Cape Wind Monitoring Plan Is for the Birds

The plan for monitoring impacts on birds and bats from the Cape Wind turbine farm slated for Nantucket Sound has gaping holes that may render it useless, according to formal comments filed today by Public Employees for Environmental Responsibility (PEER). The deficiencies mean that there will be no reliable method for gauging the true effects of the massive offshore project on bird and bat populations, especially federally protected species.

Currently, the Interior Department's Bureau of Ocean Energy Management, Regulation and Enforcement (BOEM) is conducting an environmental assessment of the Construction and Operations Plan including the "Cape Wind Avian And Bat Monitoring Plan" submitted by the project sponsor Cape Wind Associates. BOEM must approve the plan in order to issue permits for the project's final development.

The proposed 130-turbine complex straddles the migratory routes of many species, including the endangered piping plover and roseate tern. The monitoring plan, however, suffers from -

• Not knowing the flight patterns of the piping plover and roseate tern, thus making it impossible to determine risk from the rotor blades. The plan proposes to use surrogate species, again, without knowing whether these substitute birds behave as the federally protected ones do;
• Reliance on a bat detection system designed for "cool dry conditions" that will instead be deployed in the ocean. Moreover, the manufacturer warns that some bat species will not be detected if they are flying more than one meter away from the detector and cautions that "detection distances will vary enormously"; and
• Such narrow use of acoustic monitoring and other sampling that it is unclear whether any data produced will be statistically meaningful.

"This plan is designed to create the illusion of effective monitoring," stated New England PEER Director Kyla Bennett, a former federal scientist and attorney. "In that sense, this is worse than nothing at all because it blocks constructive efforts to measure true impacts."

PEER is leading a coalition of plaintiffs in a lawsuit against the project for violations of the Endangered Species Act, Migratory Bird Treat Act, and National Environmental Policy Act. In addition, PEER disclosed a trove of agency e-mails documenting that scientists did not have the data to make required assessments of the mega-project.

"By the time the actual effects of this project become apparent, it may be too late for the populations of concern," Bennett added. "The Obama administration has repeatedly promised science-based decision-making. This would be the ideal moment to start following through on that pledge."