July 28, 2006
Mr. Jeff Keeler
New England Director
Community Energy Inc.
22 Stanton Court
Madison, CT 06443
Dear Mr. Keeler:
This letter is a follow-up to our July 12, 2006 meeting at our office, attended by you, myself and Maria Tur of this office, regarding the proposed Lempster Wind Project, Lempster, New Hampshire.
While the July 12, 2006 meeting was scheduled for a general discussion of Section 404 permit issues associated with the Lempster Wind Project, we did discuss a range of issues and it became apparent that it would be useful for the Fish and Wildlife Service to start summarizing in correspondence some of the issues we have discussed over the past 15 months, as well as new issues, including comments on studies, study protocols, and other information needs.
Starting with our first interagency meeting on April 8, 2005, we have generally discussed three broad categories of activities that pose a potential concern for fish and wildlife resources. These include the potential for bird and bat collisions with turbines, habitat fragmentation effects on wildlife and impacts to waters/wetlands. At the April 8, 2005 interagency meeting, we recommended that CEI collect three (3) years of radar data on spring and fall bird/bat migrations to document the spatial and temporal use of the airspace by these flying vertebrates. Three years of radar data should be sufficient to gather information on the spatial and temporal distribution of birds in the airspace, including the year-to-year variability in migration patterns at this site, and represent our normal request for these data at wind projects. We have consistently requested that this data be collected at our meetings and field visits and continue to make this request for radar information.
With respect to specific details of the radar study protocols, we recommend 45 days of data collection during the period April 15-June 5, and 60 days of data collection during the August 15-October 31 period. Our preference is for radar equipment that is designed for 24/7, constant operation in horizontal and vertical modes with automated electronic storage of raw radar data. However, a single X-band radar that can be used alternately in horizontal and vertical modes with raw radar data storage capability is acceptable. At least one, and preferably two verification techniques (such as acoustic detectors or infrared imagery) should be employed to ground truth biotargets. Siting of the radar should be on one of the ridgetops which would maximize coverage of the project area vertically and horizontally. In addition to weather data collected at the met towers, information on precipitation, fog, cloud cover, cloud ceiling height, and arrival/departure of frontal systems should be collected. Special care should be taken to ensure that the radar is capable of and does collect migrant stopover arrival/departure data. In the case of non-24/7 operation, the radar operation would need to start before nocturnal migration begins, and end after nocturnal migration ends in the morning. To the extent possible, the radar should be calibrated for targets of known size and distance from the radar location. Since the Lempster project area is a montane setting with considerable topographic variation and tall forest cover, it will be important to describe with some precision what the volume of airspace is that is being sampled as the radar beam sweeps 360° in horizontal and ±180° in vertical modes. If either or both beams can be adjusted to scan below the radar horizon from the ridgeline so as to “see” into adjacent valleys, this should be done to improve the sampling regime.
The Lempster site is largely undeveloped except for a residence, some open fields for pasture, former logging roads and Bean Mountain Road, an unimproved, non-maintained local road. The construction and maintenance of new access roads and turbine sites will result in eliciting some of the habitat fragmentation syndrome effects on wildlife and habitat at this site. Habitat fragmentation effects include, but are not limited to, direct loss of habitat, an increase in edge habitat, increased isolation of remaining habitat, a decrease in abundance and diversity of area-sensitive and/or tall structure-sensitive species, decreased size of remaining patches of suitable habitat, increased human disturbance, increased stress, interruption of travel patterns and activities, displacement, a decrease in habitat suitability for area-sensitive species and a concurrent increase in habitat suitability for generalist or structure non-sensitive species, increased potential for colonization by invasive species and behavioral effects. Field studies to identify vegetation communities, and use of the project area by birds, bats, mammals and herptiles are necessary to establish an adequate baseline for evaluation of potential fragmentation effects.
During our January 20, 2006 meeting, we discussed the results from the 2005 breeding bird study at the Lempster site. This initial effort included one survey in June and one in July, and was based on a sampling plan designed to place point counts near the turbine locations. This resulted in more sample sites in spruce-dominated forest than deciduous or mixed forest and the results showed this sample bias with a tendency for boreal forest species. We recommended that the breeding bird survey points or transects be more uniformly distributed to ensure that deciduous and mixed cover types are adequately sampled. We assume that the point count locations and/or transects have been expanded to address this sampling issue.
One additional issue with the breeding bird study design that may remain outstanding relates to use of the study results during post-construction monitoring. If CEI intends to use this study design during post-construction monitoring to quantitatively measure fragmentation effects on area-sensitive species, we have an issue to resolve. The current study design, subject to the above changes, is sufficient to describe presence/absence and provide a measure of relative abundance of breeding birds. A longer duration, more robust study design involving grid sampling and territory mapping would be required to provide reliable data to assess fragmentation effects in a quantitative fashion.
We have described the Lempster site as an interesting area from an ecological perspective because much of the area, including hills and ridges, is dominated by red spruce of various age classes instead of a northern hardwoods association. Balsam fir while present is a minority component of this boreal type system. The northern hardwoods forest type is present, but usually on the south- and west-facing slopes and at lower elevations. Several boreal forest species may be present in this system, including spruce grouse, Bicknell’s thrush, and the pine marten. Field surveys should be scoped for these species and others, e.g., plant surveys, and conducted at appropriate times to determine presence/absence. If any are present, additional field study would be needed to determine functions provided by the project area. We note that a single Bicknell’s thrush was observed in the fall of 2004.
Other wildlife species that may be affected by habitat fragmentation include bobcat, black bear, moose, and fisher. Moose tracks were observed frequently during our September 21 and November 18, 2005 field visits to the site. A bear-clawed beech tree was observed near the trail leading to Kennedy Hill during the November 18 field visit. Each of these species are either known or expected to occur, and their presence and abundance should be confirmed by field study, as well as functions provided by the project area.
During our November 18, 2005 and January 20, 2006 meetings, we recommended that acoustic detectors be placed on the southernmost meteorological tower in addition to the north tower, and that mist nets and acoustic detectors be deployed at the beaver pond adjacent to the trail leading to Kennedy Hill at the north end of the proposed turbine string. In 2005, the bat detectors were deployed from September 20 to October 31 at the northern meteorological tower. We agree that the bat detectors need to be deployed much earlier to provide the opportunity to collect data on resident and migratory bat use of the area. The most comprehensive coverage of the three sampling locations would be provided by operating the bat detectors from April 15-October 15. Alternatively, spring and fall sampling should be conducted during the April 15-June 15 and July 15-October 15 period. The sampling at the beaver pond area should include the use of mist nets during these sampling periods.
In a like manner, the fall 2005 raptor survey was not initiated until September 19 when the migration season was in progress. A similar raptor study at the Hoosac Wind Project in western Massachusetts in fall 2004 indicates that early and mid-September dates were peak days for raptor migration at that site that year. Accordingly, we do not think the fall 2005 raptor study can be considered as necessarily being representative. In addition, it is not clear if the 10 days of observation were spaced to include the most favorable weather periods after the passage of frontal systems, e.g., 1-3 days after the passage of a cold front. We recommend that the raptor migration study be continued in fall 2006, and include observations from more than one site in the project area. The study should be conducted between September 1 and October 31. Survey dates should be scheduled for the most favorable weather periods after the passage of frontal systems. Since there is no way to know in advance how many frontal systems and favorable migration days will occur in this period, it is likely that more than 10 days of survey effort may be necessary. We suggest that you expand the level of effort to allow for three weeks (21 days) of survey time. We agree that the observers should attempt to identify and record all birds seen when conducting the survey. The behavior of the birds with respect to updrafts, wind speed and wind direction, e.g., where their flight path is with respect to the ridge or hilltop, e.g., east-, west-, north-, southside, or directly over the ridge, should be recorded, in addition to flight height, time of day, and other standard hawk watch parameters.
During our July 12, 2006 meeting, we discussed and requested information largely pertaining to wetlands and other water resources of the Lempster site. Among the available items we requested include: aerial photography of the site; project maps showing road, transmission and turbine layout; erosion and sedimentation control plans (received 7/25/06); wetland and water course delineations of the project construction or near field area (received 7/25/06), and of the approximately 1,500-acre project area; vernal pool delineations; and any studies conducted in the wetlands, streams and vernal pools. We expressed a particular interest in the process and time period utilized for the vernal pool and vernal pool species identification process. Our recommendation is that the vernal pool identification and delineation take place after snow melt in early spring wet, e.g., saturated conditions. Please provide us with any revised wetland or vernal pool delineations.
We remain available to discuss these information needs, our comments on studies and study protocols, and other matters contained herein.
Questions should be directed to me at 603-223-2541 or email email@example.com.
Vernon B. Lang
New England Field Office