Re: Application of Atlantic Wind LLC

For a Certificate of Environmental Compatibility for Construction of the North Ridge Wind Energy Project in the Towns of Parishville and Hopkinton, St. Lawrence Co. NY.

To whom this may concern:

I have looked over the bat and avian surveys planned for the DRAFT NORTH RIDGE WIND PROJECT. From my expert viewpoint, these planned surveys are severely flawed and for many reasons and could never produce a truthful or conclusive assessment for the species that will impacted by these turbines.

I have been an independent wildlife researcher for nearly 50 years with field experience that few can match. I am an expert on raptors and have extensively analyzed wind industry related research from as far back as the mid 1980’s. I also have a BS degree in Wildlife Biology from UC Berkeley.

Below I will comment on the Stantec submission (quoted in dark blue) that illustrate this poorly planned research:

1.0 Introduction

“This work plan outlines the scope of work for 2016 spring raptor migration surveys and breeding bird surveys. The survey effort is based on the New York State Department of Environmental Conservation (DEC) Guidelines for Conducting Bird and Bat Studies at Commercial Wind Energy Projects (DEC Guidelines), dated April 2016, and a teleconference held on May 9, 2016, with DEC.”

In my expert opinion, these guidelines may be based upon New York State Department of Environmental Conservation (DEC) Guidelines for Conducting Bird and Bat Studies at Commercial Wind Energy Projects, but they deify logic and are not based upon sound scientific research. These Stantec surveys are supposed to identify bird, bat and raptor usage in and around the North Ridge Wind Energy project, yet these surveys are designed to miss much of this species usage by breeding and migratory species. Stantec gives no reasoning for choosing the flawed and inadequate methodology planned for these studies.

2.0 Spring Raptor Migration Surveys

“Spring raptor migration surveys will be conducted during the months of March, April, and May 2016. Surveys will generally be conducted weekly for a total of 11 survey days over the spring migration period. As per DEC Guidelines, surveys will be conducted from 1 prominent location with a good view of the Project area throughout the survey period (Figure 1).

Surveys will take place from 8:00 am to approximately 2 hours before sunset. Surveys will target days with optimal migration weather (southerly, moderate winds) and days with good visibility. Data will be collected on standard raptor datasheets and flight paths will be drawn on Project area maps. Data collected will include species identification, number of individuals, sex and age class (if possible), flight pattern and location, flight behavior, flight height, flight time inside the Project area, time of observation, and weather conditions. Other birds, including flocks of birds, will be recorded as incidental observations to the raptor survey.”

No observations from the field pertaining bat or avian species should be considered incidental or considered insignificant. After all turbines are known to kill virtually every bird or bat species that must share habitat and air space with wind turbines.

West of this planned project at the Derby Hill Bird Observatory in Oswego County, NY, on average 40,000 raptors are counted each spring as they migrate northwards, making this site one of the best spring sites in the country. Non-raptor observations are far greater and these can number 40,000-50,000 in a single day.

These non-raptor numbers are very significant and complete bird and raptor counts during seasons of highest usage should be reported from this site.

It is very important to note that even though Derby Hill has thousands of birds and raptors migrating through daily in the spring, it is a completely different story in the fall. At this time of year most of these birds and raptors have chosen other migration routes as they head south.

Some of these primary fall migration routes are inland. One of these New York fall migration routes passes through the well-known Franklin Mt. Hawkwatch location. It is located in Oneonta, NY. This popular fall migration lookout for raptors, sits directly south of Parishville, New York. Many of the raptors traveling through this site have very likely migrated through the Parishville region catching updrafts off the mountains as they make their way south.

Favorable winds for turbines are often favorable winds for all avian migrations. Mountains create obstacles for migrants, and good winds concentrate birds along these pathways. Lower elevations also hold more food sources for migrants in the fall. In looking over the maps below it is very likely that the site chosen for the North Ridge Wind Energy Project, sits in or very close to a major fall stopover and migration corridor for raptors.

This migration corridor in and around the proposed North Ridge wind farm, likely applies to many bird species including nighttime migrants. This should be carefully analyzed with scientific research.

JW