(Washington, D.C., February 6, 2014) American Bird Conservancy (ABC), a leading U.S. bird conservation group, has identified numerous concerns in a letter to federal officials in connection with the proposed wind power development on the Chesapeake Bay—an important breeding and foraging habitat for birds such as Bald Eagles and waterfowl—that may feature around two dozen 600-foot tall wind turbines with blade sweeps longer than a football field.

The concerns were submitted by ABC to the U.S. Fish and Wildlife Service (FWS) as part of a formal planning process for the Great Bay Wind Energy Project that would be located in Somerset, Md., near the shores of the Chesapeake Bay. This phase of the planning process is designed to identify or scope out issues associated with the project.

It is estimated that there are at least 30 breeding pairs of Bald Eagles within 10 miles of the project, potentially placing many breeding birds in jeopardy. Preliminary assessments indicate that this project is expected to kill 20 eagles per year. While the FWS considers whether or not a permit will be issued authorizing the killing of our national symbol or any other protected bird, Dr. Michael Hutchins, National Coordinator of ABC's Bird Smart Wind Energy Campaign, says: “The developer and FWS should disclose and evaluate any proposed mitigation measures designed to minimize bird fatalities.”

“Any eagle fatality is a violation of the Bald and Golden Eagle Protection Act (BGEPA),” Hutchins continues. “ABC is particularly concerned about the potential long-term impact of this facility on the Bald Eagle population in the Chesapeake Bay. Consequently, we will be looking very closely at the scientific basis for the modeling of estimated eagle fatalities and population impacts presented in the draft Environmental Assessment.”

Hutchins cautions that, “While the population (of Bald Eagles) has expanded in recent years … this could change quickly with the right combination of negative anthropogenic factors, including wind energy development.”

The project's requisite Eagle Conservation Plans should, according to ABC, identify effective methods of mitigating those impacts, not just at the turbines themselves, but also at the associated transmission lines and other infrastructure, such as roads. This could include lighting, habitat management, seasonal or temporary shutdowns, radar monitoring, micro-siting of turbines, and other proven practices to help minimize bird (and bat) fatalities. Micro-siting is positioning the turbine array within the site to reduce bird strikes.

ABC supports the development of clean, renewable sources of energy such as wind power, but also believes that it must be done responsibly and with minimal impact on public trust resources, including native species of birds and bats, and particularly threatened, endangered, and protected species. ABC is a national leader on Bird Smart Wind Energy, which requires careful wind generation siting to prevent unintended impacts to native bird species, appropriate mitigation measures to reduce impacts, and reasonable compensation for those impacts that do occur.

ABC's comments also alert FWS to a recent peer-reviewed study, which showed that the risks posed to birds by the taller, monopole turbines likely to be used at this project pose a greater threat compared to smaller turbines used elsewhere.

ABC also asked that the project's Environmental Assessment include sections assessing the potential impact on any species protected by the Endangered Species Act and Migratory Bird Treaty Act. This would include extensive surveys, literature reviews, and other information intended to identify any risks to protected species. Any risk to such species would likely trigger the need for a more detailed Environmental Impact Statement as required under the National Environmental Policy Act.

ABC calls for the development of sufficient survey and range information on any listed threatened, endangered, or protected species, including an assessment of the species' movements through the area during migration and any major nesting, roosting, or foraging sites. This should be complemented by radar data or other data that could assist in risk assessment.

In assessing risk to wildlife, ABC says that it will be important to consider the project's proximity to sensitive wildlife habitats, such as wetlands and wildlife refuges. ABC has developed a map for wind developers to use as a siting tool. More specifically, this map identifies important bird conservation areas that should be avoided by wind energy developers. Most of Somerset County is colored orange on this map, indicating the need for extreme caution given the potential impact on birds, including the Saltmarsh Sparrow, which is listed as a Vulnerable species by the IUCN Red List.

They also call for a range of project action alternatives that will minimize impact on birds, bats, and other wildlife and their habitats, including, but not limited to, the number and size of turbines, as well as a reasonable range of siting and array alternatives.

Finally, ABC asks for an effective system of post-construction monitoring of bird (and bat) fatalities to be put in place as a condition of approval. Such evaluations should be conducted by a credible independent contractor with relevant expertise and not by the developer themselves, as this would be a conflict of interest.