Sandra Riley
Town Clerk
Town of Cohocton
15 South Main Street
Cohocton, NY 14826
Re: Comment on Cohocton Wind DEIS June 23, 2006
Dear Ms. Riley:
I direct a nonprofit in Ithaca, NY that promotes the use of acoustic monitoring for studying nocturnal bird migration. I have previously been associated with the Cornell Laboratory of Ornithology and am considered an expert on bird migration in the region. I have consulted on many wind projects across eastern North America. I am an invited panelist for the upcoming NYSERDA wind/wildlife technical workshop in Albany in early August and I am an invited speaker at the upcoming USFWS conference on wind power in the Great Lakes Basin. In addition, I carried out a bird migration study for Ecogen LLC at their proposed wind facility in Prattsburgh, NY. I have no agenda against wind power and my study results from the Ecogen project suggest that it might be a relatively good site for wind power in NYS with regard to bird impacts.
Since I have been studying bird migration in central NY for 20 years, and had recently carried out a bird study in Prattsburgh, NY, I was curious to see what the findings of the Woodlot Alternatives were with respect to potential bird impacts of the Cohocton wind power project and offer my comments.
I read the Cohocton Wind DEIS several weeks ago in preparation to make my comments. Two important references in the DEIS (pp. 31-32) noted below that were used in forming the avian risk assessment were not available to me.
Woodlot Alternatives, Inc. 2005a. A Spring 2005 Radar, Visual, and Acoustic Survey of Bird and Bat Migration at the Proposed WindFarm Prattsburgh Project in Prattsburgh, NY. Prepared for WindFarm Prattsburgh, LLC.
Woodlot Alternatives, Inc. 2005b. A Fall 2004 Radar, Visual, and Acoustic Survey of Bird and Bat Migration at the Proposed WindFarm Prattsburgh Project in Prattsburgh, New York. Prepared for WindFarm Prattsburgh, LLC.
I wrote Cohocton Wind and asked for copies or direction for how I could obtain these documents (see attached letter). The letter was confirmed by Fed Ex to be delivered to Cohocton Wind on June 1. I did not receive a reply from them in this matter.
Woodlot Alternatives, the author of the avian risk assessment portion of the DEIS, is a consulting firm from Maine that has relatively little experience with bird migration in central New York State. They are also relatively new to radar study compared with a more established firm like ABR, Inc., who carried out the radar study for the Ecogen project. Woodlot has no published, peer-reviewed, scientific papers that would enable me to evaluate their methods. Therefore, I felt is was important to review the studies they carried out for Windfarm Prattsburgh. One of the key questions I had was how the ground clutter for the radar differed between that study site and the Cohocton study site, and how Woodlot addressed this inherent problem in comparing radar data.
Generally when one carries out an avian risk assessment for a wind project they gather information from previous bird studies in the region and inquire with local experts. This would be especially important for an out-of-region consulting firm like Woodlot. As mentioned, I carried out an acoustic study of avian night migration at the Ecogen wind project site near Prattsburgh. While the DEIS cites the radar study contracted by Ecogen, it does not mention my acoustic study. If Woodlot had considered this study in preparing the DEIS, they would have found out that Least Bittern, a species listed as threatened by the NYDEC, was documented in both spring and fall migration at the Ecogen project site. This almost certainly means that this species will be a migrant through the Cohocton Wind project. It is not mentioned in the DEIS.
More importantly, however, the DEIS does not include the important information on migration channeling discussed in the Ecogen acoustic study. It should be pointed out that I carried out the Ecogen acoustic study (fall 2004) before I knew about the existence of the Cohocton Wind project. My conclusions from that study were that much of the bird migration over central NYS is of a broad front nature. But on migration nights when cloud ceilings are low, the migration loses its broad front character and is channeled by the lake gorges and local montane terrain. The result is specific channels of abnormally high migration density. Such information is very pertinent for commercial wind project siting.
Evidence for this dynamic was found on three nights in the fall Ecogen study, but based on this and other similar studies I have carried out in the region, I predicted that much greater concentrations could be formed in the Naples valley and pass southward. I cite below several sentences stating this from my Ecogen acoustic study.
“The potential fall migration concentration dynamics arising from geography in the region surrounding the Ecogen project site are complex. They involve the southern half of Canandaigua Lake and the confluence of several adjacent north-south running valleys. From a theoretical basis, the highest concentration dynamics in this region would occur where many of these valleys meet in the vicinity of Naples, NY and immediately south of Naples. To some extent, the High Tor Wildlife Management Area probably plays a role in steering a significant portion of fall migration to the southwest of the Ecogen site, especially during low cloud ceiling nights.” P.85
“The most significant channeling in proximity [to the Ecogen project] is thought to be that formed by the confluence of several valleys near Naples and would flow just west of the Ecogen project area.” P.94
So, the question arises here why the Ecogen acoustic study was not included in the Cohocton DEIS. To me it is either a sign that Woodlot did not conduct an exhaustive survey of preexisting avian information for the region in preparing the DEIS or that they wanted to avoid the issue of potential significant channeling dynamics for the Cohocton Wind project area that are discussed in this Ecogen study.
Woodlot Alternatives is at fault for making broad assumptions based on only three nights of data. Their statement below is terribly irresponsible and totally without scientific grounds:
“This [their 3 nights of radar data] indicates that movement over the project areas is likely to occur as a broad front movement and that landscape features are not causing night-migrating birds to concentrate at any specific locations in the project areas.” p.9 of avian risk assessment
From my experience and my studies in the region, I would expect some of the highest densities of migration in inland NYS could pass in very close proximity, if not directly through, the proposed Cohocton Wind project. This is a project site where there are grounds for a potential bird kill problem. If there are going to be night migration bird studies at wind project sites in inland NYS, the Cohocton Wind project should be a very high priority study site.
The necessary study needs to address how the very dense fall migration events that occasionally occur in the Naples Valley during low cloud ceiling conditions behave in the vicinity of the proposed Cohocton Wind project area. Does the flight pass through the proposed wind project area or does it pass around the site? Several fall seasons of study would likely be necessary. Studies on clear sky nights are irrelevant for predicting avian risk at this project.
As stated, I have not been able to fully review the Cohocton Wind DEIS. To the extent I have been able to do so, I summarize my comments in the following points:
Key point #1: If information cited in the DEIS is not available to the public, it should not be used as a foundation for the avian risk assessment.
Key point #2: The DEIS is incomplete in not considering all pertinent migration studies in the region and regional experts have not been consulted.
Key point #3: The DEIS contains faulty information and lacks important information on a critical aspect for evaluating avian risk at this project site -- channeling of avian nocturnal migration.
Key point #4: Information exists that suggests there could be a significant bird kill problem with the Cohocton Wind project.
Key point #5: Additional studies are necessary to understand the risk to birds from the Cohocton Wind project.
Thank you for the opportunity to comment on this project. I am happy to clarify any of these concerns so please feel free to contact me directly with any questions.
Sincerely,
Bill Evans
Executive Director
Old Bird, Inc.
605 W. State St.
Ithaca, NY 14850
(607) 272-1786
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