Old Bird, Inc.

605 W. State St.

Ithaca, NY 14850

(607) 272-1786

June 27, 2007

Stantec Consulting Ltd.

361 Southgate Dr.

Guelph, ON N1G 3M5:

To Stantec Consulting:

Please find below a comment on a gap in your Bird Report for the Environmental Impact Statement of the Wolfe Island Wind Power project. I have appended my credentials for making this comment.

The lack of any research toward understanding and mitigating the impact to nocturnal migrants (e.g., songbirds) stands out as a serious omission from the Bird Report (Appendix C5). This issue is minimized first by stating that the mortality to such species has been shown to be small, though no references or figures are cited. Second, a study by EchoTrack (2005) in which some radar targets showed avoidance behavior to turbines is presented (C5: 1.2.1, 4.3.1, 4.3.2).

Regarding the first case, at the time the Bird Report was published (April 2007) there were few avian mortality studies in eastern North America from which to draw any regional conclusions on avian mortality from modern wind turbines (> 100 m height). Two of these are the Mountaineer Wind Project in northern West Virginia and the Buffalo Mountain, Tennessee study. Both these are inland wind projects in the Appalachian Mountains, more than 1000 km to the south of Wolfe Island. Since the publication of the Stantec Bird Report, mortality data from a new wind project has become available. The Maple Ridge wind project (195 turbines) is only about 70 km southeast of Wolfe Island and a three-year mortality study began in summer 2006. This study is somewhat unique in that it included daily mortality checks at 10 turbines. The fall 2006 report (mapleridgewind.com/impact.htm) indicates a rate of 9.59 birds killed per turbine and 24.53 bats killed per turbine after scavenging and surveyor efficiency rates were incorporated. Based on the daily mortality survey data, the 195-turbine project is estimated to have killed about 2000 birds and 6000 bats in the fall migration period (June 17 – Nov 15). The annual total would be higher once mortality data from a spring season was integrated..

It is important to understand that the Maple Ridge wind project is at an inland site with no major geographic features that might concentrate night migrants. A radar study at Maple Ridge in fall 2004 found a mean nocturnal passage rate of 158 targets/km/hr with 8.0% of the targets below 125 m (turbine height). A similar radar study in fall 2006 at a proposed wind project in Cape Vincent, NY, just across the St. Lawrence River from Wolfe Island, found a mean nocturnal passage rate of 345 targets/km/hr with 7.7% below 125 m (stlawrencewind.com/supplementary.html - scroll down to nocturnal marine radar survey). The Cape Vincent radar study found more than twice the migration density below turbine height compared to that documented at Maple Ridge, 70 km to the southeast. Furthermore, the Cape Vincent, NY radar study included about a third of its survey area over the water of the St. Lawrence River, which likely had lower passage rate of small passerines flying below turbine height than the area over land to the south of the river. This suggests that the overland portion of the study area had even higher migration density.

While the EchoTrack study you cite does indicate that some birds avoid turbines, one must ultimately still realize and consider that avian mortality does still occur at wind projects. Wolfe Island, due to its proximity to major water bodies, has a high incidence of low cloud and foggy conditions, which will limit avian avoidance capability and which are will exacerbate bird mortality compared to inland sites without such weather conditions.

Without an actual radar study (or previous wind turbine mortality study) on Wolfe Island, one is left to theorize about possible wind turbine mortality from more circumstantial data. My formula considers the closest mortality study to Wolfe Island (Maple Ridge) and the closest radar study to Wolfe Island (St. Lawrence Wind radar study in Cape Vincent, NY). I also consider the fact that Wolfe Island is not an inland site with generic migration patterns. It very likely has complex low altitude migration concentration dynamics associated with the St. Lawrence River and Lake Ontario. From these factors, along with the prevalence of low cloud and foggy conditions on Wolfe Island, I draw the conclusion that bird and bat mortality per turbine could be much higher than that at Maple Ridge.

Simply stated, I think Wolfe Island has the potential to have the highest bird mortality per turbine (or Megawatt) yet documented at a wind project in North America. I strongly suggest that at least a one-year radar study be conducted on Wolfe Island prior to considering construction in order to verify whether abnormally high nocturnal rates of passage below turbine height might exist and to document any migration channeling dynamics on the island. Proceeding without such information, the Wolfe Island Wind Project runs the risk of stumbling into being a high publicity bird killer. With all the good intentions of using wind energy for providing green energy, the wind industry does not need the negative publicity from large avian impacts at inadequately researched wind projects.

Sincerely,

William R. Evans

Executive Director

Curriculum vitae

William Ross Evans

Ornithologist

(Specializing in the study of nocturnal bird migration)

General accomplishments: Over the past decade developed the technique of acoustic monitoring of avian night flight calls and have been a leading researcher in mitigating bird mortality at tall man-made structures. See publications listed below for reference and general overview on this subject.

Current positions:

Old Bird Inc.

Position: Executive Director

Description: A 501(c)3 nonprofit corporation dedicated to facilitating acoustic monitoring of avian night flight calls.This organization has two primary branches of activity.One is the development and distribution of information and tools for advancing the method and utility of monitoring night flight calls of migrating birds. The second is the establishment and maintenance of networks of acoustic monitoring stations for gathering and distributing night flight call data for environmental education and understanding.

Contact:

Communications Tower Working Group (CTWG)

Position: Principle Investigator

Description: A study peer-reviewed and coordinated by the US Fish and Wildlife Service chaired CTWG. The aim of the study is to determine the role of the flash rate of aviation hazard warning lighting on tall man-made structures in leading birds to congregate around such structures. 2002 – ongoing.

Contact: Albert Manville, USFWS (703) 358-1963.

Research Planning, Inc. (RPI)

Position: Principle Investigator (subcontracted)

Description: Responsible for avian datagap analysis in the Minerals Management Service (MMS) contract “Worldwide Synthesis and Analysis of Existing Information Regarding Environmental Effects of Alternative Energy Uses on the Outer Continental Shelf”. 2006-2007.

Contact: Jacqui Michel, RPI, 803-256-7322

New York State Energy Research Authority

Position: Principal Investigator (subcontracted)

Description: Analyze nocturnal bird migration characteristics and test acoustic strike indicator methodology at Maple Ridge wind project in Upstate New York.

Contact: Mark Watson, NYSERDA, 518-862-1090

Publications

Evans W.R., Akashi, Y., Altman, N.S., and Manville, A.M.II. 2007. Response of night-migrating birds in cloud to colored and flashing light. North American Birds 60(4):xxx (in press).

Evans, W.R. 2005. Monitoring avian night flight calls - the new century ahead. Passenger Pigeon 67:15-24.

Evans W.R. and M. O’Brien. 2002. Flight Calls of Migratory Birds - Eastern North American landbirds.Old Bird, Inc. ( [CD-Rom].

Larkin, R.P., Evans, W.R., and R. H. Diehl. 2002Nocturnal flight calls of Dickcissels and Doppler radar echoes over south Texas in spring.Journal of Field Ornithology73:2-8.

Evans W.R. 2000. Applications of avian night flight call monitoring for tower kill mitigation. Transcripts of Proceedings of the Workshop on Avian Mortality at Communication Towers, August 11, 1999, Cornell University, Ithaca, NY. (scroll down to paper).

Evans, W.R. and A.M. Manville, II (Eds.). 2000. Avian mortality at communications towers. Transcripts of Proceedings of the Workshop on Avian Mortality at Communication Towers, August 11, 1999, Cornell University, Ithaca, NY.

Evans, W.R. 2000. Applications of acoustic bird monitoring for the wind power industry. PNAWPPM-III. 2000. Proceedings of National Avian - Wind Power Planning Meeting III, San Diego, California, May 1998. Prepared for the Avian Subcommittee of the National Wind Coordinating Committee by LGL Ltd., King City, Ont. 202 p. (then scroll down to paper).

Evans, W.R. and K.V. Rosenberg. 2000. Acoustic monitoring of night-migrating birds: a progress report. In Bonney, Rick, David N. Pashley, Robert J. Cooper, and Larry Niles, eds. Strategies of Bird Conservation: The Partners in Flight Planning Process. Proceedings of the 3rd Partners in Flight Workshop; 1995 October 1-5; Cape May, NJ. Proceedings RMRS-P-16. Ogden, UT: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station.

Evans, W.R. and D.K. Mellinger 1999. Monitoring Grassland Birds in Nocturnal Migration. Studies in Avian Biology No. 19:219-229.

Evans, W.R. 1994. Nocturnal flight call of Bicknell’s Thrush. Wilson Bulletin 106:55-61.

Positions or contracts held:

Cornell Laboratory of Ornithology (CLO)

Position: Research Associate 1994-1998

Contact: Dr. Christopher Clark, Director of Bioacoustics Research Program (607) 254-2408

Nebraska Public Power District (NPPD)

Position: Principal Investigator

Description: Acoustic monitoring of night migrating birds at proposed wind farm, 1996-1997.

Contact: Jim Jenniges, NPPD environmental staff (308) 236-2293

United States Fish and Wildlife Service (USFWS)

Position: Principal Investigator

Description: Project using acoustic censusing of night migrating birds to determine the species composition and relative numbers of migrants crossing the Mexican border region of south Texas, 1999-2001.

Contact: Bill Howe, USFWS (505) 248-6875

US Bureau of Reclamation (BOR)

Position: Principal Investigator

Description: Project using acoustics in remote censusing of breeding Willow Flycatchers along the Colorado River. 1998-2000.

Contact: Barbara Raulston, BOR (702) 293-8788

Wisconsin Public Service Corporation (WPSC)

Position: Principal Investigator

Description: Monitoring the species composition, altitude characteristics, and numbers of night-migrating birds for assessing the potential impact of wind turbines in Northern Wisconsin. 1999-2001.

Contact: Shawn Puzen, WPSC environmental staff (920) 433-1094

New York State Tower Kill Survey

Position: Director

Description: A volunteer-operated survey that monitored bird mortality at communications towers in New York State in fall 1998-2000.

Workshop on Avian Mortality at Communications Towers

Position: Co-organizer

Description: The first ever conference on the issue of bird mortality at communications towers held in conjunction with the American Ornithologist’s Union meeting at Cornell University on August 11th, 1999. Co-organized by Albert Manville of FWS and co-sponsored by the FWS, American Bird Conservancy, and the Ornithological Council.

Contact: Albert Manville, USFWS (703) 358-1963

UNIsite tower construction project

Position: Ornithological Consultant

Description: Prepare avian section of Environmental Assessment regarding proposed installation of 20 communications towers along the I80 corridor in Nebraska. Five threatened or endangered bird species involved. 1999-2000.

Contact: Joseph Quandt, Attorney in law firm representing UNIsite (231) 947-7900

Clipper Windpower, LLC

Position: Principal Investigator

Description: Monitoring the species composition, altitude characteristics, and numbers of night-migrating birds for assessing the potential impact of wind turbines in western Maryland. 2003.

Contact: Kevin Rackstraw , Clipper Windpower LLC, (301) 263-0028.

Ecogen, LLC

Position: Principal Investigator

Description: Monitoring the species composition, altitude characteristics, and numbers of night-migrating birds for assessing the potential impact of wind turbines in west-central New York State. 2004-2005.

Contact: Tom Hagner, Ecogen LLC, (716) 675-0751.

Catamount Energy

Position: Principal Investigator

Description: Monitoring the species composition, altitude characteristics, and numbers of night-migrating birds for assessing the potential impact of wind turbines in Vermont and Pennsylvania 2004-2005

Contact: Bob Charlebois, Catamount Energy, (802) 772-6767

2006 Invited Presentations

NYSERDA Wind /Wildlife Technical Workshop

Position: Invited speaker

Contact: Mark Watson, NYSERDA, 518-862-1090

“Toward Wildlife-Friendly wind Power: A focus on the Great Lakes Basin

Position: Invited speaker

Contact: Alex Hoar, USFWS, 413-253-8631