Fill and Sign the Osap Affidavit Form

INTERIM GUIDELINES TO AVOID AND MINIMIZE WILDLIFE IMPACTS FROM WIND TURBINES Introduction Wind-generated electrical energy is renewable, produces no emissions, and is generally considered to be an environmentally friendly technology. Development of wind energy is strongly endorsed by the Secretary of the Interior, as expressed in the Secretary’s Renewable Energy on Public Lands Initiative (May 2002). However, wind energy facilities can adversely impact wildlife, especially birds (e.g., Orloff and Flannery 1992, Leddy et al. 1999, Woodward et al. 2001, Braun et al. 2002, Hunt 2002) and bats (Keeley et al. 2001, Johnson et al. 2002, Johnson et al. 2003). As more facilities with larger turbines are built, the cumulative effects of this rapidly growing industry may initiate or contribute to the decline of some wildlife populations (Manes et al. 2002, Johnson et al. 2002, Manville 2003). The potential harm to these populations from an additional source of mortality or adverse habitat impacts makes careful evaluation of proposed facilities essential. Due to local differences in wildlife concentration and movement patterns, habitats, area topography, facility design, and weather, each proposed development site is unique and requires detailed, individual evaluation. The following guidance was prepared by the U.S. Fish and Wildlife Service (Service). Like the Service’s voluntary guidance addressing the siting, construction, operation, and decommissioning of communication towers (http://migratorybirds.fws.gov/issues/towers/comtow.html) and the voluntary guidance developed in cooperation with the electric utility industry to minimize bird strikes and electrocutions (APLIC 1994, APLIC 1996), this guidance is intended to assist the wind energy industry in avoiding or minimizing impacts to wildlife and their habitats. This is accomplished through: (1) proper evaluation of potential Wind Resource Areas (WRAs), (2) proper location and design of turbines and associated structures within WRAs selected for development, and (3) pre- and post-construction research and monitoring to identify and/or assess impacts to wildlife. These guidelines are based on current science and will be updated as new information becomes available. They are voluntary, and interim in nature. They will be evaluated over a two-year period, and then modified as necessary based on their performance in the field, on comments from the public, and on the latest scientific and technical discoveries developed in coordination with industry, states, academic researchers, and other Federal agencies. After this period, the Service plans to develop a complete operations manual for evaluation, site selection, design, construction, operation, and monitoring of wind energy facilities in both terrestrial and aquatic environments. Data on wildlife use and mortality collected at one wind energy facility are not necessarily applicable to others; each site poses its own set of possibilities for negative effects on wildlife. In addition, the wind industry is rapidly expanding into habitats and regions that have not been well studied. The Service therefore suggests a precautionary approach to site selection and development, and will employ this approach in making recommendations and assessing impacts of wind energy developments. We encourage the wind energy industry to follow these guidelines and, in cooperation with the Service, to conduct scientific research to provide additional information on the impacts of wind energy development on wildlife. We further encourage the industry to look for opportunities to promote bird and other wildlife conservation when planning wind energy facilities (e.g., voluntary habitat acquisition or conservation easements). The Service is guided by the Fish and Wildlife Service Mitigation Policy (Federal Register 46 (15), January 1981) in evaluating modifications to or loss of habitat caused by development. This policy follows the sequence of steps recommended in the Council on Environmental Quality’s Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act (NEPA) in seeking to avoid, minimize, or compensate for negative impacts. Mitigation can involve (1) avoiding the impact of an activity by taking no action; (2) minimizing impacts by limiting the degree of activity; (3) rectifying an impact by repairing, rehabilitating, or restoring an affected environment; (4) reducing or eliminating an impact by conducting activities that preserve and maintain the resources; or (5) compensating for an impact by replacing or providing substitute resources or environments. Any mitigation recommended by the Service 1 for wind energy development would be voluntary on the part of the developer unless made a condition of a Federal license or permit. Mitigation does not apply to “take” of species under the Migratory Bird Treaty Act, Bald and Golden Eagle Protection Act, or Endangered Species Act. The goal of the Service under these laws is the elimination of loss of migratory birds and endangered and threatened species due to wind energy development. The Service will actively expand partnerships with regional, national, and international organizations, States, tribes, industry, and environmental groups to meet this goal. Projects with Federal involvement may require additional analysis under the National Environmental Policy Act (http://www.fws.gov/r9esnepa), Endangered Species Act (http://endangered.fws.gov), or National Wildlife Refuge System Administration Act (http://www.fws.gov/policyMakers/mandates/index.html#adminact). This includes projects on federallyowned lands (e.g., National Wildlife Refuges, National Forests), lands where a Federal permit is required for development (e.g., BLM-administered lands), or lands where Federal funds were used for purchase or improvement (some State Wildlife Management Areas). These guidelines are not intended nor shall they be construed to limit or preclude the Service from exercising its authority under any law, statute, or regulation, and to take enforcement action against any individual, company, or agency, or to relieve any individual, company, or agency of its obligations to comply with any applicable Federal, State, or local laws, statutes, or regulations. The guidelines contain a site evaluation process with checklists for pre-development evaluations of potential terrestrial wind energy development sites (Appendix 1). Use of this process allows comparison of one site with another with respect to the impacts that would occur to wildlife if the area were developed. The evaluation area for a potential development site should include the “footprint” encompassing all of the turbines and associated structures planned for that proposed facility, and the adjacent wildlife habitats which may be affected by the proximity of the structures, but excluding transmission lines extending outside the footprint. All potential development sites within a geographic area should be evaluated before a site is selected for development. Pre-development evaluations should be conducted by a team that includes Federal and/or State agency wildlife professionals with no vested interest (e.g., monetary or personal business gain) in the sites selected. Teams may also include academic and industry wildlife professionals as available. Any site evaluations conducted by teams that do not include Federal and/or State agency wildlife professionals will not be considered valid evaluations by the Service. The pre-development evaluation may also identify additional studies needed prior to and after development. Post-construction monitoring to identify any wildlife impacts is recommended at all developed sites. Pre- and post-development studies and monitoring may be conducted by any qualified wildlife biologist without regard to his/her affiliation or interest in the site. Additional information relevant to these guidelines is appended as follows: Appendix 2 – Definitions Related to Wind Energy Development and Evaluation Appendix 3 – Wildlife Laws Relevant to Wind Power Development Projects Appendix 4 - Research Needs on the Impacts of Wind Power Development on Wildlife Appendix 5 – Procedures for Endangered Species Evaluations and Consultations Appendix 6 – Guidelines for Considering Wind Turbine Siting on Easement Lands Administered as Part of the National Wildlife Refuge System in Region 6 (CO, KS, MT, NE, ND, SD, UT, WY) Appendix 7 – Known and Suspected Impacts of Wind Turbines on Wildlife Appendix 8 – Literature Cited Site Evaluation The site evaluation protocol presented in Appendix 1 was developed by a team of Federal, State, university, and wind energy industry biologists to rank potential terrestrial wind energy development sites by their potential impacts on wildlife. There are two steps to follow: 2 1. Identify and evaluate reference sites, preferably within the general geographic area of the proposed facility. Reference sites are high-quality wildlife areas where wind development would result in the maximum negative impact on wildlife (i.e., sites selected to have the highest possible rank using the protocol). Reference sites are used to determine the comparative risks of developing other potential sites. 2. Evaluate potential development sites to determine risk to wildlife and rank sites against each other using the highest-ranking reference site as a standard. Although high-ranking sites are generally less desirable for wind energy development, a high rank does not necessarily preclude development of a site, nor does a low rank automatically eliminate the need to conduct predevelopment assessments of wildlife resources or post-development assessments of impacts. Studies to Assess and Monitor Wildlife Impacts While ranking potential development sites, the site evaluation team referenced above may identify predevelopment studies that are needed to better assess potential negative impacts to wildlife. Ranking may also suggest the extent and duration of study required. Developers are encouraged to conduct any studies suggested by the team in coordination with Service and other agency wildlife biologists. Post-development mortality studies should be a part of any site development plan in order to determine if or to what extent mortality occurs. As with pre-development studies, ranking may suggest the extent and duration of study needed. Studies should be designed in coordination with Federal and other agency biologists. Site Development Recommendations The following recommendations apply to locating turbines and associated structures within WRAs selected for development of wind energy facilities: 1. Avoid placing turbines in documented locations of any species of wildlife, fish, or plant protected under the Federal Endangered Species Act. 2. Avoid locating turbines in known local bird migration pathways or in areas where birds are highly concentrated, unless mortality risk is low (e.g., birds present rarely enter the rotor-swept area). Examples of high concentration areas for birds are wetlands, State or Federal refuges, private duck clubs, staging areas, rookeries, leks, roosts, riparian areas along streams, and landfills. Avoid known daily movement flyways (e.g., between roosting and feeding areas) and areas with a high incidence of fog, mist, low cloud ceilings, and low visibility. 3. Avoid placing turbines near known bat hibernation, breeding, and maternity/nursery colonies, in migration corridors, or in flight paths between colonies and feeding areas. 4. Configure turbine locations to avoid areas or features of the landscape known to attract raptors (hawks, falcons, eagles, owls). For example, Golden Eagles, hawks, and falcons use cliff/rim edges extensively; setbacks from these edges may reduce mortality. Other examples include not locating turbines in a dip or pass in a ridge, or in or near prairie dog colonies. 5. Configure turbine arrays to avoid potential avian mortality where feasible. For example, group turbines rather than spreading them widely, and orient rows of turbines parallel to known bird movements, thereby decreasing the potential for bird strikes. Implement appropriate storm water management practices that do not create attractions for birds, and maintain contiguous habitat for area-sensitive species (e.g., Sage Grouse). 3 6. Avoid fragmenting large, contiguous tracts of wildlife habitat. Where practical, place turbines on lands already altered or cultivated, and away from areas of intact and healthy native habitats. If not practical, select fragmented or degraded habitats over relatively intact areas. 7. Avoid placing turbines in habitat known to be occupied by prairie grouse or other species that exhibit extreme avoidance of vertical features and/or structural habitat fragmentation. In known prairie grouse habitat, avoid placing turbines within 5 miles of known leks (communal pair formation grounds). 8. Minimize roads, fences, and other infrastructure. All infrastructure should be capable of withstanding periodic burning of vegetation, as natural fires or controlled burns are necessary for maintaining most prairie habitats. 9. Develop a habitat restoration plan for the proposed site that avoids or minimizes negative impacts on vulnerable wildlife while maintaining or enhancing habitat values for other species. For example, avoid attracting high densities of prey animals (rodents, rabbits, etc.) used by raptors. 10. Reduce availability of carrion by practicing responsible animal husbandry (removing carcasses, fencing out cattle, etc.) to avoid attracting Golden Eagles and other raptors. Turbine Design and Operation Recommendations 1. Use tubular supports with pointed tops rather than lattice supports to minimize bird perching and nesting opportunities. Avoid placing external ladders and platforms on tubular towers to minimize perching and nesting. Avoid use of guy wires for turbine or meteorological tower supports. All existing guy wires should be marked with recommended bird deterrent devices (Avian Power Line Interaction Committee 1994). 2. If taller turbines (top of the rotor-swept area is >199 feet above ground level) require lights for aviation safety, the minimum amount of pilot warning and obstruction avoidance lighting specified by the Federal Aviation Administration (FAA) should be used (FAA 2000). Unless otherwise requested by the FAA, only white strobe lights should be used at night, and these should be the minimum number, minimum intensity, and minimum number of flashes per minute (longest duration between flashes) allowable by the FAA. Solid red or pulsating red incandescent lights should not be used, as they appear to attract night-migrating birds at a much higher rate than white strobe lights. 3. Where the height of the rotor-swept area produces a high risk for wildlife, adjust tower height where feasible to reduce the risk of strikes. 4. Where feasible, place electric power lines underground or on the surface as insulated, shielded wire to avoid electrocution of birds. Use recommendations of the Avian Power Line Interaction Committee (1994, 1996) for any required above-ground lines, transformers, or conductors. 5. High seasonal concentrations of birds may cause problems in some areas. If, however, power generation is critical in these areas, an average of three years monitoring data (e.g., acoustic, radar, infrared, or observational) should be collected and used to determine peak use dates for specific sites. Where feasible, turbines should be shut down during periods when birds are highly concentrated at those sites. 6. When upgrading or retrofitting turbines, follow the above guidelines as closely as possible. If studies indicate high mortality at specific older turbines, retrofitting or relocating is highly recommended. 4 Appendix 1 PROTOCOL TO RANK POTENTIAL TERRESTRIAL WIND ENERGY DEVELOPMENT SITES BY IMPACTS ON WILDLIFE This protocol was developed by a team of Federal, State, university, and industry biologists to rank potential wind development sites in Montana by their potential for impacts on wildlife (USFWS 2002). It has been modified to apply nationwide. The protocol allows the user to evaluate potential development sites and rank them against a reference site. Objectives are to: (1) assist developers in deciding whether to proceed with development; (2) provide a procedure to determine pre-construction study needs to verify use of potential sites by wildlife; and (3) provide recommendations for monitoring potential sites postconstruction to identify, quantify, or verify actual impacts (or lack thereof). Although this protocol focuses on impacts to wildlife, potential impacts to fish, other aquatic life, and plants should be considered as well. Surveys for rare, threatened, or endangered plants known or suspected to occur in the geographic area should be conducted at all proposed terrestrial development sites having suitable habitat. This protocol is intended to provide a conceptual framework for initial steps in investigating a site. It is not intended to be all-inclusive relative to objectives, methods, and analysis nor to serve as the definitive reference or directive for any step in wind power related investigations. The Physical Attributes, Species Occurrence and Status, and Ecological Attractiveness groupings in this protocol should serve as a model framework; the terrain features, species, and conditions used in these groupings will be dictated by local conditions and should be developed by wildlife biologists familiar with the region in which this protocol is being used. Potential Impact Index (PII) The Potential Impact Index represents a “first cut” analysis of the suitability of a site proposed for development. It does so by estimating use of the site by selected wildlife species as an indicator of potential impact. Emphasis of the PII is on initial site evaluation and is intended to provide more objectivity than simple reconnaissance surveys. There are two steps to follow in ranking sites by their potential impact on wildlife: 1. Identify and evaluate reference sites within the general geographic area of Wind Resource Areas (WRA’s) being considered for development of a facility. Reference sites are areas where wind development would result in the maximum negative impact on wildlife, resulting in a high PII score. Reference sites are used to determine the comparative risks of developing other potential sites. 2. Evaluate potential development sites to determine risk to wildlife, and rank sites against each other using the highest-ranking reference site as a standard. While high-ranking sites are generally less desirable for wind development, a high rank does not necessarily preclude development of a site, not does a low rank automatically eliminate the need to conduct pre-development assessments of wildlife use and impact potential. The following assumptions are implicit in the PII process: 1. All WRA sites, regardless of turbine design, configuration, placement, or operation present some hazard and risk to wildlife from both an individual and population perspective. 2. Certain sites present less hazard and risk to wildlife than others. 5 3. No adequate and defensible information exists regarding the appropriateness of the proposed WRA site being evaluated relative to impacts to wildlife. 4. Evaluations will be conducted by qualified biologists without competitive interest in site selection, including those from State and Federal agencies who are familiar with local and regional wildlife. The PII is designed primarily to evaluate potential impacts on aerial wildlife from collision with turbines and infrastructure. The PII is derived from the results of three checklists (forms are attached). These checklists should be developed and applied as follows: A. The PHYSICAL ATTRIBUTE checklist considers topographic, meteorological, and site characteristics that may influence bird and bat occurrence and movements. B. The SPECIES OCCURRENCE AND STATUS checklist includes: Birds of Conservation Concern at the Bird Conservation Region level (http://migratorybirds.fws.gov/reports/reports.html); all federally-listed Endangered, Threatened, and Candidate Species (http://endangered.fws.gov); bird species of high recreational or other value (e.g., waterfowl, prairie grouse); State Endangered, Threatened, and Species of Management Concern; and any additional species of concern listed by State Natural Heritage Programs. C. The ECOLOGICAL ATTRACTIVENESS checklist evaluates the presence and influence of ecological magnets and other conditions that would draw birds or bats to the site or vicinity. Each checklist has boxes to be checked for a particular attribute or species found at an evaluation site. The number of boxes in each checklist will vary from region to region due to variations in the number of physical attributes and species of concern in that region. Keep in mind that all boxes in a checklist are very unlikely to be checked at a single evaluation site, because all species and ecological physical conditions potentially occurring in the region would not exist at one site. Each checklist should be assigned a divisor, which is developed by dividing the number of boxes in a checklist by the total number of boxes in all three checklists. This expands the spread of index values and more dramatically displays the magnitude of differences among sites. For example, if the PHYSICAL ATTRIBUTE checklist has 36 boxes and the total number of boxes in all three checklists is 144, divide 36 by 144 = 0.25, the divisor. You can change the number of boxes in any of the checklists to fit your geographic area, habitat type, or other selected region (e.g., a state or portion of a state). Remember to recalculate the divisor if you change the number of boxes. Boxes in a checklist are checked if the condition or species is known or strongly suspected to occur. Criteria for checklist conditions marked with an asterisk (*) are explained on the following page. Conditions that are self-explanatory are not included. Conditions are not weighted. Boxes are checked in the SPECIES OCCURRENCE AND STATUS checklist if presence of the species is unconfirmed but strongly suspected (i.e., WRA is within the range and habitat of the species). This permits more liberal assignment of potential impact, reduces the probability of missing impacts on specific species due to lack of empirical data, and focuses future study and monitoring effort. Totals for each checklist are simple column sums. The PII is calculated from the checklist totals. A completed example from Montana is provided at the end of this Appendix. Determining Checklist Scores Checklist scores are determined as follows: 1. Place a check in each box for which an attribute, species, or condition is present or strongly suspected. 6 2. After completing the three checklists for each site, add the total number of checks in a checklist for an ending sum (each box checked equals one). Determining PII Score The Potential Impact Index score is determined as follows: 1. Place the sums from each of the three checklists in the POTENTIAL IMPACT INDEX table sum boxes ( column) in the appropriate category. 2. Divide each checklist sum by the previously calculated divisor to adjust the sum for disproportionate numbers of conditions in each checklist, and place this adjusted sum in the /p boxes for each checklist. 3. Add the adjusted checklist sums ( /p column) to produce the PII score. Include any questions, statements, comments, or concerns regarding any checklist cell or category on the SITE SPECIFIC COMMENTS sheet. These comments are critical to determining pre-construction study needs. They will also help identify and refine questions and objectives to be addressed by follow-up study and monitoring. The nature of suspected Significant Ecological Events should be noted on the SITE SPECIFIC COMMENTS sheet. Ranking PII Scores PII of each site evaluated is assigned a ranking based on its proportional relationship to the reference site that has the maximum PII score, as shown in Figure 2 in the Montana example. Ranking categories (High, Low, etc.) in the example are arbitrarily set at intervals of 20 percent of maximum. Rankings are intended as a guide to developers. They are designed to serve as indicators of relative risk to wildlife and thus provide an estimator of the level of impact that may be expected should a site be developed. A high rank does not preclude development, nor does a low rank automatically eliminate the need to conduct pre-development assessments of impacts on wildlife. More intensive pre-construction studies may be needed for both scenarios if development of the site is pursued. Rankings may also suggest the extent of additional study needed. In the case of federally listed threatened, endangered, or candidate species of wildlife, fish, or plants, consultation with the Fish and Wildlife Service under the Endangered Species Act is required, and may preclude development of a site regardless of its PII score. See Appendix 5 for procedures for obtaining lists of these species that may be present, and for consulting with the Fish and Wildlife Service if species or their habitats are found. Determining Pre-construction Study Needs The goals of pre-construction studies are to estimate impacts of proposed wind power development on wildlife by addressing areas of concern identified during the PII process. Objectives, intensity, duration, and methods of pre-construction studies are likely to be site specific, but may be independent of ranking. Regardless of ranking, studies should be designed to address (1) verification of use of WRAs by all species recorded in the “SPECIES OCCURRENCE AND STATUS” checklist, (2) verification of natural conditions (e.g., under “Significant Ecological Events”, the magnitude, timing, and location of suspected bird/bat migration), or (3) questions noted in the SITE SPECIFIC COMMENTS sheet for that site. The SITE SPECIFIC COMMENTS sheet may also indicate conditions that need not be investigated. As a result, a site with a low rank may require radar surveillance (e.g., important songbird migration site) while a site with a high rank may require only a single season visual survey (e.g., site potentially contains autumn Whooping Crane habitat). The process should involve a feedback mechanism within an adaptive management strategy (Figure 1). Timely review of study results will determine if data are 7 POTENTIAL IMPACT INDEX SPECIES/CONDITIONS SCORE RANK Proceed with Process Abandon Site STUDY SCOPE (Objectives, Methods) Narrow Medium Wide Results Inadequate Adequate Proceed with Development New Spp./Conditions Found Expand Scope Abandon Site Develop Mitigation Recommendations Monitor Post-Construction Figure 1. A suggested decision tree for assessing potential development sites. Begin by developing a PII score. adequate, if conclusions are defensible (Anderson et al. 1999), and if additional investigational effort is required (e.g., if Black-footed Ferrets are found on Mountain Plover searches). Projects with Federal involvement may require additional analysis under the National Environmental Policy Act (http://www.fws.gov/r9esnepa), Endangered Species Act (http://endangered.fws.gov), or National Wildlife Refuge System Administration Act (http://www.fws.gov/policyMakers/mandates/index.html#adminact). Also, the mere existence of a pre-construction study, whether in progress or completed, does not imply Federal sanction for development of a site. 8 Post-construction Studies The Service recommends that all sites be monitored for impacts on wildlife after construction is completed. Some sites may be so obviously benign that little more than simple reconnaissance study may be needed and any impact will be revealed during post-construction monitoring. Otherwise, pre-construction studies should be designed to explicitly consider post-construction monitoring that permits statistically valid evaluation of actual impacts. Accordingly, studies should be conducted as much as possible within a Before-After-Control-Impact (BACI) study design (Green 1979). Such design requires investigation of at least two sites (Impact [proposed site] and Control) simultaneously, both pre-construction (Before) and post-construction (After). Because true “Control” sites are seldom available, other sites may be substituted, including reference sites used in developing the PII ranking. In the case of radar surveillance studies, sites within the proposed WRA boundaries may be acceptable (e.g., Harmata et al. 1998). Structuring preconstruction studies within a hypotheses-testing framework will help identify appropriate metrics, focus effort, and permit comparisons with post-construction conditions or other WRAs. Where feasible, post-construction studies should also be utilized to test measures that may eliminate or reduce impacts on wildlife. See Appendix 4, Research Needs on the Impacts of Wind Power Development on Wildlife. Metrics and Methods Metrics and methods are specific tools used to assess wildlife populations and their status (e.g., point counts, line transects, nest success studies, radar surveys, mortality rates, and risk). They can provide important information about birds, bats, and other wildlife at proposed development sites. Metrics and methods may be selected to collect seasonal, group, guild, or habitat specific information, based on data and comments in the SPECIES OCCURRENCE AND STATUS checklist and SITE SPECIFIC COMMENTS sheet. For example, a proposed WRA may be in a narrow north-south oriented valley of relatively monotypic habitat. These conditions suggest a heavy seasonal avian migration corridor but little avian breeding habitat. Accordingly, study emphasis should be on defining use and mortality of migratory birds during autumn or spring or both, with little effort directed at defining use and mortality of breeding birds. Conversely, a potential WRA on a flat plain in diverse habitat would indicate the exact opposite in study emphasis. While metrics represent specific measurements, concepts, and relationships, methods refer to observational or manipulative study techniques that may be used to verify the location of birds and other wildlife, estimate their numbers, and document their use and behavior (Anderson et al. 1999). Table 1 depicts some commonly used metrics and methods for wildlife studies. Table 1. Examples of metrics and methods associated with evaluating use and mortality of wildlife at proposed Wind Resource Areas in Montana. Data Metric Need Methods Use Individuals/Count Point Counts (birds) Profile Winter Raptor Surveys Lek Counts (grouse) Migration Counts Ungulate Surveys Spotlight Surveys 9 Species/Count Species/guild/group List Point Counts (birds) Raptor Nesting Surveys Raptor Migration Counts Winter Raptor Surveys Acoustic Surveillance (bats) Pellet Counts Bait Stations Track Boards Radar Migration Counts Raptors/watch Area Searches Various techniques for capture Use per unit of time (e.g., hour, season) Individuals/capture effort Productivity Events/height category (Altitude Profile) Events/distance category (Spatial Profile) Mortality Nests/area Raptor Nesting Surveys Nest Success Ungulate Surveys Radar Radar Dead/injured individuals/unit Transects Spot Searches Carcass Removal Study Observer Detection Efficiency Study Studies should also strive to generate information to mitigate impacts by properly locating, configuring, or operating turbines (Johnson et al. 2000). Every effort should be made to choose metrics and methods that allow comparisons of pre-construction studies with post-construction studies, other WRAs, and other regions. Interpreting Metrics It may be difficult to establish empirically exactly what constitutes high use (i.e., potentially high impact). When looking at the distribution and movements, and local, regional, or range-wide population estimates for particular species, the relative proportions of species, groups, or guilds of wildlife using proposed WRAs may indicate degrees of risk. If baseline population data are unknown, consult with a qualified biologist who can recommend a specific metric. It is likely that little or no evidence of mortality will be found during pre-construction study. If, however, post-construction mortality is found, and statistical evaluation is not possible, that mortality should be assessed in regard to the species status (e.g., ESA-listed species or Birds of Conservation Concern) or the effect of the loss of individuals of that species on a local, regional, or continental population. Determining Post-construction Monitoring Needs Post-construction monitoring is important to the Service, industry, and public because of the limited information available on impacts of wind turbines and WRAs on wildlife. Therefore, post-construction monitoring should be designed to detect major impacts. The intended time frame for post-construction monitoring is not expected to exceed three years, however. Major impacts may be considered as statistically significant decreases in use by species of concern, or limited to statistically significant increases in mortality rates of any wildlife. Monitoring effort may be intensive or cursory, depending on results of pre-construction use and mortality studies. Simple, infrequent mortality surveys on impact and 10 control plots may be all that is needed at WRAs where recorded pre-construction use by wildlife is low. Documented high use of a proposed WRA may require monitoring methods identical to those employed in pre-construction studies. Anderson et al. (1999) provide specific, detailed direction in post-construction study design and monitoring. Manville (2002) developed a monitoring protocol for use by the U.S. Forest Service at three National Forests in Arizona to monitor the impact of cellular telecommunications towers on migratory birds that could be modified for use at land-based wind turbines. 11 POTENTIAL IMPACT INDEX CHECKLIST FORMS AND INSTRUCTIONS 12 PHYSICAL ATTRIBUTE CHECKLIST Site Topography Mountain Aspect, if mountainous* Physical Attribute W E Side N S Top W E Foothill N S S Wind* Direction N E W Updrafts* Latitudinal (N Migratory* Corridor Potential S) Longitudinal (E W) Wide Approaches (>30 km)* Funnel Horizontal Effect Vertical 640 1000 20 mi) - Terrain characteristics of approaches to site from each migratory direction, i.e., a large plain, river corridor, long valley. The larger the area that migrant birds/bats are drawn from, the more may be at risk Funnel Effect - Is the site in or near an area where migrant birds/bats may be funneled (concentrated) into a smaller area, either altitudinally, laterally, or both? Site Size & Configuration – Size is estimated as if a minimum convex polygon (MCP) were drawn around peripheral turbines. Successive boxes are checked to convey relationship of larger size = increased impact to birds/bats, e.g., a 700 acre site will have 2 categories checked while a 1,200 acre site will have all 3 categories checked. Configuration of turbine rows is usually perpendicular to prevailing wind direction. Rows aligned perpendicular or oblique to route of migration intuitively presents more risk to birds than rows aligned parallel to movement. Buildings – Building are categorized by relative size and visitation frequency, i.e., structures that are visited daily are usually larger and present more impact than those that are not. If a “Daily Activity” building is required, all Building categories are checked. If a maintenance structure is required, Substation is also checked. Increased Activity - Will any type of human activity increase? Sites in urban-suburban or otherwise developed areas (oil, gas, mines) will have less impact on wildlife than those in remote or undeveloped areas. 14 Avian Species of Concern Checklist (Complete prior to SPECIES OCCURRENCE & STATUS Checklist) Site Birds (n = ) Occurrence B M/W B M/W B M/W Subtotals Total Avian Species of Concern Checklist ( species, max 15 = ) B M/W Column totals of this list are added to appropriate cells in the SPECIES OCCURRENCE & STATUS checklist. Consult Birds of Conservation Concern (http://migratorybirds.fws.gov/reports/reports.html) and Threatened/Endangered Species list (http://endangered.fws.gov), and list other species of high value or management concern such as migratory waterfowl and prairie grouse. Appropriate avian field guides and species accounts should be consulted for confirmation of species distribution and habitat associations. State Natural Heritage Programs may also provide species accounts that include additional information useful in completing checklists. In addition to species lists (rows), season of occurrence is also indicated (columns). “B” indicates breeding or summer occurrence and “M/W” indicates presence during migration or as wintering species. If occurrence within or in the vicinity of a proposed site is confirmed or suspected, an “X” is entered. 16 Bat Species Of Concern Checklist (Complete prior to SPECIES OCCURRENCE & STATUS Checklist) Site Bats (n = ) Occurrence B M/W B M/W B M/W B M/W Subtotals Total Bat Species Of Concern Checklist ( species, max = ). Column totals of this list are added to appropriate cells in the SPECIES OCCURRENCE & STATUS checklist. Appropriate bat field guides and references (Barbour and Davis 1969) should be consulted for confirmation of species distribution and habitat associations. State Natural Heritage Programs may also provide species accounts that include additional information useful in completing checklists. In addition to species lists (rows), season of occurrence is also indicated (columns). “B” indicates breeding or summer occurrence and “M/W” indicates presence during migration or as wintering species. If occurrence within or in the vicinity of a proposed site is confirmed or suspected, an “X” is entered. 17 SPECIES OCCURRENCE & STATUS CHECKLIST Site Species Occurrence B M/W Threatened & Endangered (includes wildlife, fish, and plants) Candidate* Special Concern* Birds (max =) Bats (max =) Subtotals Total Criteria on following page 18 B M/W B M/W B M/W SPECIES OCCURRENCE & STATUS Checklist ( categories, max = , (p = ). Checklist totals for each column in “Avian Species of Concern List” and “Bat Species of Concern List” are inserted in this checklist. Threatened & Endangered Species - Species on the Federal List of Endangered and Threatened Species (http://endangered.fws.gov). Candidate Species - Species being investigated for inclusion in the Federal List of Endangered and Threatened Species (http://endangered.fws.gov). Species of Special Concern - Species listed in Birds of Conservation Concern; by Natural Heritage Programs that are known or suspected to be rare, endemic, disjunct, threatened or endangered; and species of high value such as migratory or other game birds. Golden Eagles may be included in this checklist because of special protective status afforded under the Bald and Golden Eagle Protection Act (16 U.S.C. 668-668d). Other species (e.g., Sage Grouse) may be included because of recent concern over population declines range wide. Bats (other than bat Species of Special Concern) should be included due to generally unknown impacts of wind farms on individuals and populations. 19 ECOLOGICAL ATTRACTIVENESS CHECKLIST Site Ecological Attractor Local N Migration Route* S Continental* E W Lotic System Lentic System Wetlands Native Grassland Ecological Magnets* Forest Food Concentrated Energetic Foraging Vegetation/ Habitat Unique Diverse Significant Ecological Event* Site of Special Conservation Status* Total Criteria on following page 20 ECOLOGICAL ATTRACTIVENESS CRITERIA - categories, max = , (p = ). Migration Route - Indicates predominate direction of movement of seasonal migrations. Multiple categories may be checked. Local - Some avian populations move only altitudinally & direction may be East-West (Sage Grouse, owls, Bald Eagles). Continental - Some migratory corridors experience mass movements in only one season/direction annually (e.g., Bridger Mountains autumn eagle migration). Ecological Magnets - Special, unique, unusual, or super ordinary habitats or conditions within the vicinity of the site that may attract wildlife. Lotic systems include small perennial or seasonal creeks to major rivers. Lentic systems include stock ponds to lakes to marine environments. Multiple categories may be checked. Vegetation/Habitat - Unique or exceptionally diverse vegetation or habitat in the vicinity may indicate exceptional diversity and abundance of avian species or bats. Significant Ecological Event - Special, unique, unusual, or super ordinary events that occur or are suspected to occur in the vicinity of the site, e.g., up to one third of the Continental population of Trumpeter Swans visit Ennis Lake, < 2.5 miles from a proposed Wind Resource Area; the Continental migration of shorebirds passes over (many stop) at Benton Lake National Wildlife Refuge) and up to 2,000 Golden Eagles pass over the Bridger Mountains in autumn. If unknown but suspected a “?” is entered. Specifics regarding the cell are then addressed in the appropriate box of the SITE SPECIFIC COMMENTS sheet to focus follow-up investigation and assist in definition of study objectives. Site of Special Conservation Status - Any existing or proposed covenants, conservation easements, or other land development limitations intended to conserve, protect, or enhance wildlife or habitat. This criterion is weighted (2 entered if true) because of previous financial or other investment in ecological values. Specifics regarding the easement are then addressed in the appropriate box of the SITE SPECIFIC COMMENTS sheet to focus follow-up attention. 21 POTENTIAL IMPACT INDEX Site Checklist (p)1 /p /p /p /p Physical ( ) Species Occurrence & Status ( ) Ecological ( ) Totals 1 Proportion of total checklist categories. Determining PII Score A. Place the sums from each of the three checklists in the POTENTIAL IMPACT INDEX table sum boxes ( column) in the appropriate category. B. Divide each checklist sum by the previously calculated divisor to adjust the sum for disproportionate numbers of conditions in each checklist, and place this adjusted sum in the /p boxes for each checklist. C. Add the /p boxes for the three checklists to obtain a total score. 22 SITE SPECIFIC COMMENTS Site Checklist Physical Species Occurrence Ecological 23 EXAMPLE SITE ASSESSMENT AND CALCULATION OF POTENTIAL IMPACT INDEX (PII) FROM MONTANA POTENTIAL IMPACT INDEX CHECKLISTS Calculating Divisors A. Each checklist should be assigned a divisor, which is developed by dividing the number of boxes in a checklist by the total number of boxes in all three checklists. In this example, the total number of boxes in all three checklists is 143. B. Physical Attribute checklist: 36 boxes 143 = 0.25; Species Occurrence and Status checklist: 91 boxes 143 = 0.63; Ecological Attractiveness checklist: 16 boxes 143 = 0.11. Determining Checklist Scores A. Place a check in each box for which an attribute, species, or condition is present or strongly suspected. B. After completing the three checklists for each site, add the total number of checks in a checklist for an ending sum (each box checked equals 1). 24 PHYSICAL ATTRIBUTE CHECKLIST Site Snowy Mtn.Range Physical Attribute Mountain Aspect W Topography X E Side N S Top W X E Foothill N S Valley X Pass Gap Ridge X Bluff Butte S Wind Direction N X E W Updrafts Latitudinal (N Migratory Corridor Potential Site Size (acres) & Configuration X S) Longitudinal (E X W) Wide Approaches (>30 km) Funnel Horizontal Effect Vertical X 640 1000