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Data Gaps in DEIS for Cape Wind

Mass Audubon Urges Army Corps to Produce Supplemental Draft Environmental Impact Statement for the Proposed Cape Wind Project

In the organization's first public comment since the Draft Environmental Impact Statement (DEIS) for the Proposed Cape Wind Project was released, Mass Audubon urges the Army Corps to produce a Supplemental DEIS addressing key data gaps, particularly in regard to birds, which need to be filled before the document could be considered adequate to move forward to the Final EIS (FEIS) stage.

On November 9, 2004, Mass Audubon began its review of the long-awaited 4,000-page DEIS. As proposed, Cape Wind would be the first offshore wind farm in North America and one of the largest in the world.

"We appreciate this opportunity participate in the public hearings, which begin tonight, in response to the Draft Environmental Impact Statement for the Cape Wind Energy Project. Our comments are focused on avian, marine, and public lands impacts as these are most relevant to Mass Audubon's mission," said Jack Clarke, Mass Audubon's director of advocacy. "As we review the DEIS we are weighing both the project's benefits and detriments. Our review standard is that the construction and operation of 130 Cape Wind turbines on Horseshoe Shoal pose no undue mortality risks for avian and marine wildlife there or significantly lower its habitat value."

Mass Audubon will testify on the project at public hearings on the Cape and Islands, focusing on the following information in the report. The conclusion reached in the DEIS that the project is likely to cause approximately 364 bird deaths per year due to collisions with the turbines is not supportable. This number is derived from averaging data from studies of land-based wind farms and does not include studies from Europe that report higher per turbine mortality, nor does it consider data collected for the DEIS. Due to the high degree of uncertainty associated with this first large scale offshore project in the U.S., a range of figures should be presented rather than a single number of estimated bird collision deaths per year based on a more complete review of the literature and collision-risk models using data collected from the project area.

Mass Audubon and the US Fish & Wildlife Service have requested three (3) years worth of seasonal avian information as a necessary component of the NEPA review. Data on three groups of birds are needed: terns, winter waterfowl, and migrating passerines (songbirds). Mass Audubon's position on this project may be dependent on the submission of complete and adequate avian information in the FEIS. The DEIS contains two years of data on terns and winter waterfowl, and one incomplete year of information on migrating passerines, falling short of the three years for each as requested.

As the DEIS was being drafted, Mass Audubon offered and the Army Corps accepted their independent, primary research data on terns and winter waterfowl to supplement the data provided by the applicant. Other studies are underway and will be submitted to the Army Corps when complete. Mass Audubon looks forward to further cooperation with the Corps as bird studies on Nantucket Sound continue this winter and to the incorporation of this data in the next iteration of the EIS.

Even with the addition of the pending studies, Mass Audubon has identified two significant avian data gaps. The first regards wintering Long-tailed Ducks and their evening roosting areas in and around Nantucket Sound. The second regards nocturnal passerines migrating through the site in spring and fall.

Additionally, statements concluding a minimal risk to bats are made in the absence of any data.

As responsible citizens, stewards, and advocates, Mass Audubon strongly supports public policies and private projects that advance energy conservation and efficiency. Rapid climate warming is one of the most serious long-term threats to the nature of Massachusetts and planet. This warming primarily results from the burning of fossil fuels to power cars, trucks, planes and trains, and generate electricity. Though we make up just 4 percent of the world's population, Americans produce 25 percent of the world's carbon dioxide pollution.

Mass Audubon supports the development of wind farms as a renewable energy source to offset the effects of global climate change produced by the burning of fossil fuels. "The development, production, and consumption of fossil fuels damages the public's health and environment every day through the destruction of wildlife habitat from drilling and mining; the closure of shell fisheries and fouling of beaches by oil spills; damage to human health from air and water pollution; and contamination of groundwater from the disposal of solid and hazardous waste," said Jack Clarke. "Mass Audubon will continue to work with the state and federal government, the energy industry, and environmental colleagues to ensure rapid progress on reducing reliance on fossil fuels through conservation and wind energy development while minimizing the negative environmental impacts."

You can find out more about Mass Audubon's position statement on wind energy at www.massaudubon.org/wind.

For more information:
Please contact Jack Clarke at 617-962-5187 or Susannah Caffry at 781-259-2135.