality rate to the current capacity of wind projects in BCR 23 of 3,622 MW (Hoen et al. 2019, OPSB 2019). Using the median rate, regional wind energy facilities in BCR 23 currently kill roughly 9,525 birds each year. The rate at which wind energy will develop over the next 35 years is difficult to predict. As noted in Section 4.3.1, we assumed installed wind energy capacity in BCR 23 would grow by 2.7 percent annually, the rate estimated in USEIA (2019) from 2018 to 2050, resulting in approximately 9,202 MW by year 2054. Based on the median mortality rate (2.63 birds/MW/year), wind projects in BCR 23 may kill about 567,731 birds over the 35-year permit term (Table 4-4). As discussed, bird mortality at the Project is expected to be the same regardless of the alternative under which the Project operates, with an average of 1,125 birds per year. Therefore, over the
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remaining 35-year life of the Project, the Project would contribute approximately 6.9 percent of the median cumulative bird mortality from wind projects in BCR 23 (Table 4-4). Seven BCC species were documented during post-construction mortality monitoring surveys: Black-billed cuckoo, bobolink, brown thrasher, cerulean warbler, dickcissel, golden-winged warbler, and marsh wren (Section 3.4.2.5). We do not expect that wind projects in BCR 23 will cause population-level effects to avian resources, even those BCC that have been identified by the Service given that wind farms contribute to less than one percent of anthropogenic sources of avian mortality. 4.3.2.1 Anthropogenic Sources of Avian Mortality Other than Wind Power Facilities Discussed below and included in Appendix E, Table E-5 are estimates of anthropogenic sources of bird mortality for the U.S. in general. We recognize that the national level is not the cumulative effects analysis area selected for birds in this EA. However, similar data scaled to any region of the U.S. are not available. Communication Towers Avian collisions with communication towers in the U.S. present a significant source of annual mortality, particularly for nocturnally migrating songbirds, namely warblers, vireos, and thrushes (Erickson et al. 2005). Erickson et al. (2005) suggest the number of communication towers in the U.S. may be as many as 200,000 towers, and that 5,000 to 10,000 new towers are being built each year. Mortality estimates range from 4–5 million to 40–50 million birds per year in the U.S., and involve more than 230 species (Kerlinger 2000, Erickson et al. 2005, Manville 2005), with an estimated mean annual mortality of approximately 6.5 million (Longcore et al. 2012). Collisions occur throughout the year but are most frequent during migration periods. Studies indicate fatality rates are highest at taller, guyed towers (Gehring et al. 2009, Gehring et al. 2011). Data associate higher collision rates at pulsating beacons and steady burning Federal Aviation Administration obstruction lighting as compared to towers lit only with flashing or white-strobe beacons (Erickson et al. 2005, Gehring et al. 2009, Gehring et al. 2011). During nights with fog or low cloud-ceiling heights, researchers believe nocturnal migrants become disoriented by steady burning lights on towers (Erickson et al. 2005, Gehring et al. 2009). Estimates of mean annual collisions per tower have ranged from 82 birds per year at a 250-meter tower in Alabama, to 3,199 birds per year at a 305-meter tower in Wisconsin (Erickson et al. 2005).
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Table 4-4. Cumulative Avian Mortality Estimates and Wind Power Capacity in BCR 23 Project Mortality Rates BCR 23 (Regional) (All Alternatives) Birds per MW per Year 35-Year Project % Permit Annual Contribution Annual 35-Year Annual 35-Year Term Mortality to 2019 Mortality Year Permit Term Range Mortality Cumulative Project Regional1 Cumulative Year 2019 Annual 2054 Project % (304 MW) Mortality Mortality (3,622 MW)2 Mortality (9,202 MW) 3 Contribution (304 MW) (304 MW) Median 3.74 2.63 1,125 39,368 9,525 11.8 24,200 567,731 6.9 Minimum 1.43 1.3 435 15,215 4,708 9.2 11,962 280,627 5.4 Maximum 6.25 7.2 1,900 66,500 26,075 7.3 66,251 1,554,243 4.3 1. Based on the range of bird mortality in the Midwest of 1.3 – 9.1 (AWWI 2019a, AWWI 2019b). The minimum regional rate represents the first quartile value of the Midwest studies, not the absolute minimum from a single facility. Regional rates applied to BCR 23 total MW capacity, and Project rates applied to Project MW. 2. Estimate developed from Hoen et al. 2019 and OPSB 2019. 3. Based on project annual growth of 2.7 percent per year (USEIA 2019c). 4. Project average bird mortality rate; more conservative rate than the median with three years of available post-construction monitoring results (2012, 2013, and 2015).
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Buildings USEIA (2015) estimates there were 5.6 million commercial buildings in 2012 in the U.S. More than 134 million residential housing units existed in the U.S. in 2017 (U.S. Census Bureau 2017). Estimates of collisions with buildings and windows suggest a range of 97 million to 1.2 billion bird deaths per year (Erickson et al. 2005). Loss et al. (2014a) estimate that between 365 and 988 million birds (median 599 million) are killed annually by building collisions in the U.S. The vast majority of avian collisions with buildings and windows involve passerines (Erickson et al. 2005). A study conducted in 1996 in Toronto, Ontario estimated 733 avian fatalities per building per year (Erickson et al. 2005). A study of avian collisions with residential windows indicated that avian fatalities range from 0.65 to 7.7 birds per house per year (Erickson et al. 2005). Collisions with other tall structures such as smoke stacks are estimated to result in tens to hundreds of thousands of collisions. Power Lines Manville (2005) estimated that there are collectively 500,000 miles of transmission lines in the U.S. There is an estimate of 116,531,289 distribution poles in the U.S. An accurate estimate of the collective distance of distribution lines is not feasible, but Manville (2005) suggests the length may be in the millions of miles. In general, avian collision and electrocution mortality at power transmission and distribution lines are not systematically monitored or subject to observational biases. Collision estimates range from hundreds of thousands to 175 million birds annually, and estimates of electrocutions range from tens to hundreds of thousands of birds annually. Loss et. al. (2014c) estimate approximately 7.7 to 57.3 million annual avian electrical line collisions. Raptors, particularly eagles, are most commonly reported for collision or electrocution with transmission or distribution lines in the U.S. (Manville 2005). The species composition of birds involved in power line collisions is largely dependent on location. For example, power lines located in wetlands have resulted in collisions of mainly waterfowl and shorebirds, while power lines located in uplands and away from wetlands have resulted in collisions of mainly raptors and passerines (Erickson et al. 2005, Manville 2005). Legal Harvest Banks (1979 as cited in Thogmartin et al. 2006) estimated that 120 million game birds are legally harvested by hunters each year in the U.S. State and federal wildlife managers’ census waterfowl and monitor harvests annually. These data are used to regulate harvest levels through bag limits such that hunting does not contribute to population declines. Vehicles and Airplanes Vehicle strikes are estimated to result in 89 million to 340 million avian fatalities per year (Loss et al. 2014b). Numbers and species involved in vehicle collisions depend on habitat and geographical location (Erickson et al. 2005). Including both U.S. Air Force and civil aircraft strikes, it is estimated that more than 28,500 avian collisions occur each year (Erickson et al. 2005). The majority of bird species involved in airplane strikes include gulls, waterfowl, and raptors (Erickson et al. 2005).
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Domestic Cats Dauphiné and Cooper (2009) estimate that 117 to 157 million feral and free-ranging domestic cats within the U.S. kill at least 1 billion birds annually. Loss et al. (2013) estimate that free-ranging domestic cats kill 1.3 to 3.9 billion birds annually in the U.S. Based on these estimates and others (Manville 2005, Erickson et al. 2005), cat predation is considered the most significant anthropogenic source of bird mortality in the U.S. (Dauphiné and Cooper 2009). Domestic cats are considered as the primary cause for the extinction of 33 bird species since the 1600s (Winter and Wallace 2006). With at least 90 million pet cats estimated in the U.S. and an equal amount expected to be stray or feral cats (Winter and Wallace 2006), domestic cats are considered a significant threat to rare, threatened, and endangered birds and sources of species extinction worldwide. Habitat Loss and Displacement In BCR 23, avian resources have experienced impacts due to land conversion (habitat loss) associated with urbanization, agriculture, and residential development. These activities are likely to continue into the reasonably foreseeable future. Most of these land conversion activities often include extensive road networks. Agriculture activities, urbanization, and residential development convert habitat for the length of time that the development is maintained. Development that includes pavement (asphalt, concrete) results in an extreme conversion of habitat with a very slow recovery rate unless pavement is removed. Conversely, some active agricultural lands may become inactive and revert to native habitats within the 35-year permit term. Reasonably foreseeable future actions in the Permit Area for the next 35 years that will affect avian resources include low-density development for residences and agricultural operations. This will largely affect those birds that are likely to use agriculture lands. 4.3.2.2 Summary of Cumulative Effects to Avian Resources Compared to other anthropogenic sources of avian mortality (see Appendix E,Table E-5), the effect of avian mortality at wind energy facilities is less significant. None of the alternatives considered is expected to cause avian species populations to be reduced to numbers below levels for maintaining viability at local or regional levels. The alternatives will not result in losses or degradation of habitat for a rare, threatened, or endangered avian species. None of the alternatives is expected to result in any changes in habitat conditions producing indirect effects that cause populations to be reduced in numbers below levels for maintaining viability at local or regional levels. Project mortality will contribute cumulatively to other causes of mortality, specifically wind projects and other anthropogenic sources as described above. However, a small fraction of all anthropogenic bird mortality is attributed to wind projects (Appendix E, Table E-5). The Service finds that this amount of bird mortality is not likely to result in population-level impacts to any avian species.
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4.3.3 Bat Resources
4.3.3.1 Wind Project Mortality The cumulative effects analysis for bats primarily focuses on mortality attributable to the Project in the context of other existing and future wind facilities in the former Service Region 3 for NLEB and unlisted bat species, and the MRU for Indiana bat. This analysis also considers the effects of WNS and habitat impacts. This analysis includes present effects of past actions to the extent they are relevant and useful in analyzing whether the reasonably foreseeable effects of the agency’s proposed action and its alternatives may have a continuing additive and significant relationship to those effects. Based on the analysis of direct and indirect effects to bat resources in Section 4.2.3.6, the Project has the potential to kill bats during the 35-year operational life of the Project. The Service recognizes that bat mortality is likely to occur at all wind projects in the former Service Region 3, but that mortality rates are likely to vary by site and between years. Indiana bats Nine Indiana bat fatalities have occurred at wind projects in the MRU, with six of these fatalities occurring in fall, one in summer, and two in spring (Appendix E, Table E-1). Any project within the MRU has the potential to take an Indiana bat during the fall or spring migratory season. Based on a Service post-construction dataset for the Midwest MRU (USFWS 2019f), Indiana bats represented approximately 0.121 percent of all-bat fatalities from 2000 to 2018. Assuming approximately 18.67 bats per MW per year as the average all-bat fatality rate (Appendix E, Table E-4), 0.121 percent of that rate leads to a baseline pre-minimization mortality estimate of 0.023 Indiana bats per MW. Applying this same estimate to the current installed wind energy capacity in the MRU (5,851 MW) results in 132 Indiana bats taken per year within the MRU. By year 2054, the annual predicted take will be approximately 334 Indiana bats based on the projected wind development indicated in Table 4-3. This represents 0.14 percent of the 2019 Indiana bat population in the MRU (245,474 bats). This estimate assumes no reduction in mortality from operational curtailment, no mitigation benefit, and that take of Indiana bat does not decline even if Indiana bat populations decline due to WNS, none of which is a likely scenario. However, this represents a worst-case scenario for the purposes of assessing cumulative effects of wind projects and the contribution of each alternative to the cumulative impact. Table 4-5 provides a summary of cumulative effects to bats from each of the analyzed alternatives and from the future installed capacity of wind projects in the MRU. The Service predicts the No- Action Alternative for the Project is unlikely to result in Indiana bat mortalities and, therefore, will not contribute to cumulative impacts to Indiana bat. Under Alternative 2 the Service’s predicted take is 2.5 Indiana bats per year and 87.5 bats over the duration of the permit, accounting for 1.1 percent of the cumulative predicted take for the MRU during the same period. The Applicant’s predicted take is 4.39 Indiana bats per year and 154 over the duration of the permit, accounting for 2.0 percent of the cumulative take predicted for the MRU during the same period. Alternative 3 is predicted to take 1.4 Indiana bats per year and 49 Indiana bats over the full permit duration, accounting for 0.7 percent of cumulative take for the MRU. Alternative 4 is predicted to take 2.6
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Indiana bats per year and 91 Indiana bats over the full permit duration, accounting for 1.2 percent of cumulative take for the MRU. The action alternatives are not substantially different in the extent to which they contribute to cumulative adverse impacts to Indiana bat in the MRU, particularly considering that the Applicant would fully offset estimated take associated with Alternatives 2, 3, and 4 using mitigation of summer, fall swarming, and/or hibernation habitat mitigation. Northern Long-eared Bats Post-construction monitoring results for the former Service Region 3 reported eight NLEB fatalities to date (Appendix E, Table E-2). However, any project within the species’ range has the potential to take NLEB, particularly during the fall migratory season. Using a Service dataset (USFWS 2019f) of projects within the Service’s former Region 3, NLEB represented approximately 0.051 percent of all-bat fatalities from 1998 to 2018. Assuming approximately 18.67 bats per MW per year as the average all-bat fatality rate (Appendix E, Table E-4), 0.051 percent of that rate leads to a pre- minimization baseline mortality estimate of 0.01 bats per MW. Applying this estimate to the current installed wind energy capacity in the Service’s former Region 3 (25,343 MW) yields 241 NLEBs taken each year within the Region. By year 2054, the annual predicted take would be roughly 613 NLEBs based on the projected wind development indicated in Table 4-3. Summing the annual mortality over the operational life of the Project (35 years) results in approximately 14,384 NLEBs taken by wind projects cumulatively in the Region (Table 4-5). This estimate assumes no reduction in mortality from operational curtailment, that take of NLEB does not decline even if NLEB populations decline due to WNS, and no mitigation benefit, none of which would be a likely scenario. However, this represents a worst-case scenario for the purposes of assessing the contribution of each alternative to the cumulative totals. With updated WNS information, the Service currently estimates there may be 56,000 NLEBs in the Midwest region (see Section 3.4.3.2). An annual mortality of 613 NLEB in 2054 is approximately 1.1 percent of the regional population. Additionally, as the population of NLEB declines, it is likely that the take rate at wind energy projects will also decline, leading to lower take rates in 35 years as compared to the current level. With the implementation of curtailment and mitigation projects, the Service concludes that this extent of mortality at the Project level and the regional level is not likely to lead to population-level declines of NLEB.
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Table 4-5. Cumulative Effects to Indiana Bats, Northern Long-Eared Bats, and Unlisted Bat Species from the Project and Projected Installed Wind Power Capacity in the Midwest Recovery Unit and former Service Region 3 Alternative MRU 2054 MRU 2019 Region 3 Region 3 2: 3: 4: Wind Wind 2019 Wind 2054 Wind Species Impact 1: Applicant’s More Less Installation Installation Installation Installation No Action Proposed Restrictive Restrictive 14,792 5,851 MW1 25,343 MW1 64,391 MW1 304 MW Project Operations Operations MW1 304 MW 304 MW 304 MW
Annual mortality 0.00 2.5 (4.39) 1.4 2.6 132 334 -- --
Cumulative Indiana 0.00 87.5 (154) 49 91 7,840 -- bat2 mortality Project % contribution 0.00% 1.1 (2.0)% 0.6% 1.2% -- -- to cumulative mortality Annual mortality 0.00 1.6 (2.96) 1.0 1.8 -- -- 241 613 Northern long- Cumulative mortality 0.00 57.7 (103) 34.1 62.2 -- 14,384 eared Project % contribution bat2 0.00% 0.4 (0.7)% 0.2% 0.4 -- -- to cumulative mortality
Annual mortality 538 1,617 955 1,742 -- -- 473,157 1,202,183 Unlisted bat Cumulative mortality 18,833 56,605 34,410 60,967 -- 28,203,163 species Project % contribution 0.1% 0.2% 0.1% 0.2% -- -- to cumulative mortality
1. Predictions of MRU and former Service Region 3 mortality assumes all projects will operate with no adjustments (curtailments or feathering). Unlisted bat fatality rate is 18.67 bats per MW per year, the average of rates observed at ten wind projects over multiple years (Appendix E, Table E-4). Indiana bat fatality rate is 0.023 bats per MW per year, and NLEB fatality rate is 0.01 bats per MW. These rates are based on the portion of all-bat fatalities identified by the Service for Indiana bats in the MRU and NLEB in former Service Region 3 (USFWS 2019f) multiplied by the unlisted bat fatality rate used in this analysis of 18.67 bats per MW per year. 2. For Covered Species, under Alternative 2 the Service’s predicted take is listed first, followed by the Applicant’s predicted and requested take level in parentheses/italics (see Section 2.2.2 for discussion).
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Table 4-5 provides a summary of cumulative effects to bats from each of the analyzed alternatives and from the possible future installed capacity of wind projects in the Service’s former Region 3. The Service predicts the No-Action Alternative for the Project is unlikely to result in NLEB fatalities and, therefore, will not contribute to cumulative adverse impacts to NLEB. Under Alternative 2 the Service’s predicted take is 1.6 NLEBs per year and 57.7 bats over the course of the permit duration, accounting for 0.4 percent of the cumulative take prediction for the Region during the same period (Table 4-5). The Applicant’s predicted take is 2.96 NLEB per year and 103 over the duration of the permit, accounting for 0.7 percent of the cumulative take predicted for the Region during the same period. Alternative 3 is predicted to take 1.0 NLEB per year and 34.1 bats over the permit duration, accounting for 0.2 percent of the cumulative take for the Region during this period. Alternative 4 is predicted to take 1.8 NLEBs per year and 62.2 bats over the permit duration, accounting for 0.4 percent of the cumulative take for the Region during this period. The action alternatives are not substantially different in the extent to which they contribute to cumulative adverse impacts to NLEB, particularly considering that the Applicant would fully offset estimated take from the Project associated with Alternatives 2, 3, and 4 through implementation of summer, fall swarming, and/or hibernation habitat mitigation. Unlisted Bat Species Rates of mortality of unlisted bats vary substantially among projects and depend to a large extent on operational decisions and turbine characteristics, both of which are subject to change over time as the wind industry grows and becomes more sophisticated. Nevertheless, for the purposes of assessing cumulative impacts to unlisted bats, we use an average fatality rate of 18.67 bats per MW per year, which is based on publicly available information from ten wind projects in the Service’s former Region 3 (IA, IL, IN, MI, MN, MO, OH, WI) (Appendix E, Table E-4). The bat fatality rates from these projects were based on normal turbine operations (no feathering or cut-in speeds applied for bat conservation), and roughly 90 percent of the fatalities were migratory tree-roosting bats. The Service assumed this rate is applicable for all wind projects in the Service’s former Region 3 and will remain constant during the 35 years of Project operation. Applying this rate of 18.67 bats/MW/year to the 25,343 MW of wind turbines currently installed in the Region yields a mortality estimate of roughly 473,157 unlisted bats, 425,841 of which will be migratory tree- roosting bats. Applying this rate to the projected installed capacity of 64,391 MW of wind turbines in year 2054 indicates annual mortality of approximately 1,202,183 unlisted bats in the Region, for a potential cumulative total of roughly 28.2 million bats taken during this 35-year permit period (Table 4-5). Of this total, approximately 25.4 million will potentially be migratory tree-roosting bats. The Service assumed that the rate of 18.67 bats per MW per year is the appropriate rate, but regional fatality rates for bats are likely to be less as operational curtailment is becoming more common and may significantly reduce unlisted bat mortality region-wide. Nonetheless, this value provides a reasonable fatality rate for estimating cumulative effects to bats in the Region. Cumulative mortality for unlisted bats across the four alternatives ranges from roughly 18,833 bats to 60,967 bats over the life of the Project, accounting for less than 1 percent of cumulative unlisted bat mortality for the Service’s former Region 3, with the Applicant’s Proposed Project accounting
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for 56,605 bats or 0.2 percent of cumulative mortality (Table 4-5). The action alternatives are not substantially different in the extent to which they contribute to cumulative impacts to unlisted bats. Additionally, mortality of unlisted bats at the Project is not expected to be a significant addition to the cumulative bat mortality at wind energy facilities in the Region, particularly with implementation of operational adjustments. Direct mortality of 28.2 million unlisted bats over the next 35 years associated with wind energy facilities, in concert with other challenges faced by these species, could have a substantial cumulative effect on these species, including potentially substantial declines in populations (Frick et al. 2017). Other recent research has shown that eastern red bat and hoary bat populations both have large, well-connected populations and have not yet started to show genetic evidence of population declines (Korstian et al. 2015). However, it is unknown whether tree bat populations can be sustained under wind energy development that may cause the loss of millions of bats over the next 35 years. The actual level of bat mortality across the region may be lower, as some wind energy facilities in the Service’s former Region 3 now implement at least some degree of modified turbine operations during the fall bat migration season. Additionally, a growing body of research and improved understanding of the factors affecting bat mortality risk at wind energy facilities is likely to increase the effectiveness of future turbine operational protocols at reducing bat mortality, as well as aid in siting decisions to minimize impacts on bats. If all wind energy facilities in the region followed AWEA guidelines (AWEA 2015) regarding feathering below manufacturer’s cut-in speed over the next 35 years, this would reduce bat mortality by 35 percent or more, and the cumulative impacts of wind energy development on bat species not listed under the ESA in the Region would be greatly reduced. 4.3.3.2 White-Nose Syndrome WNS has emerged as the largest single source of mortality for cave-hibernating bats in recent years. As of July 2019, bats with WNS have been confirmed in 33 states and seven Canadian provinces and the fungus that causes WNS has been confirmed in five additional states (California, Mississippi, North Dakota, Texas, and Wyoming) (USFWS 2019e). The Service estimates that the fungus has killed over 6 million bats in the Northeast and Canada, with some sites experiencing a 90 to 100 percent loss (USFWS 2018b). Turner et al. (2011) documented an 88 percent decline in overall numbers of hibernating bats comparing pre- and post-WNS counts at 42 sites in five northeastern states with declines varying by species. At these sites, NLEBs decreased by 98 percent, little brown bats by 91 percent, tri-colored bats by 75 percent, Indiana bats by 72 percent, big brown bats by 41 percent, and eastern small-footed bats by 12 percent (Turner et al. 2011). To date, WNS has not been documented in migratory tree-roosting bat species (hoary bat, silver-haired bat, eastern red bat), which account for the majority of wind turbine-related mortality. The Service has estimated a decline of about 19 percent in the number of Indiana bats range-wide since the onset of WNS in 2007, with a decline of 20.4 percent estimated within the MRU since 2011 (USFWS 2019d). While the range-wide decline is estimated at 19 percent, there have been some
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hibernacula studies that have documented a 100 percent mortality rate of Indiana bat due to WNS (Turner et al. 2011). As noted earlier, it is possible the Midwest region has seen a NLEB population reduction by as much as 98 percent as a result of WNS (the population loss reported in the northeast by Turner et al. 2011). Such a decline in Indiana bat and NLEB populations across the region would likely reduce the probability of their mortality at wind projects, but also would increase the ecological impact of all sources of mortality. Based on proportions of individuals of WNS-affected North American species with relatively high fungal loads but lower infection intensities, Hoyt et al. (2016) predicted that Indiana bats and big brown bats were unlikely to experience WNS-related extinction. In addition, Lilley et al. (2016) found that surviving little brown bats exhibited less frequent arousals than had been documented for bats dying due to WNS, suggesting that survivors may respond to the disease differently. However, NLEB populations may not have the same ability to stabilize or recover from WNS (Frick et al. 2015). 4.3.3.3 Habitat Loss and Fragmentation Cumulative impacts of land use conversion and habitat fragmentation on bats in the Midwest have largely taken place in the past, as agricultural land use has dominated the region for decades. Often wind projects in the Midwest, such as the Project, are built in agricultural areas and do not contribute to forest habitat loss. However some wind projects are built in areas where forest habitat impacts cannot be avoided and thus may contribute to loss of forest habitat for bats. Mitigation for bats under wind power HCPs may protect and restore some forest habitat for bats. Therefore, expansion of wind energy in the region may contribute a small amount toward cumulative effects of summer bat habitat loss. Winter bat habitat (caves and mines) are relatively static features on the landscape and are not typically impacted by specific threats associated with habitat loss. WNS may have drastic impacts on hibernating bat populations, but will not alter the physical characteristics of hibernacula. 4.3.3.4 Summary of Cumulative Effects to Bat Resources The Service acknowledges that bat mortality at wind projects contributes to overall bat mortality, and the Project mortality will contribute cumulatively to other wind project mortality. Compared to the effects of WNS, cave-dwelling bat mortality at wind energy facilities is minor. However, wind energy facilities kill more migratory tree-roosting bats than any other known documented source. All four alternatives will contribute cumulatively to effects associated with bat mortality. Based on results of post-construction monitoring, the Service finds that the No-Action Alternative will result in a relatively small amount of bat mortality (Sections 3.4.3.3 and 4.2.3.6). Among the three action alternatives, Alternative 3 will contribute the least to cumulative bat mortality, and Alternative 4 will likely contribute the most. Under any of the four alternatives, there will be some impact associated with either avoidance or displacement should bats react to the presence of turbines. However, the extent of this effect is unknown. Mitigation for estimated take of Covered Species would result in the permanent protection, and restoration if needed, of habitat known to be used by these species during critical life stages such as
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breeding, pup rearing, and hibernation. Mitigation is expected to benefit the covered species by contributing to survival and reproduction and therefore fully offsetting the impact of the take for any of the four Alternatives. Mitigation may benefit other bat species in the Plan Area as well. As compared to the No-Action Alternative, Alternative 2 (Applicant’s Proposed Project) would have roughly three times as much annual mortality of unlisted bats. Alternative 2 also includes mitigation to fully offset the impact of the estimated take of Indiana bat and NLEB and may benefit other bat species. The HCP, as part of Alternatives 2, 3, and 4, includes a monitoring plan and an adaptive management framework designed to monitor listed bat mortality and respond to significant listed bat mortality should it be identified. By 2054, the cumulative impact of wind power projects in the Service’s former Region 3 is predicted to result in mortality of roughly 28.2 million unlisted bats, most of these being migratory tree-roosting bats (approximately 90 percent). The effect of cumulative mortality on unlisted bat populations is uncertain because no population estimates exist for these species; however, the direct mortality of millions of unlisted bats at wind energy facilities over the next 35 years in concert with other threats to these species could have a substantial adverse cumulative effect on these species, including potentially substantial declines in populations (Frick et al. 2017). However, as noted earlier, the actual level of bat mortality across the region may be lower due to increasing implementation of modified turbine operations, new research and improved understanding of effective operational measures, and improved siting decisions to minimize impacts on bats. Additionally, mitigation offsetting the impact of Covered Species take may also benefit unlisted bats. Under Alternative 2, bat mortality would be reduced by approximately 61 percent compared to operating without cut-in speeds due to the curtailment strategy. The cumulative effect of wind mortality on Indiana bat in the MRU and on NLEB in the Service’s former Region 3 in combination with WNS is difficult to predict. Possibilities include a synergistic effect of two new stressors affecting the species at the same time. It also is possible that as the population of either species is reduced by WNS, the numbers of bats taken at wind facilities also would be reduced. However, the impacts of taking bats are likely to increase because each individual would become more important. Research into these questions is ongoing and will likely focus, in part, on how these new stressors will affect rare bat populations and ecology.
Consultation and Coordination
5.1 Agency and Tribal Coordination In support of the application to build a wind energy project in Van Wert and Paulding counties, Ohio, the Applicant consulted with the Service, ODNR, and other state and local agencies. While there are no tribal lands currently in Ohio, the Service is sending notice of this Draft EA to Tribes with historic interest in Ohio to solicit input during the public comment period. The Service will also consult with ODNR prior to finalizing the EA.
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5.2 Distribution of the Draft EA In accordance with NEPA, this Draft EA is being circulated for public review and comment. The public review period is initiated with the publication of the Notice of Availability (NOA) in the Federal Register, and the public comment period will extend for 30 days from the date of publication.
List of Preparers
Name Project Role and Qualifications U.S. Fish and Wildlife Service Megan Seymour EA Project Manager, EA Preparation and Review USFWS Ohio Field Office Patrice Ashfield Project Leader/Responsible Official USFWS Ohio Field Office Erik Olson EA Review USFWS Region 3 Office Sharon Pudwill EA Review US Dept. of the Interior Solicitor Tetra Tech, Inc. EA Project Manager, EA Preparation and Review M.A. Earth Science and Geology Leslie Knapp 36+ years’ experience with NEPA and state level environmental review and permitting for energy and other projects. EA Preparation and Review M.S. Wildlife Biology Susan Hurley 18 years’ experience with NEPA, T&E species, and other permitting with technical background in avian and bat ecology. EA Preparation M.P.A Environmental Policy/Natural Resource Management Rachael Katz 14 years’ experience in public and private sectors, with last seven years focused on NEPA, ESA, and other environmental permitting.
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Appendix A – Acronyms and Abbreviations
December 2019 U.S. Fish and Wildlife Service DRAFT ENVIRONMENTAL ASSESSMENT FOR APPENDIX A. ACRONYMS AND ABBREVIATIONS PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC
Acronyms and Abbreviations °C degrees Celsius °F degrees Fahrenheit Applicant Blue Creek Wind Farm, LLC AWWI American Wind Wildlife Institute BCC Birds of Conservation Concern BCR Bird Conservation Region BO Biological Opinion CEQ Council on Environmental Quality CFR Code of Federal Regulations EA Environmental Assessment EO Executive Order ESA Endangered Species Act FONSI Finding of No Significant Impact FR Federal Register GHG greenhouse gas HCP Habitat Conservation Plan ITP Incidental Take Permit m/s meters per second MRU Midwest Recovery Unit MW megawatt NEPA National Environmental Policy Act NLEB northern long-eared bat NMFS National Marine Fisheries Service O&M operations and maintenance ODNR Ohio Department of Natural Resources ORC Ohio Revised Code P Priority PIF Partners in Flight Project Blue Creek Wind Farm Project
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REA Resource Equivalency Analysis SCADA supervisory control and data acquisition Service U.S. Fish and Wildlife Service SO Secretarial Order U.S. United States USC United States Code USDOI U.S. Department of the Interior USEPA U.S. Environmental Protection Agency USEIA U.S. Energy Information Administration WNS white-nose syndrome
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Appendix B – Figures
December 2019 U.S. Fish and Wildlife Service Figure 1 1 Blue Creek Wind Farm ocation - L Figure 1 -2 Turbines Locations and B oundary of the Permit Area for the Blue Creek Wind Farm Habitat Conservation Plan Figure 3-1 Blue Creek Wind Farm Land Cover DRAFT ENVIRONMENTAL ASSESSMENT FOR PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC
Appendix C – References
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December 2019 U.S. Fish and Wildlife Service 16 DRAFT ENVIRONMENTAL ASSESSMENT FOR APPENDIX C. REFERENCES PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC
USFWS. 2017a. Final Environmental Assessment for Proposed Habitat Conservation Plan and Incidental Take Permit. Hoopeston Wind Project. Vermilion County, Illinois. Available online: https://ecos.fws.gov/docs/plan_documents/neas/neas_1682.pdf USFWS. 2017b. Threats to Birds: Migratory Bird Mortality – Questions and Answers. Division of Migratory Bird Management, Falls Church, Virginia, USA. Available at: https://www.fws.gov/birds/bird-enthusiasts/threats-to-birds.php. Accessed on October 21, 2019. USFWS. 2018a. Midwest Region Endangered Species. Ohio County Distribution of Federally-Listed Endangered, Threatened, and Proposed Species. Revised January 29, 2018. Available at: https://www.fws.gov/midwest/endangered/lists/ohio-cty.html USFWS. 2018b. White-nose syndrome: the devastating disease of hibernating bats in North American. U.S. Fish and Wildlife Service. June 2018. https://www.whitenosesyndrome.org/mmedia-education/white-nose-syndrome-fact- sheet-june-2018 USFWS. 2018c. Threats to Birds: Collisions – Wind Turbines. Available online: https://www.fws.gov/birds/bird-enthusiasts/threats-to-birds/collisions/wind- turbines.php USFWS. 2019a. Service Manual Chapters. Series 500 – Interagency, Intergovernmental and International Activities, Environmental Quality Series. U.S. Fish and Wildlife Service, Division of Policy, Performance, and Management Programs. Accessed May 21, 2019. Available at: https://www.fws.gov/policy/manuals/part.cfm?series=500&seriestitle=INTERAGENCY, INTERGOVERNMENTAL AND INTERNATIONAL ACTIVITIES, ENVIRONMENTAL QUALITY SERIES USFWS. 2019b. Final Environmental Assessment for Proposed Habitat Conservation Plan and Incidental Take Permit. Headwaters Wind Farm, LLC. Randolph County, Indiana. Available online: https://ecos.fws.gov/docs/plan_documents/neas/neas_2441.pdf USFWS. 2019c. Final Environmental Impact Statement for Proposed Habitat Conservation Plan and Incidental Take Permit. MidAmerican Energy Company Wind Energy Facility Portfolio, Iowa. September 6, 2019. Available online: https://www.fws.gov/midwest/rockisland/te/pdf/Final%20EIS%20for%20the%20MidA merican%20Energy%20Company%20HCP%20and%20ITP.pdf
USFWS. 2019d. 2019 Indiana Bat (Myotis sodalis) Population Status Update. Indiana Ecological Services Field Office, U.S. Fish and Wildlife Service. Revised June 27, 2019. Available online: https://www.fws.gov/Midwest/endangered/mammals/inba/pdf/2019_IBat_Pop_Estimate _6_27_2019a.pdf
December 2019 U.S. Fish and Wildlife Service 17 DRAFT ENVIRONMENTAL ASSESSMENT FOR APPENDIX C. REFERENCES PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC
USFWS. 2019e. White-nose Syndrome Occurrence by County or District (or portions thereof). WNS timelapse from 2005-06 through 2018-19. Data last updated July 25, 2019. Accessed August 6, 2019. https://www.whitenosesyndrome.org/where-is-wns. USFWS. 2019f. Northern long-eared bat and Indiana bat, Wind Power post-construction mortality summary. Provided by USFWS Columbus, OH Ecological Services Field Office. October 10, 2019. USFWS and NMFS (National Marine Fisheries Service). 1998. Habitat Conservation Plans – Rules and Regulations. Federal Register 63: 8859-8873. February 23, 1998. Available online at: https://www.fws.gov/endangered/what-we-do/rules-and- regulations.html. USFWS and NMFS. 2016. Habitat Conservation Planning and Incidental Take Permit Processing Handbook. https://www.fws.gov/endangered/esa-library/pdf/HCP_Handbook.pdf. Accessed August 2018. USGS (US Geological Survey). 2011. National Land Cover Database 2011. Multi-Resolution Land Characteristics Consortium, National Land Cover Database. USGS Earth Resources Observation and Science Center, Sioux Falls, South Dakota. Available online: https://www.mrlc.gov/data/nlcd-2011-land-cover-conus-0 Walston, L.J., K.E. Rollins, K.E. LaGory, K.P. Smith, S.A. Meyers. 2016. A preliminary assessment of avian mortality at utility-scale solar energy facilities in the United States. Renewable Energy 92: 405–414. doi: 10.1016/j.renene.2016.02.041. Available online: https://www.sciencedirect.com/science/article/pii/S0960148116301422 WEST (Western Ecosystems Technology, Inc.). 2009. Habitat Assessment for Indiana Bats and Raptor Nest Search along the Proposed Blue Creek Transmission Line: December 15, 2009. Prepared for Iberdrola Renewables. Bloomington, Indiana. Whitaker, J. O., Jr., and L. J. Rissler. 1992. Winter activity of bats at a mine entrance in Vermillion County, Indiana. American Midland Naturalist 127: 52-59. Whitaker, J.O., Jr. and W.J. Hamilton, Jr. 1998. The Mammals of the Eastern United States, Third Edition. Cornell University Press, Ithaca, New York. 583 pp. Whitaker, J. O., Jr. and F. A. Winter. 1977. Bats of the Caves and Mines of the Shawnee National Forest, Southern Illinois. Transactions of the Illinois Academy of Science 70: 301-313. Whitaker, J. O., Jr., V. Brack, and J. B. Cope. 2002. Are Bats in Indiana Declining? Proceedings of the Indiana Academy of Science 1: 95-106. Winhold, L. and A. Kurta. 2006. Aspects of migration by the endangered Indiana bat, Myotis sodalis. Bat Research News 47(1):1-6. Winter, L., and G. E. Wallace. 2006. Impacts of Feral and Free-Ranting Cats on Bird Species of Conservation Concern. Other Publications in Wildlife Management. 28. Available at: http://digitalcommons.unl.edu/cgi/viewcontent.cgi?article=1027&context=icwdmother. Accessed on April 15, 2019.
December 2019 U.S. Fish and Wildlife Service 18 DRAFT ENVIRONMENTAL ASSESSMENT FOR APPENDIX C. REFERENCES PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC
Woods, A. J., J. M. Omernik, C. S. Brockman, T. D. Gerber, W. D. Hosteter, and S. H. Azevedo. 1998. Ecoregions of Indiana and Ohio. (Color poster with map, descriptive text, summary tables, and photographs.) US Geological Survey (USGS) map (map scale 1:1,500,000). USGS, Reston, Virginia. US Environmental Protection Agency (USEPA). Information online: https://www.epa.gov/eco-research/ecoregion-download-files-state-region-5#pane-33 Young, D. P., Jr., W. P. Erickson, K. Bay, S. Nomani, and W. Tidhar. 2009. Mount Storm Wind Energy Facility, Phase 1 Post-Construction Avian and Bat Monitoring, July - October 2008. Prepared for NedPower Mount Storm, LLC, Houston, Texas. Prepared by Western EcoSystems Technology (WEST), Inc., Cheyenne, Wyoming. February 17, 2009. Young, D. P., Jr., C. Nations, M. Lout, and K. Bay. 2013. 2012 Post-Construction Monitoring Study, Criterion Wind Project, Garrett County, Maryland. April - November 2012. Prepared for Criterion Power Partners, LLC, Oakland, Maryland. Prepared by Western EcoSystems Technology, Inc. (WEST), Cheyenne, Wyoming, and Waterbury, Vermont. January 15, 2013.
December 2019 U.S. Fish and Wildlife Service 19 DRAFT ENVIRONMENTAL ASSESSMENT FOR PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC
Appendix D – USFWS Template Language to Be Included in Easement and Fee Simple Conveyances
December 2019 U.S. Fish and Wildlife Service APPENDIX D
USFWS TEMPLATE LANGUAGE TO BE INCLUDED IN EASEMENT AND FEE SIMPLE CONVEYANCES
Real property deeds, transfers, and conservation easements take a variety of forms. To provide uniformity and consistency when implementing the Habitat Conservation Plan and Incidental Take Permit (HCP/ITP) mitigation requirements, this Template presents the legal text to be included when drafting those conveyance documents. Where indicated, there may be flexibility in terms of the language used or the content of a particular provision.
This Template reflects the organization and content of a standard conveyance document in that it includes recitals, purpose, rights, interpretation and miscellaneous provisions. Restrictions on uses and reserved rights appear at the end.
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The following legal recitals must be included in any legal document conveying a real property interest over conservation lands. Due to variations in state law and the type of conveyance that may be used, and the preferences of the parties as to the format of their documentation, the wording of these recitals may need to change, but must remain substantially similar in content. The parties are entitled to include other recitals that are not contradictory.
RECITALS
WHEREAS, this ______[insert type of conveyance] is conveyed this ______day of ______, from ______[name], a ______[description of entity], Grantor, with an address of______, to ______[name], a ______[description of entity], Grantee, with an address of ______; and
WHEREAS, the Grantor is [the owner in fee simple of][current holder of an easement or lease, over, through and across] certain real property, hereinafter called the "Protected Property," which has ecological, scientific, educational and aesthetic value in its present state as a natural area which has not been subject to development or exploitation [or describe status with respect to development or exploitation] , which property is located in ______and is more particularly described in Exhibit A, attached hereto and incorporated by this reference; and
(If applicable) WHEREAS, the Grantee, is a nonprofit corporation incorporated under the laws of [State, Commonwealth, or District] as a tax-exempt public charity under Section 501(c)(3) and/or 509(a)(1) of the Internal Revenue Code of 1986, as amended, and the regulations promulgated pursuant thereto (“IRC”); Grantee, whose purpose is to preserve natural areas for scientific, charitable, educational and aesthetic purposes, is qualified under section 170(h) of the IRC to receive qualified conservation contributions; and APPENDIX D
(If applicable) WHEREAS, the Protected Property is a significant natural area which qualifies as a "...relatively natural habitat of fish, wildlife, or plants, or similar ecosystem," as that phrase is used in P.L. 96-541, 26 USC 170(h)(4)(A)(ii), as amended, and in regulations promulgated thereunder; specifically, the Protected Property is habitat for the ______[ESA listed species for which mitigation is required]; and
WHEREAS, the Protected Property consists of ______[general description of habitat] and conservation of the Protected Property will protect and enhance ______[describe habitat values to be conserved], particularly as it relates to the [ESA listed species] with regard to ______[discuss species needs and behaviors (e.g., breeding, feeding, sheltering, migration, etc.]; the Protected Property’s______[describe habitat values] provides [or will provide] suitable ______habitat for the______[ESA listed species]; and
WHEREAS, the United States Fish and Wildlife Service (the “USFWS”) within the United States Department of the Interior, is authorized by federal law to administer the federal Endangered Species Act (hereinafter “ESA”), 16 U.S.C. § 1531 et seq., and other laws and regulations; and
WHEREAS, the ______[ESA listed species] has been listed as ______[insert species listing status; e.g., endangered or threatened] by the USFWS under the ESA; and
WHEREAS, ______applied to the USFWS for the issuance of an Incidental Take Permit (the “ITP”), submitted a Habitat Conservation Plan (“HCP”) pursuant to ESA Section 10 regarding its ______, and was issued an ITP on ______[insert date]; and
WHEREAS, ______is required to mitigate for take of ESA listed species, including ______[species to be conserved through this conveyance], in a manner and amount consistent with the terms of its HCP, and intends to accomplish said mitigation through acquisition and permanent preservation of the Protected Property, and implementation of mitigation measures on the Protected Property, if necessary; and
WHEREAS, the specific conservation values of the Protected Property are documented in an Easement Documentation Report, prepared by ______[insert name of entity preparing report] and signed and acknowledged by the Grantor, establishing the baseline condition of the Protected Property at the time of this grant and including reports, maps, photographs, and other documentation; and
WHEREAS, the Grantor and Grantee have the common purpose of conserving the above-described conservation values of the Protected Property in perpetuity; and
[If through a conservation easement] WHEREAS, the State [or Commonwealth] of ______has authorized the creation of Conservation Easements pursuant to ______[insert citation to state law] and Grantor and Grantee wish to avail themselves of the provisions of that law;
NOW, THEREFORE, the Grantor, for and in consideration of the facts above recited and of the mutual covenants, terms, conditions and restrictions herein contained and as an absolute and unconditional gift [or consideration of $1], does hereby give, grant, bargain, sell and convey unto APPENDIX D
the Grantee, a ______[insert type of conveyance] in perpetuity over the Protected Property of the nature and character and to the extent hereinafter set forth.
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The following provisions should be incorporated in their entirety. Any deviation must be both substantially similar and approved by U.S. Fish and Wildlife USFWS, in consultation with its Solicitor, prior to execution and recording.
PURPOSE
It is the primary purpose of this ______[insert type of conveyance] to assure that the Protected Property will be retained forever in its ______[insert type of habitat] as suitable for the______[insert ESA listed species], irrespective of the federal listing status of the species; [optional, depending on Grantor interest: and also to the extent consistent with the primary purpose, to protect any other rare plants, animals, or plant communities on the Protected Property, and to ensure the Protected Property remains permanently in a natural, scenic and _____ [describe habitat , e.g., forested, etc.] condition; and to prevent any use of the Protected Property that will significantly impair or interfere with the conservation values or interests of the Protected Property described above. Grantor intends that this ______[insert type of conveyance] will confine the use of the Protected Property to such activities as are consistent with the purpose of this ______[insert type of conveyance].
THE USFWS AS THIRD-PARTY BENEFICIARY: ENFORCEMENT AND REMEDIES
1. The parties hereto agree that, because of the USFWS’s duties and powers arising under the ESA and consistent with ______’s commitments to its HCP and ITP, the USFWS has a clear and substantive interest in the preservation and enforcement of this______[insert type of conveyance]. Therefore, the parties grant to the USFWS, its agents, successors and assigns, the rights and standing to be noticed, to enter the Protected Property, to approve or disapprove requests, and to enforce this ______[insert type of conveyance] as described in this section and according to its terms.
2. Grantor or Grantee, as appropriate, shall notify the USFWS in writing of the names and addresses of any party to whom the Protected Property, or any part thereof, is to be granted, conveyed or otherwise transferred, said notice to be provided at or prior to the time said transfer is consummated.
3. This ______[insert type of conveyance] does not convey a general right of access to the public, except that the USFWS, its agents, contractors, and assigns, may enter onto the Protected Property at any time upon 24 hours notice to Grantor or Grantee, as appropriate, for the purpose of conducting inspections to determine compliance with the terms contained herein, for the purpose of assessing the ______[ESA listed species] population status and vegetative habitat suitability, in accordance with the terms of the ITP, HCP and the ESA implementing regulations at 50 C.F.R. Parts 13, Subparts C and D, or for the purpose of conducting ______[specific management or monitoring activities] in accordance with the terms of the HCP. This right of entry does not include a right to enter any buildings on the property that serve as residences or places of business. APPENDIX D
4. In addition to any other rights and remedies available to the USFWS at law or in equity, the USFWS shall have the right, but not the obligation to enforce this ______[insert type of conveyance] and is entitled to exercise the same remedies available to Grantee, identified in paragraph ______[paragraph that lists Grantee enforcement rights]. The USFWS may do so upon the written request of Grantee or if Grantee fails to enforce the______[insert type of conveyance]. Prior to taking any enforcement action, the USFWS shall notify Grantee in writing of its intention and shall afford Grantee a reasonable opportunity to negotiate a remedial action and settlement with Grantor or commence its own enforcement action. No failure on the part of the USFWS to enforce any term, condition, or provision hereof shall discharge or invalidate such term, condition, or provision to affect its right or that of Grantee or Grantor to enforce the same.
OTHER MANDATORY PROVISIONS
Assignment. The parties hereto recognize and agree that the benefits of this ______[insert type of conveyance] are in gross and assignable, and the Grantee hereby covenants and agrees that in the event it transfers or assigns ______[property interest], it shall obtain written concurrence of the USFWS, and the organization receiving the interest will be a qualified organization as that term is defined in Section 170(h)(3) of the IRC (or any successor section) and the regulations promulgated thereunder, which is organized and operated primarily for one of the conservation purposes specified in Section 170(h)(4)(A) of the IRC, and Grantee further covenants and agrees that the terms of the transfer or assignment will be such that the transferee or assignee will be required to continue to carry out in perpetuity the conservation purposes which the contribution was originally intended to advance.
Subsequent Transfers. The Grantor agrees that the terms, conditions, restrictions and purposes of this grant or reference thereto will be inserted by Grantor in any subsequent deed or other legal instrument by which the Grantor divests any retained, reserved or reversionary interest and by Grantee if Grantee subsequently transfers any fee simple title or possessory interest in the Protected Property; and Grantor and Grantee further agree to notify Grantee or Grantor, as appropriate, and the USFWS of any pending transfer at least thirty (30) days in advance.
Government Permits and Approvals. The conveyance of this ______[insert type of conveyance] by the Grantor to the Grantee does not replace, abrogate, or otherwise set aside any local, state or federal laws, requirements or restrictions applicable to the Protected Property and shall not relieve Grantor of the obligation and responsibilities to obtain any and all applicable federal, state, and local governmental permits and approvals, if necessary, to exercise Grantor's retained rights and uses of the Protected Property even if consistent with the conservation purposes of this______[insert type of conveyance].
Eminent Domain. Whenever all or part of the Protected Property is taken in exercise of eminent domain by public, corporate, or other authority so as to abrogate the restrictions imposed by this______[insert type of conveyance], the Grantor and the Grantee shall join in appropriate actions at the time of such taking to recover the full value of the taking and all incidental or direct damages resulting from the taking, which proceeds shall be divided______[insert method], and ______[discuss how proceeds will be spent]. All expenses incurred by the Grantor and the Grantee in such action shall be paid out of the recovered proceeds. APPENDIX D
Interpretation. This ______[insert type of conveyance] shall be interpreted and performed pursuant to the laws of the State in which it is recorded, the federal Endangered Species Act, and other applicable federal laws.
Severability. If any provision in this instrument is found to be ambiguous, an interpretation consistent with the purposes of this ______[insert type of conveyance] that would render the provision valid shall be favored over any interpretation that would render it invalid. If any provision of this ______[insert type of conveyance] or the application thereof to any person or circumstance is found to be invalid, the remainder of the provisions of this ______[insert type of conveyance] and the application of such provisions to persons or circumstances other than those as to which it is found to be invalid shall not be affected thereby.
Successors and Assigns. The term "Grantor" shall include the Grantor and the Grantor's successors and assigns and shall also mean the masculine, feminine, corporate, singular or plural form of the word as needed in the context of its use. The term "Grantee" shall include ______and its successors and assigns.
Notices. Any notices, consents, approvals or other communications required in this ______[insert type of conveyance] shall be sent by registered or certified mail to the appropriate party or its successor in interest at the following address or such address as may be hereafter specified by notice in writing:
Grantor: Grantee: USFWS: [Others:]
Counterparts. The parties may execute this instrument in two or more counterparts, which shall, in the aggregate, be signed by both parties; each counterpart shall be deemed an original instrument as against any party who has signed it. In the event of any disparity between the counterparts produced, the recorded counterpart shall be controlling.
Captions. The captions herein have been inserted solely for convenience of reference and are not a part of this ______[insert type of conveyance] and shall have no effect upon construction or interpretation.
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Additionally, each conveyance must include provisions to address the following topics. The contents of these provisions must be negotiated by the parties. They may therefore differ considerably depending on the property, values to be conserved, and the intensity of management and monitoring required. There is no prescribed template for the following provisions. But the USFWS has recommended language it can provide the parties if desired: APPENDIX D
Monitoring and Management; Endowment [if applicable]; Cost and Liabilities; Taxes; Title; Standing; Extinguishment; Merger; Parties subject to the conveyance; and, Grantee Rights of Entry and Enforcement [which must include, at a minimum, the right to: 1) prevent any activity on or use of the Protected Property that is inconsistent with the purpose of the conveyance and to require the restoration of such areas or features of the Protected Property that may be damaged by any inconsistent activity or use; 2) bring an action at law or equity in a court of competent jurisdiction to enforce the terms of the conveyance; 3) require the restoration of the Protected Property to its previous condition; 4) enjoin non-compliance by ex parte temporary or permanent injunction in a court of competent jurisdiction; and/or, 5) recover any damages arising from such noncompliance.]
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Also, each conveyance must include the following text regarding force majeure. This text may be revised only to reflect any binding contingencies for adaptive management and changed circumstances, if any, memorialized in the HCP or ITP. But any changes must first be reviewed and approved by the USFWS in consultation with its Solicitor.
Neither absence of [ESA listed species] from the Protected Property nor a loss of or significant injury to conservation values for the ______[ESA listed species] due to circumstances including, but without limitation, fire, flood, storm, disease, or seismic events, shall be construed to render the purpose of this ______[insert type of conveyance] impossible to accomplish and shall not terminate or extinguish this ______[insert type of conveyance] in whole or in part. In the case of loss of or significant injury to any of the conservation values for the [ESA-listed species] due to fire, flood, storm, disease, seismic events or similar circumstances, the Grantor or Grantee may, but shall not be required to, seek to undertake measures in consultation with the USFWS to restore such conservation values, subject to the terms of the HCP/ITP. APPENDIX D
INDIANA BAT (SUMMER/SWARMING HABITAT) USE RESTRICTIONS AND RESERVED RIGHTS1
RESTRICTIONS
General Description Legal Description to be included in Conveyance
No Industrial Use No industrial activities, including but not limited to the construction or placement of buildings or parking areas, shall occur on the Protected Property
No New Residential Use No new residential structures or appurtenances, including but not limited to the construction or placement of new homes, mobile homes or storage sheds, shall be constructed on the Protected Property.
No Commercial Use No commercial activities shall occur on the Protected Property, except for the low impact recreational uses explicitly identified under Reserved Rights.
No Agricultural Use No new agricultural activities that were not previously documented as part of the baseline conditions shall occur on the Protected Property, including the use of the Protected Property for cropland, waste lagoons, detention or collection ponds, or pastureland.
No Vegetative Clearing No forestry or timbering activities shall occur on the Protected Property, except that 1) Grantee maintains the right to conduct silvicultural modifications with the intent to improve listed species habitat within the Protected Property through reforestation, afforestation or silvicultural management to improve the health of the Indiana bat habitat; and 2) limited vegetative clearing may occur as described under Reserved Rights only.
Development Rights Extinguished No development rights which have been encumbered or extinguished by this ______[insert type of conveyance] shall be transferred pursuant to a transferable development rights scheme or cluster development arrangement or otherwise.
No Subdivision The Protected Property may not be divided or subdivided. Further, the Protected Property may not be divided, partitioned, nor conveyed except in its current configuration as an entity, without USFWS and Grantee’s written approval. All terms and conditions of this easement will apply to each subdivided portion.
1USFWS acknowledges that there may be limited or extenuating circumstances that may warrant a deviation from this required boilerplate. The nature of the restrictions and consideration of allowable uses will necessarily depend on the land to be protected. Grantors or Grantees who wish to alter the language of these provisions bear the burden of demonstrating to the satisfaction of _____ and USFWS that doing so would not diminish or interfere with the conservation of Indiana bats and their habitat. Any such change(s) must be approved by USFWS in writing, after consulting with agency counsel, and prior to execution of the conveyancing document. APPENDIX D DRAFT ENVIRONMENTAL ASSESSMENT FOR PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC
Appendix E – Reference Tables
December 2019 U.S. Fish and Wildlife Service DRAFT ENVIRONMENTAL ASSESSMENT FOR APPENDIX E. REFERENCE TABLES PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC
Table E-1. Indiana Bat Fatalities Documented at Wind Energy Facilities in the U.S.1 # of Project Name State/Province County Date Found WNS Status2 Reference Fatalities Fowler Ridge Indiana3 Benton 9/11/2009 Pre Good et al. 2011 1 Fowler Ridge Indiana3 Benton 9/18/2010 Pre Good et al. 2011 1 Anonymous Indiana3 Anonymous 8/23/2015 Post Pruitt and Reed 2018 1 Anonymous Indiana3 Anonymous 7/1/2017 Post Pruitt and Reed 2018 1 Anonymous Indiana3 Anonymous 5/1/2018 Post Pruitt and Reed 2018 1 Anonymous Indiana3 Anonymous 9/17/2018 Post Pruitt and Reed 2018 1 North Allegheny Pennsylvania Blair, Cambria 9/26/2011 Transition USFWS 2011 1 Laurel Mountain West Virginia Barbour, Randolph 7/8/2012 Post USFWS 2012b 1 Blue Creek Ohio3 Van Wert 10/3/2012 Post USFWS 2012a, Pruitt and Reed 2018 1 Anonymous Ohio3 Anonymous 10/9/2013 Post Pruitt and Reed 2018 1 Anonymous Ohio3 Paulding 4/14/2014 Post Pruitt and Reed 2018 1 Anonymous Illinois Anonymous 9/23/2016 Unknown Pruitt and Reed 2018 1 Anonymous Iowa Anonymous 7/13/2016 Unknown Pruitt and Reed 2018 1 Total 13 1. Through April 2019. 2. WNS status signifies the extent of WNS contamination in the region’s hibernacula. The WNS status for northeastern projects was provided by R. Niver, USFWS, pers. comm; the WNS status for all other was projects sourced from the WNS map (Heffernan 2016). 3. In Midwest MRU for Indiana bat.
December 2019 U.S. Fish and Wildlife Service 1 DRAFT ENVIRONMENTAL ASSESSMENT FOR APPENDIX E. REFERENCE TABLES PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC
Table E-2. Northern Long-Eared Bat Fatalities Documented at Wind Energy Facilities in the U.S. and Canada1 Date or Time # of Project Name State/Province County WNS Status2 Reference Period Found Fatalities Mountaineer West Virginia Tucker 8/18 – 9/8, 20033 Pre Kerns and Kerlinger 2004 6 Meyersdale Pennsylvania Somerset 9/11 - 9/13, 2004 Pre Arnett et al. 2005 2 Kingsbridge I Ontario Huron 10/5/2006 Pre Stantec 2007 1 5/25 – 6/12, 2007 3 Erie Shores Ontario Norfolk Pre James 2008 8/28 – 8/30, 2007 3 7/13 – 8/24, 20074 4 Steel Winds New York Erie Pre Grehan 2008 9/4 – 9/24, 20074 2 Noble Ellenburg New York Clinton 8/2008 Pre Jain et al. 2009 1 8/4/2008 1 Ripley Ontario Bruce Pre Jacques Whitford 2009 9/5/2008 1 Mount Storm West Virginia Grant 8/26/2008 Pre Young et al. 2009 1 Fowler Ridge Indiana* Benton 8/25/2009 Pre Good et al. 2011 1 Anonymous Missouri* Anonymous 9/20095 Pre M. Turner, USFWS, pers. comm. 1 Pennsylvania Game Commission (PGC) Pennsylvania n/a 9/2009 Pre J. Taucher, PGC, pers. comm. 1 Site 2-146 6/11/2010 Jain et al. 2011 1 Noble Wethersfield New York Wyoming 7/17/2011 Post Kerlinger et al. 2011 1 8/6 – 9/3, 2011 Kerlinger et al. 2011 4 Cohocton/Dutch Hills New York Stueben 6/22/2010 Post Stantec 2011 1 Bear Mountain British Columbia - 8 and 9, 2010 Pre Hemmera 2011 5 Criterion Maryland Garrett 7/22/2011 Pre Young et al. 2013 1 PGC unknown site4 Pennsylvania n/a 7/2012 Post J. Taucher, PGC, pers. comm. 1 Anonymous Illinois* Anonymous 8/10/2013 Transition M. Turner, USFWS, pers. comm. 1 Anonymous Illinois* Anonymous 8/22/2013 Transition M. Turner, USFWS, pers. comm. 1
December 2019 U.S. Fish and Wildlife Service 2 DRAFT ENVIRONMENTAL ASSESSMENT FOR APPENDIX E. REFERENCE TABLES PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC
Date or Time # of Project Name State/Province County WNS Status2 Reference Period Found Fatalities Anonymous Illinois* Anonymous 9/25/2013 Transition M. Turner, USFWS, pers. comm. 1 Anonymous Michigan* Anonymous 7/10/2014 Transition M. Turner, USFWS, pers. comm. 1 Anonymous Illinois* Anonymous 5/2014 Transition M. Seymour, USFWS, pers. comm. 1 Anonymous Illinois* Anonymous 9/2/2014 Transition M. Seymour, USFWS, pers. comm. 1 Total 48 1. Through April 2019. 2. WNS status signifies the extent of WNS contamination in the region’s hibernacula. The WNS status for northeastern projects was provided by R. Niver, USFWS, pers. comm; the WNS status for all other was projects sourced from the WNS map (Heffernan 2016). 3. Study reported that these northern long-eared bat fatalities were first recorded on August 18, 2003, and last recorded on September 8, 2003, but did not provide dates for every fatality event of the species. 4. New York State Department of Environmental Conservation identified the bat species for this survey and provided the information via pers. comm. with Western EcoSystems Technology, Inc.; species were not included in the original study report. 5. Northern long-eared bat fatality occurred between May 16 – November 15, 2009. 6. Sites participating in the PGC Wind Energy Voluntary Cooperation Agreement are not identified by name. *State in former Service Region 3.
December 2019 U.S. Fish and Wildlife Service 3 DRAFT ENVIRONMENTAL ASSESSMENT FOR APPENDIX E. REFERENCE TABLES PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC
Table E-3. Species Composition of Bat Carcasses Found and Identified at a Sampling of Wind Projects in the Midwest that Provided Publicly Available Post-Construction Monitoring Reports and Did Not Utilize Facility-Wide Cut-In Speeds. Bat carcasses Migratory Tree- Project State Cave- Hibernating2 Reference identified Roosting1 Buffalo Ridge, MN 163 93% 7% Johnson et al. 2003 Phases I–III Buffalo Ridge, Lake MN 151 93% 7% Johnson et al. 2004 Benton I & II Blue Sky Green WI 235 50% 50% Gruver et al. 2009 Field
Kewaunee County WI 72 90% 10% Howe et al. 2002
Cedar Ridge (2009) WI 89 68% 32% BHE Environmental 2011
Cedar Ridge (2010) WI 155 74% 26% BHE Environmental 2011
Crescent Ridge IL 20 100% 0% Kerlinger et al. 2007
Top of Iowa IA 76 64% 36% Jain 2005
Forward Energy Grodsky and Drake WI 108 78% 22% Center 2011
Fowler Ridge3 IN 809 95% 4% Good et al. 2011
Fowler Ridge3 IN 573 96% 4% Good et al. 2012
Blue Creek OH 850 87% 13% Project HCP Appendix A
Blue Creek4 OH 724 91% 8% Project HCP Appendix A
Total 4,025 Median = 90% Median = 10%
1. Hoary bat, eastern red bat, silver-haired bat, Seminole bat. 2. Myotis species, big brown bat, tri-colored bat; includes evening bat, although not a cave-hibernating bat. 3. A range of cut-in speeds (3.5 m/s to 6.5 m/s) were applied to a subset of facility turbines during the fall migration season in 2010 and 2011 as part of bat mortality causality studies at Fowler Ridge. 4. A cut-in speed of 4.5 m/s was implemented on half of the operational turbines during the fall migration season in 2013.
December 2019 U.S. Fish and Wildlife Service 4 DRAFT ENVIRONMENTAL ASSESSMENT FOR APPENDIX E. REFERENCE TABLES PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC
Table E-4. Bat Mortality Estimates for Wind Projects in the Midwest Operating Without Feathering Below Cut-in Speeds Facility- Wide, with Publicly Available Post-Construction Monitoring Reports
Bat Fatalities per Project State MW Study Period Reference MW per Study1
Buffalo Ridge, Phases I– Mar. 15–Nov. 15, 1996 MN 235.6 2.30 Johnson et al. 2003 III Mar. 15–Nov. 15, 1999
Buffalo Ridge, Lake Jun. 15–Sep. 15, 2001 MN 210.8 2.88 Johnson et al. 2004 Benton I & II Jun. 15–Sep. 15, 2002
Blue Sky Green Jul. 21–Oct. 31, 2008 WI 145.0 24.60 Gruver et al. 2009 Field Mar. 15–May 31, 2009
Kewaunee County WI 20.5 6.45 Jul. 1999–Jul. 2001 Howe et al. 2002
Sep.–Nov. 2005 50.5 (2009) BHE Environmental Cedar Ridge WI 67.6 Mar.–May 2005 39.8 (2010) 2011 Aug. 2005
Sep.–Nov. 2005 Crescent Ridge IL 54.5 1.71 Kerlinger et al. 2007 Aug. 2006
Apr. 15–Dec. 15, 2003 Top of Iowa IA 80.1 8.57 Jain 2005 Apr. 15–Dec. 15, 2004
Jul. 15–Nov. 15, 2008 Apr. 15–May 31, 2009 Forward Energy Center WI 129.0 17.50 Grodsky and Drake 2011 Jul. 15–Oct. 15, 2009 Apr. 15–May 31, 2010
December 2019 U.S. Fish and Wildlife Service 5 DRAFT ENVIRONMENTAL ASSESSMENT FOR APPENDIX E. REFERENCE TABLES PROPOSED HCP AND INCIDENTAL TAKE PERMIT BLUE CREEK WIND FARM, LLC
Bat Fatalities per Project State MW Study Period Reference MW per Study1
Apr. 13–May 15, 2010 29.79 (2010) Aug. 1–Oct. 15, 2010 Fowler Ridge IN 600.0 Good et al. 20122 34.10 (2011) Apr. 1–May 15, 2011 Jul. 15–Oct. 29, 2011. 15.51 (2012) Apr. 1-Nov 15, 2012 Blue Creek3 OH 304.0 Project HCP - Appendix A 11.76 (2013) Apr. 1-Nov 15, 2013
Average 18.67
1. Averaged across multiple survey seasons unless shown otherwise with years in parentheses. 2. Estimates of bat fatality rates at control plots were determined using an empirical estimator after 2010 estimates were adjusted for bats falling outside of plots. 3. Project fatality rates are the estimated annual bat fatality rate for each year using the Huso estimator (Huso et al. 2015). Additional monitoring was completed in 2015 and 2016; however, operations had implemented a 6.9 m/s cut-in speed, leading to lower bat morality rates as compared to other years and other projects without operational curtailment.
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Table E-5. Anthropogenic Sources of Avian Mortality Other than Wind Power Facilities Mortality Source Estimated Annual Mortality Source Cats 1.3 billion – 3.9 billion Loss et al. 2013 Building and Glass Collisions 365 million – 988 million Loss et al. 2014a Vehicle Collisions 88.7 million – 339.8 million Loss et al. 2014b Poison 72 million1 USFWS 2017b Electrical Line Collisions 7.7 million – 57.3 million Loss et al. 2014c Communication Tower Collisions 6.5 million1 Longcore et al. 2012 Electrocution 920,000 – 11.5 million Loss et al. 2014c Oil Pits 500,000 – 1 million Trail 2006 Land-based Wind Turbines 140,000 – 500,000 USFWS 2018c Solar Energy 37,800 – 138,600 Walston et al. 2016 All Sources 549.1 million – 5.1 billion2 USFWS 2017b 1. Only the mean is presented in the estimate 2. Overall estimate of all sources of anthropogenic mortality; not a sum of the preceding values from individual sources.
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