The Humane Society of the United States comments on Virginia wind farm application

(September 5, 2003) - The Humane Society of the United States (HSUS) called for an environmental impact statement on a wind farm proposed for waters off the coast of Smith Island, Virginia. The HSUS believes that an environmental impact statement should be required of this project as a result of the controversial nature of the project and its potential for causing adverse impacts to species listed under the Endangered Species Act.

The proposed location of this project is important for a number of key wildlife species. The Smith Island site is adjacent to the Nature Conservancy's Virginia Coastal Reserve--an area valued by naturalists and well known by state and federal officials for its importance as a flyway for migratory birds and seasonal home to literally millions of wintering waterfowl. It is in the migratory path of monarch butterflies migrating south in the fall. It is also heavily used by marine mammals and is potentially important for endangered turtles and key fish species.

The operation of turbines may place bird species at risk in a number of different ways, all of which need to be assessed. Small passerines, flying with limited caloric budgets, may be blown offshore where they often attempt to rest on boats and structures. If a wind farm forces alteration of a migratory pathway, it may be devastating to marginalized individuals. Furthermore, attempting to land on a turbine tower to rest may prove fatal. Additionally, turbines may pose a risk to hundreds or thousands of seasonal resident or migrant water fowl which may rest on the water surface and need to take off near or under turbine blades. Fragmentation of resting or foraging areas by turbine fields, may force seasonal residents and migrants to utilize sub-optimal habitat, which may compromise members of sensitive species.

It is critical that the applicant address concerns raised by lighting that will be required on turbines. Certain types of lighting used to warn aircraft of towers have been shown to be a hazard to night migrating birds, and adverse weather can lower the altitude of migrating songbirds, placing them at risk as they fly at the height of the turbines proposed for the Virginia site. Moreover, assessing the potential risk to birds resting on the water surface and forced to fly off the water and possibly up into turbine blades cannot be taken lightly. The survey efforts in terrestrial sites that have found bodies or birds and bats beneath turbines (indicating the level of mortality that may be occurring from an operational site) are not possible in a marine environment. A thorough assessment is needed to determine the potential adverse impacts of the proposed turbines on birds protected under the Migratory Bird Treaty Act.

Offshore energy projects have a range of documented impacts on the shoreline, the sea and seabed, and on economically important biological resources. Renewable energy projects must not -- and need not -- undermine protection of coastal habitats and living marine resources. A thorough evaluation of the site must be conducted by way of the EIS process in order to fully evaluate the range and abundance of protected species utilizing this area and to identify any necessary mitigation measures if the project is finally permitted. If the Corps wishes to seriously entertain this proposal, and others like it, it is critical that there be a rigorous evaluation of habitat use by protected species and there must be ample opportunities for public comment as well as review and evaluation by the affected states.

To view the comments in their entirety, please click here.