AVIAN AND BAT PROTECTION PLAN

AVIAN AND BAT PROTECTION PLAN
AVIAN AND BAT PROT ECT ION PLAN
AWA Goodhue, LLC
Goodhue County, Minnesota
December 15, 2011
Prepared For:
AWA Goodhue, LLC
c/o American Wind Alliance LLC
8117 Preston Road, Suite 260
Dallas, Texas 75225
Prepared By:
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Avian and Bat Protection Plan
AWA Goodhue Wind Project
Goodhue County, Minnesota
Prepared for:
AWA Goodhue, LLC
Goodhue Wind Project
c/o American Wind Alliance, LLC
8117 Preston Road, Suite 260
Dallas, TX 75225
Prepared by:
Westwood Professional Services
7699 Anagram Drive
Eden Prairie, MN 55344
(952) 937-5150
Project Number: 20081147.00
Submitted in compliance with the
Minnesota Public Utilities Commission
Site Permit for AWA Goodhue, LLC
PUC Docket No. IP-6701/WS-08-1233
Permit Section 6.7 and Special Condition 13.1
December 15, 2011
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Avian and Bat Protection Plan – AWA Goodhue Wind Project
December 15, 2011
CONTENTS
List of Tables .......................................................................................................................... iii
List of Exhibits.......................................................................................................................... iii
List of Appnedices .....................................................................................................................iv
1.0 OVERVIEW ...................................................................................................................... 1
1.1 Project Description .................................................................................................... 1
1.2 Purpose of Avian and Bat Protection Plan (ABPP) ..................................................... 1
1.3 ABPP Content ........................................................................................................... 2
1.4 Acronyms and Abbreviations used in the Plan ........................................................... 2
2.0 APPLICABLE WILDLIFE LAWS AND GUIDANCE ...................................................... 2
3.0 MPUC SITE PERMIT COMPLIANCE .............................................................................. 3
3.1 Site Permit Conditions Relevant to ABPP .................................................................. 3
3.1.1 Biological and Natural Resource Inventories.................................................. 3
3.1.2 ABPP Preparation and Approval .................................................................... 3
3.1.3 Eagle Special Condition ................................................................................. 3
3.1.4 Bat Special Condition .................................................................................... 4
3.1.5 Loggerhead Shrike Special Condition ............................................................ 5
4.0 WILDLIFE AGENCY CONSULTATION AND INFORMATION SHARING .................. 6
4.1 Consultation Efforts to Date....................................................................................... 6
4.2 Plan for Consultation, Information Sharing, and Reporting ........................................ 6
5.0 2011-2012 AVIAN AND BAT FIELD STUDIES .............................................................. 6
5.1 Bald Eagles ................................................................................................................ 6
5.1.1 2011 Monitoring of New Eagle Nests ............................................................ 6
5.1.2 2011 Monitoring of Eagle Movements ........................................................... 8
5.1.3 Proposed 2011-2012 Bald and Golden Eagle Surveys .................................. 10
5.2 Loggerhead Shrikes ................................................................................................. 12
5.2.1 Agency Coordination and Field Investigation .............................................. 13
5.2.2 Inclusion of Loggerhead Shrikes in Point Count Surveys ............................. 15
5.2.3 Reporting Loggerhead Shrike Nesting Activity ............................................ 15
5.3 Trumpeter Swans ..................................................................................................... 16
5.4 Updated 2012 Raptor Nest Survey ........................................................................... 16
5.5 Acoustic Bat Monitoring .......................................................................................... 16
5.5.1 Bat Detector Installation .............................................................................. 16
5.5.2 Anabat Data Analysis and Report Preparation .............................................. 17
5.5.3 Bat Monitoring Report ................................................................................. 18
6.0 POST-CONSTRUCTION AVIAN AND BAT FATALITY MONITORING.................... 21
6.1 Number and Selection of Turbines for Monitoring ................................................... 21
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6.2 Fatality Monitoring Protocol .................................................................................... 21
6.3 Fatality Reporting .................................................................................................... 22
7.0 RISK ASSESSMENT ...................................................................................................... 22
7.1 Overall Avian Community ....................................................................................... 22
7.2 Bald and Golden Eagles ........................................................................................... 23
7.3 Loggerhead Shrikes ................................................................................................. 27
7.4 Trumpeter Swans ..................................................................................................... 29
7.4.1 Trumpeter Swan Habitat Preferences ........................................................... 29
7.4.2 Collision Risk to Trumpeter Swans .............................................................. 31
7.5 Bats ......................................................................................................................... 31
7.5.1 White-Nose Syndrome ................................................................................. 32
7.5.2 Risk of Turbine-Related Bat Fatality ............................................................ 32
8.0 IMPACT AVOIDANCE AND MINIMIZATION ............................................................ 33
8.1 Overall Avian Community ....................................................................................... 33
8.1.1 Pre-Construction .......................................................................................... 33
8.1.2 Construction ................................................................................................ 33
8.1.3 Post-Construction ........................................................................................ 34
8.2 Bald Eagles .............................................................................................................. 36
8.2.1 Pre-Construction .......................................................................................... 36
8.2.2 Construction ................................................................................................ 38
8.2.3 Post-Construction ........................................................................................ 39
8.3 Golden Eagles .......................................................................................................... 43
8.4 Loggerhead Shrikes ................................................................................................. 43
8.4.1 Pre-Construction .......................................................................................... 43
8.4.2 Construction ................................................................................................ 45
8.4.3 Post-Construction ........................................................................................ 45
8.5 Trumpeter Swans ..................................................................................................... 46
8.6 Raptor Nests ............................................................................................................ 48
8.6.1 Pre-Construction .......................................................................................... 48
8.6.2 Construction ................................................................................................ 48
8.6.3 Post-Construction ........................................................................................ 49
8.7 Bats ......................................................................................................................... 49
8.7.1 Pre-Construction .......................................................................................... 49
8.7.2 Construction ................................................................................................ 49
8.7.3 Post-Construction ........................................................................................ 50
8.7.4 Potential Federal Listing of Northern Long-eared Bat .................................. 50
9.0 ABPP IMPLEMENTATION ............................................................................................ 50
9.1 Training ................................................................................................................... 50
9.1.1 Development Stage Environmental Training ................................................ 51
9.1.2 Construction Stage Environmental Training ................................................. 51
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9.1.3 Operations Stage Environmental Training .................................................... 51
9.1.4 External Training: ........................................................................................ 52
9.2 Quality Control and Adaptive Management ............................................................. 52
9.2.1 Quality Control ............................................................................................ 52
9.2.2 Adaptive Management ................................................................................. 53
9.2.3 Avian and Bat Reporting to MPUC, DOC-EFP, USFWS and MDNR .......... 53
9.3 Key Resources ......................................................................................................... 56
10.0 PROJECT DECOMMISSIONING ................................................................................... 56
11.0 LITERATURE CITED ..................................................................................................... 58
TABLES
Table 5.1. Bat Species and Species Groups used to Categorize Acoustic Data ........................... 19
Table 5.2. Bat Species Recorded during July 22-November 22, 2011 ....................................... 19
EXHIBITS
Exhibit 1: MPUC-Approved Project Area and Proposed Facilities
Exhibit 2: Approximate Operational Project Area
Exhibit 3: Bald Eagle Nests and Monitoring Clusters
Exhibit 4: Bald Eagle Monitoring Results – Cluster 1
Exhibit 5: Bald Eagle Monitoring Results – Cluster 1A
Exhibit 6: Bald Eagle Monitoring Results – Cluster 2
Exhibit 7: Bald Eagle Monitoring Results – Cluster 3
Exhibit 8: Bald Eagle Monitoring Results – Cluster 4
Exhibit 9: Bald Eagle Point Count Plots, Post-construction Fatality Monitoring Turbines, and
Trumpeter Swan Nesting Site
Exhibit 10: Aerial Survey Transects
Exhibit 11: Road Survey Routing
Exhibit 12: Loggerhead Shrike Course Filter Habitat Model (August 19, 2011)
Exhibit 13: Field Review Turbine Cluster A
Exhibit 14: Field Review Turbine Cluster B
Exhibit 15: Turbine Centered Habitat Model Review
Exhibit 16: Land Cover and Bat Monitoring Locations
Exhibit 17: Fatality Search Plot Schematic
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APPENDICES
Appendix A: Site Selection Factors
Appendix B: Acronyms and Abbreviations Used in ABPP
Appendix C: Applicable Wildlife Laws
Appendix D: Biological Inventories
Appendix E: Summary of Agency Coordination to Date
Appendix F: Minnesota DNR Fatality Monitoring Report Forms
Appendix G: Eagle Collision Risk Modeling – 2011 Breeding Season Data
Appendix H: Wildlife Incident Reporting Form
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1.0 OVERVIEW
1.1 Project Description
AWA Goodhue, LLC (AWA Goodhue) received a site permit from the Minnesota Public
Utilities Commission (MPUC) on August 23, 2011 to construct a 78 MW large wind
energy conversion system in Goodhue County, Minnesota. The Project Area approved
under the Site Permit covers approximately 32,684 acres (51 square miles) (Exhibit 1),
which is mostly agricultural land. Upon completion of construction, the MPUC will amend
the Project Area approved in the Site Permit to cover only the properties necessary for the
efficient operation of the project. In this ABPP, we have referred to this final Project Area
as the “Operational Project Area” for purposes of the ongoing wildlife survey work. The
approximate boundary of the Operational Project Area plus a two mile buffer is depicted in
Exhibit 2.
The Project has been revised to involve construction of 48 1.6 MW GE turbines with a total
nameplate capacity of 76.8 MW, two project substations, collector and feeder lines, an
operation and maintenance (O&M) facility, two permanent meteorological towers,
associated access roads and a new approximately four mile 69 kV transmission line. The
final turbine layout depicts 52 total turbines locations, of which 48 are primary turbines and
will actually be constructed and four are alternate locations (see Exhibit 1). The number of
turbines proposed has been reduced by shifting entirely to 1.6 MW machines. The four
alternate turbine locations exist in case any proposed turbine locations are eliminated due
to unforeseen constraints. The factors relied upon in selecting the site for the Project and
developing the turbine layout are discussed in Appendix A.
1.2 Purpose of Avian and Bat Protection Plan (ABPP)
AWA Goodhue, LLC is committed to being a good steward of the environment and
adhering to the law. As part of this commitment, AWA Goodhue has developed an Avian
and Bat Protection Plan (ABPP) for the AWA Goodhue Wind Project. This ABPP is the
culmination of over three years of coordination between AWA Goodhue, DOC-EFP,
MDNR and USFWS to adequately address wildlife issues. This coordination included
ongoing telephone and email coordination, several comment letters and multiple meetings
and/or conference calls.
The purpose of the AWA Goodhue ABPP is to provide a framework for fulfilling the
conditions set forth under Section III.C.2 of the project MPUC Site Permit and for
complying with other applicable federal and state laws. Specific objectives are to ensure
that:
1. Avian and bat fatalities and secondary effects on wildlife are minimized at the
AWA Goodhue Wind Project;
2. Project-related actions comply with federal and state wildlife regulations;
3. The wildlife-related conditions contained in the MPUC Site Permit (i.e. Sections
6.1, 6.7 and 13.1) for the Project are fulfilled;
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4. Bird and bat injuries and fatalities are effectively documented, so as to provide the
basis of ongoing development of avian protection procedures;
5. Ongoing surveys, monitoring and management efforts are undertaken to avoid and
minimize adverse wildlife impacts throughout all phases of the project;
6. Adequate ABPP implementation training is provided to the Construction Contractor
and Operations and Maintenance staff;
7. Coordination between AWA Goodhue, wildlife agencies, DOC-EFP and the MPUC
is continuous and understanding is maximized.
8. Extensive, detailed records on pre- and post-operational eagle movements are
compiled to inform future management decisions on the Project and facilitate the
future refinement and validation of the USFWS draft risk assessment model for
eagles.
1.3 ABPP Content
This ABPP is specific to the AWA Goodhue wind project. It describes protocols to
responsibly address wildlife risks and conduct studies to understand the interaction of
wildlife with the AWA Goodhue wind project. The organization and content of this ABPP
is based on a number of sources, which include, but are not limited to:
1. A white paper prepared by the U.S. Fish and Wildlife Service (USFWS 2010a);
2. Recommendations prepared by the Wind Turbine Guidelines Advisory Committee
(WTGAC 2008a);
3. ABPPs prepared across the United States for other wind power projects;
4. Specific requirements set forth in the MPUC Site Permit;
5. Draft Avian and Bat Survey Protocols for Large Wind Energy Conversion Systems
issued by the MDNR;
6. Bald Eagle Conservation Plan Guidance issued by the USFWS; and
7. Extensive input and feedback obtained from the USFWS, MDNR and DOC-EFP
through a series of written reviews and coordination meetings.
1.4 Acronyms and Abbreviations used in the Plan
This document uses a variety of acronyms and shortened terms to describe involved
corporations, agencies, units of measure, regulations, programs, and technical terms. These
acronyms and abbreviations are supplied in Appendix B.
2.0 APPLICABLE WILDLIFE LAWS AND GUIDANCE
A number of federal and state wildlife laws apply to the AWA Goodhue Wind Project and
guided various aspects of this ABPP. These laws are summarized in Appendix C. Because the
MPUC Site Permit for the Project contains very specific conditions that are to be addressed in
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this ABPP, those conditions are set forth in detail in the next section. Also, the USFWS has
recommended that AWA Goodhue apply for an Incidental Take Permit (ITP) under the Bald and
Golden Eagle Protection Act (BGEPA). AWA Goodhue accepts this recommendation and will
submit an ITP application after approval of this ABPP. The ITP process is discussed in
Appendix C. AWA Goodhue will work with the USFWS to develop the appropriate terms of
the ITP and quantify the allowable take.
3.0 MPUC SITE PERMIT COMPLIANCE
3.1 Site Permit Conditions Relevant to ABPP
3.1.1 Biological and Natural Resource Inventories
Section 6.1 of the Site Permit issued for the Project on August 23, 2011 requires that
AWA Goodhue, in consultation with the MPUC and MDNR, design and conduct preconstruction desktop and field inventories to identify potentially affected native
prairies, wetlands, and other biologically sensitive areas within the project area, and
assess the presence of state and federal threatened, endangered, or special concern
species. AWA Goodhue conducted a series of investigations that collectively
represent a comprehensive inventory of the biological and natural resources in the
project area. These investigations are summarized in Appendix D.
3.1.2 ABPP Preparation and Approval
Section 6.7 of the Site Permit requires that AWA Goodhue prepare an ABPP and
obtain MPUC approval of the document prior to construction. Section 13.1 of the
Site Permit sets forth ABPP Special Conditions relating to eagles, bats and
loggerhead shrikes (described in more detail below). This ABPP has been prepared to
address these permit conditions and respond to the significant input and feedback
received from the USFWS and MDNR during the development and review of this
document. The details of these conditions and the manner in which compliance will
be achieved are discussed in more detail below.
3.1.3 Eagle Special Condition
Site Permit Section 13.1.1 states:
“The Permittee shall develop a plan for monitoring Bald and Golden
Eagle nest1 sites near turbine locations and shall develop protocol to
1
Golden eagles do not nest in Minnesota (Mark Martell, Minnesota Audubon, Pers. Comm.)
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identify proposed point count locations, suggested count duration and
number of survey visits. Point counts of 20-30 minutes shall be conducted
to document eagle movements in these areas. Multiple point count visits
shall be conducted to cover the remainder of the 2011 nesting season
(eaglets are expected to fledge by mid-July). Additional point counts shall
be conducted in the fall of 2011 and the winter of 2011-2012. Details of
the plan shall be included in the Avian and Bat Protection Plan. Ongoing
monitoring for eagles shall be conducted in accordance with the Avian
and Bat Protection Plan and U.S. Fish and Wildlife Service requirements.
The Permittee shall submit the results of the summer, fall, and winter
surveys, and any subsequent surveys, to the Commission within one
month of completion of the surveys.”
This ABPP sets forth the proposed protocol for conducting eagle point counts which
are: (1) consistent with the project-specific input received from the USFWS; (2)
exceed the recommendations set forth in the Draft Eagle Conservation Plan Guidance
(USFWS 2011); and (3) comply with this special condition of the Site Permit. AWA
Goodhue has initiated additional surveys recommended in supplemental
recommendations provided by the USFWS in a letter dated September 16, 2011.
These additional surveys include: (1) point count surveys conducted during the fall
2011 and spring 2012 migration periods; (2) monthly aerial surveys during the winter
of 2011-2012 to search for Important Eagle Use Areas (IEUAs) and raptor nests and
(3) bi-weekly driving surveys during the winter of 2011-2012 to search for and verify
IEUAs. These additional surveys are described in more detail in Section 5.13.
Seasonal and annual survey results will be reported to the MPUC and USFWS within
one month of the completion of each round of surveys.
3.1.4 Bat Special Condition
Site Permit Section 13.1.2 states:
“The Permittee shall install a minimum of two Anabat detectors on each
temporary or permanent meteorological tower. Data should be collected,
at a minimum, from July 15 to November 15, 2011, and May 1 to
November 15, 2012. One Anabat detector on each meteorological tower
shall be mounted at 5 meters above ground, and one shall be mounted as
close to the rotor-swept area as possible. Additional monitoring or
mitigation measures may be imposed based on results obtained from bat
surveys. The Permittee shall submit the results of the 2011 monitoring by
December 15, 2011 and the 2012 monitoring by December 15, 2012.
Each report shall include an update on the status of the U.S. Fish and
Wildlife Service potential listing of the Northern long-eared bat.”
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As described in Section 5.5 of this ABPP, two Anabat detectors were installed on a
temporary met tower on site on July 22, 2011. Given that the Anabat permit
condition only became known on June 30, 2011, it was not possible to acquire the
necessary equipment from Titley Scientific and have it installed and operational by
July 15, 2011. To compensate for the seven day deficit at the beginning of the
monitoring period, AWA Goodhue added seven days at the end of the period.
Accordingly, these Anabat units will be monitored through November 22, 2011 and
again from May 1 to November 15, 2012. Survey results will be submitted by the
dates specified in this special condition and will include updates on the federal listing
status of the Northern Long-eared Bat.
3.1.5 Loggerhead Shrike Special Condition
Site Permit Section 13.1.3 states as follows:
“The Permittee shall avoid placement of turbines in areas identified as
highly suitable or very highly suitable loggerhead shrike habitat.
Alternate turbine sites are to be considered the primary avoidance
strategy. If alternate sites cannot be utilized, the Permittee shall provide
the Commission and DNR with a Loggerhead Shrike Protection Plan for
approval by the Commission detailing why avoidance is not possible,
outlining strategies to minimize effects to Loggerhead Shrike, and
providing mitigation measures for impacts. Permittee shall conduct two
years of post-construction fatality monitoring to evaluate the impacts of
wind turbines sited in loggerhead shrike habitat determined to be highly
to very highly suitable.”
The turbine layout has been modified so that all 48 proposed turbine locations and all
4 alternates are in locations that the MDNR concurs are not of concern with regard to
loggerhead shrike habitat. In comments dated September 21, 2011, the MDNR
indicated as follows:
“DNR staff have reviewed AWA Goodhue efforts to relocate turbines
away from state-listed threatened loggerhead shrike habitat. The DNR
appreciates the project proposer’s willingness to make project
adjustments. The adjustments made and included in the ABPP and
associated aerial photography dated August 19, 2011 address DNR
concerns regarding the location of turbines in highly suitable and very
highly suitable habitat.”
Based upon the above-quoted MDNR concurrence, AWA Goodhue has complied
with Site Permit Section 13.1.3 in the siting of turbines and a formal, separate
Loggerhead Shrike Protection Plan should not be required. However, two years of
post-construction fatality monitoring will still be carried out for all avian and bat
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species, including loggerhead shrikes. Also, as requested by the MDNR in their
September 21, 2011 comments, we have reviewed the current site plan to determine
which elements of project infrastructure aside from turbines would lie in highly
suitable or very highly suitable loggerhead shrike habitat. The purpose of this review
was to identify areas where construction is to be staged to avoid the shrike breeding
period. The locations where shrike-specific construction staging applies are
discussed in Section 8.4.2.
4.0 WILDLIFE AGENCY CONSULTATION AND INFORMATION SHARING
4.1 Consultation Efforts to Date
The current Project layout and this ABPP are products of a lengthy and involved agency
coordination process. Consultation efforts to date are summarized in Appendix E.
4.2 Plan for Consultation, Information Sharing, and Reporting
AWA Goodhue will continue to work cooperatively with the USFWS and the MDNR
during implementation of the ABPP, including sharing relevant, non-proprietary site data
and pre- and post-construction study results. Specific reporting benchmarks and time
frames are set forth in the ABPP implementation schedule provided in Section 9.0.
5.0 2011-2012 AVIAN AND BAT FIELD STUDIES
To provide context for the proposed field studies described in this ABPP, the following sections
discuss surveys conducted earlier in 2011.
5.1 Bald Eagles
5.1.1 2011 Monitoring of New Eagle Nests
On May 2, 2011, Westwood received notification from interested parties of new bald
eagle nests within or near the project footprint. On May 6, 2011, Westwood met with
those parties in the field and confirmed these new nest sites. These additional nests
are described as follows:
One new active nest was observed within the previously documented nesting territory
about one mile south of the AWA Goodhue footprint on the North Fork of the
Zumbro River in Section 23, Township 110, Range 16. The new nest is slightly
farther from the project footprint than the previously documented nest that was active
in 2010 (but found to be inactive in 2011).
One new active nest in a small woodlot in the northwest quarter of Section 30,
Township 111, Range 15, about 1.25 mile west of the City of Goodhue. This woodlot
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was surveyed for raptor nests in 2010 and did not contain an eagle nest at that time;
hence, this is a new nest that was established since 2010. The landowner was
contacted and he confirmed that this nest had been built in 2011. The nest is within
the project footprint and about one mile northeast of the nearest proposed turbine;
One new nest in a narrow tree line in Section 27, Township 111, Range 15, about 3/4
mile southeast of the City of Goodhue. This nest is about 2.5 miles east of the project
footprint and over 3.5 miles from the nearest proposed turbine. The landowner was
contacted, and he confirmed that this nest had been built in 2011. As discussed
below, this nest was under construction in 2011 but was later found to be inactive (i.e.
the birds building the nest subsequently abandoned it and no young were produced).
On June 1, 2011, interested parties indicated by email as many as 12 alleged nests in
and around the project footprint. A second field review was conducted with those
parties on June 8, 2011 to confirm the reported nests but no additional nests were
observed. Confirmed and reported but unconfirmed eagle nests are depicted Exhibit
3. On May 20, 2011, Westwood initiated nest monitoring at the two new bald eagle
nests using the same techniques as for earlier nests. A total of 12.5 and 13 hours of
observations were made at the nests west and southeast of Goodhue, respectively.
The results of this monitoring are as follows:
5.1.1.1 Nest West of Goodhue
During 12.5 hours of observation, 17 bald eagle flights were observed. Of these,
6 were short flights from the nest to a food source on ground about 20 yards
from the nest (later confirmed to be a livestock carcass dump from an adjacent
calving operation). The remaining flights were exercise flights, territory
defenses, local flights between perches or likely trips to a natural food source to
the south (e.g. the North Fork of the Zumbro River). Most of these movements
were local flights within about ½ mile of the woodlot in which the nest was built
and did not pass through any proposed turbine clusters. Three flights were
observed where the eagle rode thermals to gain altitude and soared to the south
or southeast. One of these soaring flights overflew the location of the proposed
turbine cluster to the southwest but the eagle was well above the rotor swept
zone during this overflight.
5.1.1.2 Nest Southeast of Goodhue
During 13 hours of observation, 11 bald eagle flights were observed. Of these,
four were short flights to or from the nest to a perch site behind the farmstead
immediately to the east. This perch site overlooked a cattle yard and calving
operation. The remaining flights were either exercise flights or likely trips to a
natural food source along the Zumbro River. All but one of these flights were
directly to the east or south and none were observed to be in the direction of the
project footprint. During the initial observations on May 27, 2011, the birds
were observed bringing in nest material. This would not be occurring if the
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birds were incubating eggs or tending to hatchlings. As of June 3, 2011, the
birds were not observed during 7 hours of nest observations. We contacted the
landowner, who said he had not seen the eagles in a week. When asked about
the eagle’s interest in his livestock operation, he indicated that he composted
dead livestock and then spread the remains with his manure spreader. No eagles
were observed during a follow up site visit June 8, 2011.
5.1.2 2011 Monitoring of Eagle Movements
On June 9, 2011, AWA Goodhue and Westwood participated in a meeting and
conference call with staff from the DOC- EFP, USFWS and MDNR. The results of
the 2011 nest monitoring activities were discussed. During this call, the USFWS
recommended that the locations for ongoing bald eagle monitoring be shifted from
the nests to the turbine cluster locations nearest to active nests. In response to this
recommendation, a total of 152 additional hours of monitoring were spent at four
turbine cluster locations nearest to: (1) the Belle Creek nest; (2) the nest on the North
Branch of the Zumbro River; (3) the nest west of Goodhue; and (4) a reservoir near
the western edge of the project footprint (see Exhibit 3).
On July 29, 2011, the 2011 eagle monitoring data was discussed at a meeting between
AWA Goodhue representatives, Westwood and staff from DOC-EFP, USFWS and
MDNR. Based on the results through that date, the USFWS recommended that one
monitoring location be shifted to the northwestern-most turbine cluster to determine
whether eagles using the Belle Creek nest were flying through that area. Since July
29, 2011, 58 additional hours of bald eagle monitoring were performed, including
14.5 hours at this location.
Through 210 hours of eagle flight path monitoring at turbine clusters, there were no
consistent flight patterns through the project area. Rather, eagles of the breeding
community in the vicinity of the Project were observed in response to natural and
likely artificial food sources within about half mile from proposed turbines,
particularly at Clusters 2 and 3. As a function of minutes observed, this accounts for
0.08% of our total observation time (i.e. 0.0008 x total observation time), which
assumes 210 observation hours or 12,600 minutes and a conservative 10-minutes of
eagle movement in the RSZ and within 10 meters of a turbine location. Generally, as
the summer went on and breeding territories loosened after juveniles left the nest, we
observed eagles more frequently at all turbine clusters, which was expected based on
eagle breeding ecology.
5.1.2.1 Turbine Cluster 1
During the 32 hours of monitoring in Cluster 1 June and July 2011, one eagle
flight was observed. This observation was of an immature (2nd or 3rd year bird)
riding thermals very high with a pair of Red-tailed Hawks (Exhibit 4). There
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were no flights below or within the RSH observed at this location. Additionally,
the observed flight did not overlap the proposed turbine cluster.
5.1.2.2 Turbine Cluster 1A
During 14.5 hours of monitoring in Cluster 1A in August 2011, four eagle
flights were observed that included two adults and two juveniles (i.e., young of
the year) (Exhibit 5). A portion of one flight was within the RSH and 100meters of a turbine as a juvenile circled to gain altitude and lasted only a few
minutes. As a function of approximate eagle flight distance, about 1.2% of
observed eagle flights at this cluster were both within the RSH and 100-m of a
turbine. Generally, eagles were observed riding thermals and soaring very high
at this location.
5.1.2.3 Turbine Cluster 2
Cluster 2 was monitored for 58.5 hours during June – August 2011. Fifteen
flights were observed, all of which were adults (Exhibit 6). A portion of four
flights was within the RSH while eagles gained altitude either to or from the
reservoir. However, no observed flights at any altitude overlapped turbine
clusters. Eagles were routinely observed flying to and from the Belle Creek
Watershed reservoir from the north and are likely the Belle Creek nest pair. The
Belle Creek Watershed reservoir is an entirely open water body with no
emergent wetland fringe. The reservoir does contain fish and bald eagles have
been observed capturing fish during low flights from various perches on the
reservoir tree line. To date, none of the observed eagle movements associated
with foraging at the reservoir were within 100 m of turbine locations to the west.
The observed movements that were within the RSZ were associated with
forested areas and ridges north of the Project Area between the nest and the
reservoir and away from the nearest turbine locations, which are in crop fields
to the east.
5.1.2.4 Turbine Cluster 3
During 54.5 hours of monitoring in June – August 2011, 29 flights were
observed around Cluster 3, including 26 by adults and 3 by juveniles (Exhibit
7). A portion of four flights were within the RSH as eagles gained altitude;
however, none of these were within 100 meters of a turbine. As a function of
flight distance, these flights represented about 9.7 percent of the observed eagle
flights at this cluster. Portions of three low and direct flights overlapped the
100-meter radius of turbines but were below RSH. Generally, observed flights
at this cluster were low and local flights in the vicinity of a farmstead on the east
side of 180th Avenue.
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5.1.2.5 Cluster 4
Cluster 4 was monitored for 50.5 hours during June – August 2011. Five flights
of four adults and one juvenile were recorded (Exhibit 8). A portion of one
eagle flight was within the RSH and 100-meter buffer of turbines while gaining
altitude after harassing a Red-tailed Hawk. As a function of approximate eagle
flight distance, about 0.89% of observed eagle flights at this cluster were both
within the RSH and 100-meters of a turbine. Generally, observed flights at this
location were very high soaring flights where the adults would drift north after
gaining altitude over the North Fork of the Zumbro River (and out of our
monitoring map extent).
5.1.3 Proposed 2011-2012 Bald and Golden Eagle Surveys
Based on the eagle nest and flight information collected during earlier survey work,
and in compliance with Special Condition 13.1.1 in the MPUC site permit, AWA
Goodhue has prepared an Eagle Conservation Plan as part of this ABPP. This ECP
follows the recommendations presented in the USFWS 2011 Draft ECP Guidance and
expanded upon in survey recommendations provided by USFWS in a letter dated
September 16, 2011. The surveys being conducted are described below:
5.1.3.1 Migration and Breeding Period Surveys
As recommended by USFWS, sixty minute point counts have been conducted 2
times per week during the fall 2011 migration period and will resume during the
spring 2012 migration periods at five previously established survey locations
plus a sixth location in the northeast corner of the Operational Project Area
(Exhibit 9). In order to capture the migration periods for both bald and golden
eagles, the survey periods will be from September 15 to December 15, 2011 and
from February 1 to April 30, 2012. Coordination will be maintained with Hawk
Ridge Environmental Center and the National Eagle Center to refine these date
ranges according to actual conditions.
Point counts are being conducted in the same manner as earlier counts in 2011,
except that surveyors are recording the amount of time spent by eagles along
flight tracks within 800 meters of the observation point and up to 175 meters in
altitude. Flight tracks are being broken out into segments observed to be below,
within or above the RSZ. This will facilitate the application of an appropriate
collision risk model. Flight tracks are being mapped on aerial photographs.
Point count surveys conducted to date during the fall of 2011 have been
seriously compromised by an active baiting program being conducted by project
opponents. The full extent of the baiting program is unknown but data from at
least two of the six observation points has been compromised by baiting activity.
Both livestock carcasses and relocated road killed wildlife have been used in this
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Avian and Bat Protection Plan – AWA Goodhue Wind Project
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effort. The Minnesota Board and Animal Health (BAH) has confirmed that
baiting with livestock carcasses is occurring. BAH is continuing to investigate
and may initiate enforcement action. The MDNR enforcement division has also
been contacted regarding the relocation of road killed deer without a possession
permit.
Point count surveys will be extended through the summer 2012 breeding season
(i.e. until the end of July 2012) to cover movements associated with bald eagle
nests active in 2012. It is anticipated that by the 2012 breeding season, road kill
clean up and artificial feeding activity on and around the Project Area will be
much better controlled than as of the date of this plan. Ongoing point counts
will assist in evaluating the effectiveness of food base management measures in
reducing eagle movements in close proximity to turbines.
5.1.3.2 Winter Aerial Surveys
As recommended by USFWS, helicopter surveys will be conducted once per
month from early November 2011 to early April 2012 to locate and document
Important Eagle Use Areas (IEUAs; e.g. winter night roosts, communal foraging
locations, nest territories) that might be located within or near the Project Area.
The area to be surveyed will consist of the Operational Project Area plus a twomile buffer. The March aerial survey will be expanded to serve as the spring
2012 leaf-off survey for the nests of eagles, other raptors and colony nesting
waterbirds (e.g. herons, egrets and cormorants). No heron or cormorant
rookeries have been identified to date within or near the Project Area; the
absence of such rookeries will be re-confirmed during the aerial surveys
conducted in March and April 2012.
To avoid disturbance to nesting birds, aerial survey techniques will follow the
USFWS Draft Eagle Conservation Plan Guidelines (2010) and the PostDelisting Monitoring Plan for the Bald Eagle (2009). The helicopter will fly 18
north-south transects spaced ½ mile apart to allow each of two observers to
observe a ¼ mile strip on each side of the aircraft (Exhibit 10). The helicopter
would fly at an altitude between 200 and 700 feet above ground level (AGL) and
at a speed of 100 miles per hour or less. When nests or IUEAs are found, the
helicopter will circle back and hover at an altitude high enough to minimize
disturbance to any birds that may be present and the feature will be located with
a sub-meter GPS unit deployed within the helicopter.
Data collected at each feature will include:
1. Type of feature (e.g. winter night roost, communal foraging location,
nest);
2. If winter night roosts or communal foraging locations are found, the
species of eagle (bald or golden), number, distribution and age classes of
eagles observed;
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3. For nests, occupied versus inactive, incubation and feeding activity of
adults, number of eggs or eaglets; and
4. Any eagle flights observed to or from the feature.
5.1.3.3 Winter Ground Transect Surveys
As recommended by USFWS, driving surveys are being carried out to further
document the presence, characteristics and use of IEUAs in and within two
miles of project area two times per month from early November 2011 to early
April 2012. If wintering eagles are observed to have dispersed due to ice break
up or an early spring, driving surveys may be ended before the first week of
April. These surveys will conducted along a pre-defined route that covers the
Operational Project Area plus a two mile buffer (Exhibit 11). Data to be
collected during driving surveys will include:
1. Areas that have open water during cold weather that could serve as
foraging habitat for wintering eagles.
2. Distribution of observed natural and man-made winter food sources (e.g.
road kills, livestock carcass dump sites, unburied garbage, locations
where promiscuous ice fishing are allowed and water bodies that stay
open allowing access to fish and/or waterfowl).
3. Any observed eagle flights, including movements to/from any winter
night roost locations that may be found.
5.1.3.4 Monitor Satellite Telemetry and Winter Golden Eagle
Survey Results from Minnesota Audubon & National Eagle
Center
AWA Goodhue will continue to coordinate with and obtain updated data from
the Minnesota Audubon and the National Eagle Center regarding golden eagles
that have been fitted with satellite telemetry equipment and are being monitored.
Annual golden eagle survey results will also be obtained from the same sources.
Any data that is relevant the Operational Project Area will be included with
reports for AWA Goodhue’s eagle monitoring and surveying activities.
5.2 Loggerhead Shrikes
Loggerhead shrikes are a state-threatened bird in Minnesota, a USFWS Region 3 Species
of Concern, and are known to occur in Goodhue County. As part of its wind turbine siting
process, AWA Goodhue designed and conducted a comprehensive loggerhead shrike
habitat assessment, coordinated with wildlife agency personnel, and conducted multiple
field investigations to identify, avoid and minimize impacts to loggerhead shrike habitat
with its final turbine layout. As described below, a “coarse filter” habitat assessment was
initially applied to rank each quarter section within the project area as to its suitability as
habitat for breeding loggerhead shrikes. The classifications used were “Unsuitable”,
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“Slightly Suitable”, “Moderately Suitable”, “Highly Suitable” and “Very Highly Suitable”.
Individual turbine locations were then subjected to a more refined “turbine-centered”
habitat model and site-specific aerial photo analysis in coordination with MDNR. In some
cases, individual turbine locations were also visited in the field with MDNR staff to
confirm the presence/absence of shrike habitat components and ensure adequate separation
between turbines and any such components. Consistent with MPUC site permit condition
13.1.3, AWA Goodhue has not sited any turbines in areas determined to be “Highly” or
“Very Highly” suitable shrike habitat, as identified through the above-described iterative
habitat assessment process.
5.2.1 Agency Coordination and Field Investigation
The AWA Goodhue project team coordinated with the MDNR to refine the turbine
layout and avoid and minimize potential effects on loggerhead shrikes and their
habitat. The AWA Goodhue team met with the MDNR and USFWS on February 2,
2010 to discuss the loggerhead shrike habitat assessment and other avian issues. The
Loggerhead Shrike Habitat Assessment (Westwood Professional Services 2009) was
submitted to the MDNR, USFWS, MDOC, and MPUC on October 10, 2010.
The AWA Goodhue team met with MDNR and MDOC staff on November 17, 2010
to address agency questions and concerns related to the results of the Loggerhead
Shrike Habitat Assessment. The Goodhue team provided the MDNR with two
handouts at this meeting: (1) quarter-section aerial photographs showing locations of
turbines proposed in habitats ranked 3-5 (Suitable, Highly Suitable and Very Highly
Suitable), and (2) a summary of the spatial habitat model, turbine siting, potential
effects, and compatibility of wind energy with loggerhead shrikes. Discussion at this
meeting focused on turbine locations, loggerhead shrike habitat, the availability of
suitable unoccupied shrike habitat in Minnesota, and MDNR recommendations to
MDOC regarding potential site permit conditions relating to loggerhead shrikes.
The MDNR team found the 1”=400’ scale quarter-section aerial photographs showing
turbine locations very helpful and agreed that most turbines in highly suitable quarter
sections avoided high-value habitat components. The MDNR’s concerns were
narrowed to two turbines located in grassland within quarter sections ranked highly
suitable for shrikes. The meeting attendees agreed to put the shrike discussion on
hold and take no action related to shrikes until after the MPUC hearing on November
23, 2010.
Biologists from the AWA Goodhue team reviewed areas of highly suitable shrike
habitat and proposed turbine locations in the field with the MDNR and USFWS on
June 13, 2011. The biologists first reviewed a shrike siting location from the
Minnesota Natural Heritage Program database. This sighting was recorded in 1996,
was situated along a fence line in a pasture, and involved a shrike observed during the
breeding season, but not nesting.
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The biologists then reviewed turbine locations proposed in quarter sections ranked
very highly suitable for shrikes and discussed potential effects on shrikes. MDNR
staff indicated concern about turbines sited in grassland within highly ranked quarter
sections, but had less concern regarding turbine locations surrounded by cropland
within highly ranked quarter sections.
As an example, Exhibits 12-15 shows a turbine cluster located in a quarter-section
ranked “Very Highly” suitable. Turbine 16 was located in grassland, while Turbines
17 and 18 were located in cropland. During the field visit, MDNR staff continued to
express concern regarding Turbine 16, but expressed no concern regarding the
locations of Turbines 17 and 18.
During the field investigation, MDNR staff were primarily concerned about
displacement of shrikes that may be caused by shrikes avoiding otherwise suitable
habitat due to the presence of wind turbines. The AWA Goodhue team stated that
available suitable habitat is not limiting shrikes in Minnesota, that there appears to be
abundant suitable habitat in the project area that is not occupied by shrikes, and that
the technical wildlife literature provides no direct evidence indicating that shrikes will
avoid turbines in locations with suitable grassland, nest sites, and perch sites. The
potential for shrike displacement from suitable habitats is discussed in more detail
under the risk assessment (section 7.3).
After the field investigation, the MDNR conservatively advocated moving two
proposed turbine locations out of high quality shrike habitat. As discussed under
section 8.4.1.1, consistent with its efforts to avoid loggerhead shrike impacts, AWA
Goodhue subsequently eliminated both of these turbine locations from its layout.
The June 13, 2011 field review demonstrated an inherent limitation in the quartersection coarse filter habitat model. Although the model functions well for an initial
review, highly suitable quarter sections may contain as little as 50 acres of grassland
that provides suitable shrike habitat, and up to 110 acres of annually-tilled cropland
and woodland that is not suitable for loggerhead shrikes. Consequently, the review of
individual turbine locations revealed that a more detailed turbine-centered habitat
assessment was warranted.
5.2.1.1 Turbine-Centered Habitat Model
AWA Goodhue discussed the development of a turbine-centered habitat model
with MDNR endangered species permit coordinator Rich Baker on August 8,
2011 and presented a working draft of this model during a meeting with MDOC
and MDNR on August 18, 2011. The draft turbine-centered habitat model
applies rankings based on the proportion of grassland, proportion of cropland,
and available perch sites and nest sites within 40-m radius (0.5 ha, 1.25 ac)
circles and 200-m radius (12.6 ha, 31 ac) circles centered on proposed turbine
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Avian and Bat Protection Plan – AWA Goodhue Wind Project
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locations. These circles correspond to the size of the rotor diameter of project
wind turbines and large loggerhead shrike breeding territories, respectively.
The draft turbine-centered model was applied to the project layout on August
18, 2011, resulting in low loggerhead shrike habitat rankings for all but one
turbine. This single turbine was eliminated from the project layout on August
19, 2011.
Following AWA Goodhue’s August 18, 2011 meeting with MDNR, AWA
Goodhue eliminated one additional alternate location that ranked as highly
suitable habitat using the turbine-centered model. In addition, at MDNR’s
request, AWA Goodhue shifted the location of Turbine 6 to provide additional
distance between the turbine and adjacent grassland.
In addition to reviewing the draft turbine-centered habitat model, the MDNR
requested detailed aerial photography showing the location of all proposed
turbines. AWA Goodhue provided the requested aerial photography showing
proposed turbine locations to the MDNR and MDOC on August 21, 2011. The
MDNR reviewed the revised layout and in its comments dated September 21,
2011, the MDNR indicated that AWA Goodhue’s turbine re-siting efforts had
addressed its concerns regarding shrike breeding habitat:
“DNR staff have reviewed AWA Goodhue efforts to relocate turbines
away from state-listed threatened loggerhead shrike habitat. The DNR
appreciates the project proposer’s willingness to make project
adjustments. The adjustments made…address DNR concerns regarding
the location of turbines in highly suitable and very highly suitable
habitat.”
5.2.2 Inclusion of Loggerhead Shrikes in Point Count Surveys
Westwood will document all loggerhead shrikes observed during the 60-minute point
counts and driving surveys conducted for eagles during 2011-2012. If loggerhead
shrikes are observed during these point counts, they will be documented and reported.
5.2.3 Reporting Loggerhead Shrike Nesting Activity
If loggerhead shrikes are observed during any other surveys conducted during the
breeding season, an effort will be made to locate and document the nesting territory
associated with the observation. Loggerhead shrike observations that may occur
incidentally during post-construction fatality monitoring will also be recorded and
reported.
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5.3 Trumpeter Swans
In August of 2011, the MDNR confirmed a report of trumpeter swans nesting and raising a
brood of goslings in a farm pond about 1/3 mile west of the southwest corner of the project
footprint in Township 110 North, Range 16 West, NW ¼ of Section 8 (see Exhibit 9). This
nest site is within the cattail fringe that surrounds this pond. On October 4, 2011, the
MDNR reported that a dead trumpeter swan had been found near the Project Area and that
the death had been from aspergillosis, caused by a fungus common in the environment that
can affect the throat and lungs. Aspergillosis can be caused by the natural environment or
from piles of moldy corn that sometimes are found on agricultural lands.
The AWA Goodhue Project Area appears to encompass very little habitat potentially
suitable for nesting trumpeter swans. Section 8.5 discusses typical trumpeter swan habitat
and evaluates whether suitable trumpeter swan habitat characteristics exist within the site.
In conjunction with other surveys being done in the area, Westwood will visit this nest site
early in the 2012 breeding season to determine whether this reservoir is used again for
nesting. If so, Westwood staff will visit the site up to four times during the nesting season
and spend one hour per visit to observe and document the movements of the adult birds. In
addition, the eagle point count survey location south of Turbine 34 is in relatively close
proximity to the confirmed nest location, and surveyors will note any flights from the nest
into the project area observed from this or any other point count location. Observations
will be reported to the DOC-EFP, MDNR and USFWS at the end of the observation period.
5.4 Updated 2012 Raptor Nest Survey
An aerial leaf-off nest survey for bald eagles and other raptors will be conducted in March
of 2012 in conjunction with winter aerial surveys for bald eagles.
5.5 Acoustic Bat Monitoring
MPUC Site Permit condition 13.1.2 requires the installation and monitoring of two
Anabat® acoustic bat detectors (Titley Scientific Ltd.) on each meteorological (met) tower
installed in the project area. These detectors are to be mounted at heights of 5 and 45
meters (the latter to detect bats in the RSH) and monitored from June 15 to November 15,
2011, and from May 1 to November 15, 2012. Due to the logistics involved in ordering
and shipping the Anabat bat detectors from Titley Scientific following the June 30, 2011
MPUC hearing, it was not possible to acquire and install Anabat equipment by July 15.
AWA Goodhue installed bat detectors and began monitoring shortly thereafter on July 22,
2011. Bat monitoring continued until November 22, 2011.
5.5.1 Bat Detector Installation
Two Anabat bat detectors were installed on a 60-meter tall temporary met tower in
the northeastern part of the project area on July 22, 2011 (Exhibit 16). In 2012,
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Avian and Bat Protection Plan – AWA Goodhue Wind Project
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Anabat equipment will be installed in April to allow monitoring for the full field
season. It is anticipated that the temporary met tower will be replaced with a
permanent met tower during 2012 construction. Once constructed, the permanent met
tower will be outfitted with Anabat acoustic monitoring systems and the temporary
met tower will be removed.
The Anabat units are connected to Anabat microphones that are installed on the met
towers at heights of 5 and 45 meters with cable-pulley systems. The microphones are
encased in “bat hats” that are fabricated from PVC pipe and other materials to protect
them from inclement weather (Arnett et al. 2006). Anabat units, batteries, and
memory cards are stored approximately 4 feet above ground level inside weathertight containers.
Acoustic monitoring is being conducted from July 22 to November 22, 2011 to cover
the late summer resident period and the full fall migration period. Acoustic
monitoring will be conducted from May 1 to November 15, 2012 to cover the spring
migration, summer resident, and fall migration periods. Anabat units are
programmed to turn on each night approximately a half-hour before sunset and turn
off each morning approximately a half-hour after sunrise. The Anabat detectors are
adjusted to a sensitivity level between 6 and 7 to reduce interference from other
sources of ultrasonic noise such as insects and raindrops.
A technician visited the Anabat systems once approximately every two weeks during
the monitoring period to change out batteries and retrieve and replace memory data
cards. Batteries and memory cards were replaced weekly during the first four weeks
of bat monitoring to help ensure quality control and equipment performance. The
recorded data are being downloaded from the memory cards, processed with Anabat
software, and uploaded to an FTP site, from which a bat ecologist retrieves and
analyzes the data. The Anabat systems and related monitoring equipment were taken
down and retrieved at the end of the monitoring season to protect it from winter
weather.
5.5.2 Anabat Data Analysis and Report Preparation
Anabat call files are typically grouped by spring migration, summer resident, and fall
migration periods, and analyzed with Analook software. Audio files are visually
screened to remove files of non-bat calls so that only suitable bat calls remain. Call
files are then examined visually and assigned to species or species-group categories
based on comparisons to libraries of known bat reference calls.
The number of bat passes is used as an index of bat activity (Hayes 1997). A bat pass
is defined as a series of echolocation calls by an individual bat, which consists of a
series of more than two call notes with no pauses longer than one second between call
notes (White and Gehrt 2001, Gannon et al. 2003). The number of echolocation
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Avian and Bat Protection Plan – AWA Goodhue Wind Project
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passes is tallied to determine the number of bat passes. The total number of bat calls
in a given time period and the mean number of bat passes per detector-night will be
used as indices of bat activity for comparisons among detectors and to other studies.
Bat calls may be grouped by high ( 35 kHz) and low (<35 kHz) frequency, which
generally correspond to small bats (e.g., Myotis spp.) versus larger bats (e.g., big
brown bat, silver-haired bat, and hoary bat). A written report will summarize the
detected call rates by species and include related results and conclusions.
5.5.3 Bat Monitoring Report
The purpose of this study was to survey bat activity during the 2011 late summer
resident and fall migratory periods within the wind development area. At the request
of AWA Goodhue, Zotz Ecological Solutions provided this summary of acoustic bat
data especially in reference to activity by the northern long-eared bat (Myotis
septentrionalis). Because the northern long-eared bat overlaps in call characteristics
with the little brown bat (Myotis lucifugus), call identification and differentiation
between these species is difficult. Differentiation of calls between these species is
especially problematic in open (low clutter) environments (Broders et al. 2004). The
temporary meteorological tower where the bat monitoring data was collected is
located in this type of open environment. In cluttered habitats (e.g., forests),
however, the echolocation call of the northern long-eared bat is more easily
distinguished due to its feeding specialization in these habitats.
Methods
Qualitative analysis of acoustic data was performed using the latest Anabat software
for call analysis, Analook version 3.7w (Corben 2009). Call files were visually
screened to remove files of non-bat calls (e.g., wind noise, insects), so that only
suitable bat calls remained. Files with suitable bat calls were examined visually and
identified to species based on comparison to libraries of known bat reference calls.
Identification to species was possible only when clear calls were recorded and only
for certain species. In the event that a call was not identifiable to species, the call was
assigned to a species group category (Table 5.1). The presence of one species or
species group within a call file was used to describe a bat pass. Thus, call analysis
may result in more bat passes than call files if two or more species (or species groups)
can be identified in the same call file. The occurrence and relative frequency of each
species and/or species groups were described for each Anabat microphone height (5
m and 45 m).
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Table 5.1. Bat Species and Species Groups used to Categorize Acoustic Data
Species/Species
Group
EPFULANO
EPLNLA
LABO
LABOPESU
LACI
LACILANO
LANO
MYLU
MYSE
MYOTIS
PESU
UNKNOWN
Description
Big Brown (Eptesicus fuscus)/Silver-haired (Lasionycteris noctivagans) bat group
Big Brown/Silver-haired/Hoary (Lasiurus cinereus) bat group
Eastern Red bat (Lasiurus borealis)
Eastern Red bat/Tri-colored bat (Perimyotis subflavus)
Hoary bat
Hoary/Silver-haired bat group
Silver-haired bat
Little Brown bat (Myotis lucifugus)
Northern Long-eared bat (Myotis septentrionalis)
Little Brown bat/Northern Long-eared bat group
Tri-colored bat
Includes files with fragmentary calls and files with solely non-search phase calls (i.e.,
approach, feeding buzz, social)
Results
A total of 2,188 bat passes were recorded during July 22-November 22, 2011, with
392 bat passes detected at 45 m and 1,796 bat passes detected at 5 m. At 45m,
average nightly activity resulted in 4.13 ± 0.80 bat passes/night and the hoary bat was
the most commonly detected species. At 5 m, average nightly activity resulted in
22.45 ± 2.88 bat passes/night and the little brown bat was the most commonly
detected species. The overall composition of bat passes classified to species or
species groups is summarized in Table 5.2 below.
Table 5.2. Bat Species Recorded during July 22-November 22, 2011
Species/Species Group
Hoary bat
Little brown/northern long-eared bat group (MYOTIS)
Little brown bat
Big brown/silver-haired bat group (EPFULANO)
Big brown/silver-haired/hoary bat group (EPLNLA)
Eastern red bat
Hoary/silver-haired bat group (LACILANO)
Silver-haired bat
Eastern red/tri-colored bat group (LABOPESU)
Tri-colored bat
Northern long-eared bat
Big brown bat
Total
19
% Composition
5 meters 45 meters
10.03
52.45
25.09
3.15
16.84
1.75
16.75
3.50
11.82
15.38
6.97
9.44
1.45
8.39
3.83
4.90
2.38
1.05
3.06
0.00
1.02
0.00
0.77
0.00
100.00
100.00
Avian and Bat Protection Plan – AWA Goodhue Wind Project
December 15, 2011
Relative proportions of species and species groups were based on the bat passes that
were classified to species and species groups. Unknown bat calls accounted for
33.18% of the 2,188 bat passes detected and these unknown calls were excluded from
the species composition results. Unknown bat calls included fragmentary calls and
files with solely non-search phase calls (see Table 5.1). Unknown calls occur in
every acoustic study of bats, but they often are not reported. Such unknown calls are
typically excluded from analysis in the scientific literature because they cannot be
effectively analyzed (Britzke et al. 2011, Gruver et al. 2010). However, they are
included here in the interest of full discloser because they provide indication of bat
activity. The analysis that follows focuses on the relative proportions of bat calls that
could be classified to species or species groups.
Nightly activity was greatest during July 22 through early September 2011 at both 5
m and 45 m. Hourly bat activity was relatively different between the two heights. At
45 m, activity appeared bimodal with greatest activity earlier in the night (2100-0000
hrs or 9:00 PM-12:00 AM), and was largely attributed to the hoary bat. At 5 m,
activity appeared unimodal with greatest activity in the middle of the night
(2300-0100 hrs or 11:00 PM-1:00 AM), and was largely attributed to the little brown
bat, possibly the northern long-eared bat, the big brown bat, and the silver-haired bat.
Overall, average nightly bat activity was significantly lower at the 45 m height than
the 5 m height. Bat activity at 45 m averaged 81.60% less than at 5 m.
Bat passes assigned to the big brown, northern long-eared, and tri-colored bats were
only detected at 5 m, yet these species may have been detected at 45 m based on bat
passes identified to species groups (i.e., EPFULANO, EPLNLA, MYOTIS, and
LABOPESU). Activity by the eastern red, silver-haired, and little brown bats was
significantly higher at the height of 5 m than at 45 m. Yet, bat activity identified as
hoary bats did not differ significantly between 5 and 45 m.
The hoary bat, a migratory tree-roosting species, was the species most detected,
followed by the little brown bat. The northern long-eared bat and tri-colored bat, both
Minnesota Species of Special Concern, were detected during this study. Although no
federally threatened or endangered bat species were detected, the northern long-eared
bat is being considered for listing under the Endangered Species Act. As of
December 13, 2011, the U.S. Fish and Wildlife Service had not yet determined
whether it will be listed. Both the northern long-eared bat and tri-colored bat were
detected only near ground level. It is possible that the northern long-eared bat was
detected at 45 m, but overlapping call characteristics with the little brown bat made it
difficult to distinguish between the two species. Nonetheless, only 3.15% (n=9) of
the identified calls recorded at 45 m were assigned to the little brown/northern longeared bat group.
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Avian and Bat Protection Plan – AWA Goodhue Wind Project
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Given that the bat detectors were located on a met tower in an open field and that
calls were identified as little brown bats much more frequently than northern longeared bats, it is probable that the majority of the MYOTIS group calls are also
attributed to little brown bats. The northern long-eared bat typically uses forested
areas for both roosting and foraging activity (Caceres and Barclay 2000), whereas the
little brown bat is more likely to occur in open habitats, but does occupy a variety of
habitats (Broders et al. 2004).
6.0 POST-CONSTRUCTION AVIAN AND BAT FATALITY MONITORING
6.1 Number and Selection of Turbines for Monitoring
AWA Goodhue proposes to conduct post-construction fatality monitoring at 10 turbines,
which represents 21 percent of the total number of turbines. This is considered adequate
coverage, as it provides monitoring of one turbine from each of the seven turbine clusters
plus three additional turbines. The turbines selected for monitoring are those which appear
to be in the closest proximity to woodlands and/or wetlands that might afford suitable avian
and bat habitat. The locations of the turbines to be monitored for post-construction fatality
are depicted in Exhibit 9.
6.2 Fatality Monitoring Protocol
Per recommendations from the MDNR, the proposed avian and bat fatality survey protocol
is based on the Minnesota DNR draft protocol for Bat and Avian Fatality Monitoring at
Large Wind Energy Conversion Systems (Mixon et al. 2011) for a moderate risk site. In
accordance with that guidance, AWA Goodhue proposes the following protocol for
monitoring post-construction fatalities:
1. Fatality monitoring will be conducted 2 times per week at 10 turbines (21 percent of
the total turbines) from April 1-November 15 for a minimum of 2 years following
the initiation of commercial operation. Whether additional fatality monitoring is
needed will be determined in coordination with the USFWS and MDNR based on
the monitoring results from the first 2 years;
2. Search transects will be spaced no more than 6 m apart within 160x160 m plots
centered on turbines at a maximum speed of 1 turbine/person/hour;
3. Search areas will be assigned to visibility classes ranging from bare ground to
>25% vegetative cover >1 foot tall. Vegetation control may be applied in the
search plots if needed to increase visibility of carcasses;
4. Carcass removal and searcher efficiency trials will be performed in accordance with
MDNR guidelines;
5. Weather conditions will be recorded at the initiation of each plot search; and
6. MDNR datasheets will be used to document searches and fatalities (Appendix F)
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Searcher efficiency can have a major influence on fatality estimates and their accuracy.
Visibility and searcher efficiency can decline substantially with increasing vegetation
density. Some fatality studies in agricultural environments have involved mowing,
herbicidal, or manual vegetative controls to limit vegetation height and increase carcass
visibility (Jain 2005, Gruver et al. 2009). On the Project, it will be prudent to implement
vegetative control by mowing 6 one-meter wide transects approximately every 2 weeks
during the growing season. The mowed transects will be distributed to cover roughly 33%
of the 160-m x160-m (1 ha) search plots. Exhibit 17 provides a schematic of a 160-m
x160-m search plot with mowed transects.
Visibility classes will be assigned to search areas on a seasonal basis. Carcass removal and
searcher efficiency trials will be distributed temporally and spatially in proportion to the
seasons and visibility classes, respectively. Carcass collection and data recording and
reporting will be in general conformance with DNR protocols, except that data recording
and reporting may be digitally customized and optimized. AWA Goodhue will obtain the
necessary DNR salvage permit and USFWS migratory bird permit prior to commencing
fatality monitoring.
6.3 Fatality Reporting
Fatality monitoring results will be reported to DOC-EFP, USFWS and MDNR using the
MDNR forms and reporting guidelines contained in Appendix F and according to the
schedule described in section 9.0.
7.0 RISK ASSESSMENT
7.1 Overall Avian Community
Overall, avian fatalities at the project are not expected to be a substantial source of avian
mortality in comparison to other factors. The predicted annual avian mortality from wind
turbines is estimated to account for less than 0.01% of the mortality caused by the top eight
anthropogenic causes (Erickson et al. 2005). The proportion of avian fatality attributable to
wind turbines ranked seventh, behind buildings, power lines, cats, automobiles, pesticides,
and communication towers.
Post-construction monitoring of modern wind energy facilities has shown avian fatalities to
be lower than observed during early avian fatality studies. Tubular steel turbines, buried
electrical cables, diligent siting, and other practices have reduced avian fatality rates in the
last 10 to 15 years. Regional average fatality rates at wind farms studied across the U.S.
have ranged from 2.31 birds/MW/year in the Rocky Mountain Region to 3.50
birds/MW/year in the Upper Midwest (National Research Council 2007). Most birds killed
are passerines and the most common passerine fatalities tend to be common species
(Poulton 2010). As discussed below under Section 7.3, many avian species are not
sensitive to displacement by wind turbines. Birds that have been shown to avoid wind
turbines are generally open grassland species, which are adapted to habitats that do not
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exist at Goodhue. AWA Goodhue’s siting of most turbines in agricultural fields is
expected to help minimize avian fatalities.
7.2 Bald and Golden Eagles
The bald eagle is rapidly becoming a relatively common wildlife species in Minnesota and
is not in danger of decline. U.S. Fish and Wildlife Service data indicates that bald eagle
populations increased approximately 20-fold in the lower 48 states between 1963 and
20052 . In Minnesota, the bald eagle breeding population in 2005 was approximately triple
that in 19903 . Bald eagles populations have increased so significantly over the last four
decides that the species was removed from the federal list of threatened and endangered
species on June 28, 20074. Bald eagles have since been removed from the Minnesota
Department of Natural Resources list of threatened and endangered species and reclassified as “special concern”5. As of 2007, the MDNR estimated that Minnesota had
approximately 2,300 breeding pairs of bald eagles. Formal surveys of breeding bald eagles
were discontinued after 20056 so the current breeding bald eagle population is unknown.
However, if previously documented rate of increase has continued (i.e. about 100 percent
increase every 5 years), the current breeding population should be in excess of 4,000
breeding pairs.
As described in Section 8.2.3.3, there has been one documented bald eagle fatality
associated with a wind turbine in North America and four other reported but undocumented
reports of fatalities in the United States. Given that the United States alone has about
43,461 MW of operating wind power facilities7 (which equates to over 25,000 operating
turbines, if the average turbine is 1.5 MW nameplate capacity), this is an extremely small
amount of mortality. One of the primary causes of bald eagle mortality is vehicle collisions
associated with the birds feeding on road-killed deer. In 2008, the Wisconsin DNR
reported recovering about 110 sick, injured, or dead eagles and determined that “…the
leading cause of death was collision with a vehicle. Most vehicle collisions occurred when
eagles were scavenging car-killed deer. Other common causes of eagle mortality include
lead poisoning, electrocution, eagle versus eagle territorial fights, and unspecified wing
injuries.”8 In 2009, the USFWS established an Incidental Take Permit (ITP) program
under the BGEPA. This program was adopted in recognition that eagle “takes” would
inevitably increase with a rapidly expanding eagle population and a continuously
developing landscape.
2
http://www.fws.gov/midwest/eagle/population/chtofprs.html
http://www.fws.gov/midwest/eagle/population/nos_state_tbl.html
4
http://www.fws.gov/midwest/eagle/1999prop/index.html
5
Species of special concern are not protected by Minnesota’s Endangered Species Statute or the associated Rules.
6
http://www.dnr.state.mn.us/rsg/profile.html?action=elementDetail&selectedElement=ABNKC10010
7
http://www.awea.org/learnabout/industry_stats/index.cfm
8
http://www.dnr.state.wi.us/org/land/wildlife/harvest/reports/eagleospreysurv08.pdf
3
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The USFWS provided Westwood with a draft eagle collision risk model (CRM) in Excel
spreadsheet format as a tool to assist in evaluating potential collision risks to bald and
golden eagles at the site. The formulas in this spreadsheet appear to be based on the
collision risk modeling method described in Appendix D of the USFWS Eagle
Conservation Plan Guidance. After studying the draft USFWS model in detail, we have
concluded that it would be more appropriate to apply the Band et al. (2007) collision risk
model to data from the AWA Goodhue project. The primary reason for using the Band et
al. (2007) model is that it has been calibrated through the development of “avoidance rates”
for a number of species while the USFWS draft model has not. Avoidance rates are
calculated by comparing collisions predicted by a CRM to actual collisions documented
through post-operational fatality monitoring. Whitfield (2009) developed an avoidance
rate for golden eagles by comparing Band et al. (2007) CRM results at four U. S. wind
farms to actual injuries and fatalities documented at each. It appears that the draft USFWS
model applies the Whitfield (2009) avoidance factor for golden eagles. However, because
the Whitfield (2009) avoidance factor was based on et al. (2007) CRM output, it would
generate incorrect answers if applied to output from a different model. Whitfield (2009)
states:
“The present study suggests that a 99.0% collision avoidance rate for the golden
eagle is a precautionary estimate, under the CRM of Band et al. (2007). This rate is
not transferable to other CRMs, as noted by Madders & Whitfield (2006), since
other CRMs may involve different assumptions…”
To date, no one has published an avoidance rate for bald eagles, most likely because so few
collisions have been documented. By using the Band et al. (2007) CRM on the AWA
Goodhue project, it will allow an avoidance rate for bald eagles to be developed for the
first time.
Two initial applications of the Band et al. (2007) model were run on the 2011 breeding
season data collected on the AWA Goodhue project site (Appendix G). The first
application used eagle flight observations within five 800 meter radius sample plots
centered on selected observation points. The second application used eagle flight
observations that occurred within 100 meters of the 18 proposed turbine locations that fell
within the five 800 meter radius sample plots. Given that turbine locations are known and
eagle movements in and around the project area are not random (i.e. many movements are
driven by food sources and habitat features), the smaller turbine-specific sample plots
should yield more accurate results than the generic 800 meter radius plots. For example,
many of the eagle movements associated with foraging at the western Belle Creek
Watershed District reservoir were within the 800 meter radius sample plot but never
approached a proposed turbine location.
Based on the more conservative 800 meter radius sample plots, the Band et al. (2007)
model yielded a result of 0.13 collisions per year, which equates to 1 collision every 7.3
years. Based on the more accurate 100 meter turbine-specific sample plots, the Band et al.
(2007) model yielded a result of 0.02 collisions per year, which equates to 1 collision every
43 years. As discussed above, we believe that the latter estimate would be more accurate
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for the breeding season, as it incorporates actual turbine locations and habitat features. We
acknowledge that the breeding season data will not be representative of the remainder of
the year and that we will likely see higher predicted collision rates once we have completed
the collection and analysis of fall migration data. As discussed elsewhere in this ABPP, the
fall migration period data has been seriously compromised by an ongoing, organized eagle
baiting program. Coordination will be undertaken with the USFWS as part of the ITP
process to determine the most appropriate way to deal with this factor in fall migration
season collision rate modeling.
To provide additional context for the above-described breeding season CRM results, we
reviewed the magnitude of predicted collisions to the allowable take in USFWS Region 3,
as set forth in Appendix C of the USFWS’ Final Environmental Assessment (FEA) on the
Proposal to Permit Take under the Bald and Golden Eagle Protection Act (USFWS 2009).
Table C3 of Appendix C provides a permissible annual take threshold for Region 3 of
224.39 individual bald eagles and 28.05 bald eagle territories. Region 3 encompasses the
states of Minnesota, Iowa, Missouri, Wisconsin, Illinois, Michigan, Indiana and Ohio. As
of 2007, the USFWS determined that Minnesota had 1,312 of the 3,475 breeding pairs of
bald eagles in Region 3 (37.76 percent). If this percentage is applied to the allowable take
established for the region forth in Appendix C of the Final EA, the proportion of the
allowable annual take attributable to Minnesota would be 87.73 individual eagles and 10.59
bald eagle territories.
If the collision risks predicted above using the Band et al. (2007) model to breeding season
data reasonably represents future breeding season fatalities, the predicted number of
collisions at the AWA Goodhue Wind Project would represent a minute proportion of the
take allowable for Region 3 and Minnesota’s pro rata portion of that allowable take. The
more conservative prediction of 0.13 collisions per year would represent 0.06 percent (i.e.
0.0006) of the allowable annual take for Region 3 and 0.15 percent (i.e. 0.0015) of
Minnesota’s pro rata portion. If additional eagle flight data at the site continues to show a
reasonable predicted percentage of the annual allowable take for bald eagles, the AWA
Goodhue Wind Project appears to be a suitable candidate for a programmatic incidental
take permit (ITP) under the BGEPA.
It should be noted that collision risk modeling based on field data collected during the 2011
fall migration season cannot fully correct for the above-described eagle baiting program. It
is likely that fall migration period survey results from baited areas will overestimate the
actual collision risk, as compared to the normal, unbaited condition. In analyzing collision
risks based on fall 2011 migration period data, we will apply the Band et al. (2007) CRM
to the full data set and to a refined data set that omits data associated with obvious baiting
activity.
As previously described, Westwood will continue to refine our initial assessments of eagle
collision risk by continuing to apply the Band et al. (2007) model to the results of future
point count data to be collected in 2012. We anticipate that the food base management
program proposed in this ABPP will reduce the collision risk below normal, unbaited
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Avian and Bat Protection Plan – AWA Goodhue Wind Project
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circumstances. This reduction should be reflected in point count data collected and CRM
output generated after the food base management program becomes operational in 2012.
Risk assessment model output will be summarized after each season’s data is collected and
a cumulative collision prediction will be generated for the survey period. Risk assessment
results will be reported to the MPUC, USFWS and MDNR at the completion of survey
period. As stated previously, we will also provide input to the USFWS regarding how the
data collected might contribute to the refinement and validation of collision risk modeling.
As additional data is collected, AWA Goodhue will continue to coordinate with the
USFWS regarding an ITP application and the appropriate magnitude of the allowable take.
Collision modeling results will be used to identify specific turbines or turbine clusters
where additional adaptive management measures may be required. Such measures may
include:
1. Removal of specific transitory food sources (e.g. road kills, carcass piles) that may
be causing foraging flights that place eagles at risk.
2. If eagles are drawn to specific farming operations, coordination with the landowner
to pursue adjustments to the operation to reduce the attraction (e.g. clean up of trash
disposal piles, better composting of dead livestock).
3. Pursuing location-specific habitat modification to reduce perch sites or remove
woody cover for prey species in immediate proximity to the turbine or turbine
cluster where collisions are predicted.
4. Intensified biologist observations of turbines where collisions are predicted to
obtain visual observations of eagle movements to gauge the degree to which
avoidance behavior is occurring.
5. The use of non-moving pylons to simulate the outer edge of a turbine cluster. Such
pylons would need to be designed not to serve as perch sites.
6. If the foregoing measures do not adequately resolve a collision risk predicted by
modeling, temporary curtailment of the nearest turbine in the nearest cluster to the
problematic movement pattern would be undertaken. To avoid diminishing the
barrier effect, this turbine would be slowed rather than shut down.
7. Based on continued biologist observations, such curtailment would cease when the
problematic movements have been resolved.
8. Stepwise expansion of curtailment would only be undertaken if continued risky
flight behavior is observed to be continuing even after all other measures, including
partial curtailment, have been implemented.
Since golden eagles winter but do not breed in Minnesota, the breeding season eagle
monitoring data does not include any golden eagle observations. During 72 hours of point
counts in October and November 2011, two golden eagles were observed. One golden
eagle was soaring, exhibiting normal migratory behavior. The other was attracted to an
active baiting location. These movements, along with any others observed in December
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2011, will be analyzed in the same fashion as bald eagles to generate a collision risk
prediction.
The collision risk to golden eagles is anticipated to be lower than for bald eagles for a
number of reasons. First, there are far fewer golden eagles using the area. Based on
golden eagle winter surveys, a population of about 60 birds is known to winter in
southeastern Minnesota and southwestern Wisconsin1 while, as of 2007, Minnesota had
about 2,300 breeding pairs of bald eagles2. Second, golden eagles winter in Minnesota and
do not breed here. Green and Janssen (1975), indicate that, at the most, golden eagles
spend up to 7 of 12 months in Minnesota (i.e. mid-September to mid-April). This is
corroborated by data from the two golden eagles being tracked by satellite telemetry by
Minnesota Audubon and the National Eagle Center. Third, wintering golden eagles appear
to spend much of their time in goat prairies and timbered rather than on agricultural land.
In contrast, bald eagles breed in Minnesota and are typically present from mid-February
through late December, with some birds staying year round to winter in open portions of
the Mississippi River. As demonstrated by the nest observations and point count data
collected to date for the AWA Goodhue project, breeding eagles will use agricultural land
if food resources and nest sites are available. As compared to bald eagles, the relative
collision risk to golden eagles should be lower because golden eagles: (1) are less common;
(2) do not breed in Minnesota; (3) are present in the state for about 3.5 to 4 fewer months
each year than bald eagles; and (4) focus their wintering activities in habitat types that are
limited in the Project Area.
However, again, the ultimate collision risk to golden eagles will estimated based on field
data and ongoing modeling results. If adaptive management measures are found necessary
to address problematic gold eagle movements, they would be the same measures used for
bald eagles.
7.3 Loggerhead Shrikes
Based on the shrike habitat avoidance strategies employed by AWA Goodhue in designing
its turbine layout, and a review of available loggerhead shrike literature, the potential for
loggerhead shrike collisions with wind turbines on this project is expected to be low.
Several facets of loggerhead shrike ecology and behavior suggest that this species is less
vulnerable to effects from wind energy development than other avian species such as
prairie chickens that inhabit open landscapes with uninterrupted horizons and few
structures.
1
2
http://www.dnr.state.mn.us/eco/nongame/projects/golden_eagle_tracking.html
http://www.dnr.state.mn.us/birds/baldeagle.html
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Information documenting the potential compatibility of wind energy with loggerhead
shrikes and their habitat was presented at national and regional wildlife conferences (Bouta
et al. 2010, Bouta et al. 2010a). Factors that suggest wind energy may not have a
substantial effect on loggerhead shrikes include:
1. Loggerhead shrikes nest and forage in proximity to roads, power lines, fence lines,
and farmsteads. The association of shrikes with roads and structures suggests that
they would be less likely than many avian species to avoid habitats due to the
presence of wind turbines.
2. Loggerhead shrikes nest and often fly much closer to the ground than wind turbine
blades. Shrikes typically nest 1.2-6m above the ground (INHS 2010, Lee 2001).
Keinath and Schneider (2005) indicated most foraging flights are within 10m of
elevated perches, which suggests that most local flights of shrikes are at 16m or
below. Conversely, the rotor-swept height of wind turbines at Goodhue Wind
Project will extend from 38.8 to 121.3m.
3. Loggerhead shrikes have small breeding territories. Such localized habitat use
would tend to reduce the probability of collisions with wind turbine blades,
particularly when most turbines are sited in cropland. The largest territories are
often about 12.6 ha or 31 acres (Kridelbaugh 1982, Porter et al. 1975). Dechant et
al. (2002) indicated territories usually cover about 6-9 ha and can range from 2.7 to
25 ha in the U.S. and Canada.
4. Loggerhead shrikes have relatively low population densities and suitable habitat is
not considered a limiting factor for shrikes in Minnesota, suggesting that shrikes
will have adequate suitable habitat even if wind turbines displace shrikes from some
suitable habitat. Brooks and Temple (1990) found substantial suitable unoccupied
shrike habitat in Minnesota. Roadside surveys of shrikes in Minnesota and Iowa
have found 0.11-0.15 pair/km (Brooks and Temple 1990, DeGeus 1990). A
reasonable maximum shrike population for the project area, based on twice the
density of 0.15 pair/km, would be 1 pair for every 330 ha of quarter-section habitat
ranked 3-5, or 12.6 pairs for the project area. Alternatively, a reasonable habitatbased population potential for the project area would be 1 territory for each quarter
section ranked 3 and 2 territories for each quarter section ranked 4-5, resulting in a
total of 93 potential shrike territories. This suggests that the project area could
include 80.4 suitable unoccupied shrike territories.
As indicated above, loggerhead shrikes may be less likely to be displaced from suitable
habitats on wind projects because shrikes use habitats associated with fences, roads, power
lines, and buildings. The AWA Goodhue team found no literature or documentation
supporting the assertion that shrikes will avoid wind turbines, resulting in displacement of
shrikes from suitable habitats. Although some grassland birds avoid wind turbines, many
do not. Shaffer and Johnson (2008) found that one of five species of grassland birds
avoided wind turbines in North and South Dakota. Although grasshopper sparrows
avoided wind turbines, western meadowlarks, chestnut-collared longspur, and killdeer did
not. Results for clay-colored sparrows were ambiguous. Research at wind projects on the
Buffalo Ridge in Minnesota found small-scale displacement of about 80-100m (Leddy et
al. 1999, Johnson et al. 2000).
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The low flights of loggerhead shrikes may reduce the potential for shrike fatalities due to
collisions with wind turbine blades. A recent avian fatality study in Oregon recorded an
incidental loggerhead shrike observation, but detected no loggerhead shrike fatalities (Enk
et al. 2010). A conversation with a biologist from Western Ecosystems Technology, Inc.
indicated he did not recall any loggerhead shrike fatalities during post-construction fatality
monitoring studies (Thompson 2011).
In a letter dated November 15, 2010, the USFWS suggested that fragmentation of grassland
habitats would have the greatest effect on loggerhead shrikes. However, grasslands in the
project area are already relatively fragmented. Furthermore, the effects of small grassland
patch size on loggerhead shrikes is not well understood (Pruitt 2000). Cultivated cropland
accounts for approximately 60% of the project area. Grasslands, pastures, and hay fields
cover up to half of a square mile in certain areas and account for about 30% of the land
cover in the project area.
AWA Goodhue has avoided and minimized turbine siting in grasslands and near important
nest and perch sites such as scattered solitary trees, tree rows, and eastern red cedars.
Instead, AWA Goodhue sited its turbines in agricultural row-crop fields wherever
practicable. These practices, combined with the low flights, small territories, and low
population densities of loggerhead shrikes, support AWA Goodhue’s expectation that the
potential for loggerhead shrike collisions with wind turbines on this project is low.
7.4 Trumpeter Swans
The recently discovered trumpeter swan nest location is within an impounded farm pond
about 1.8 miles southwest of the nearest proposed wind turbine. The pond involved is
about 2.8 miles northwest of the Zumbro River and has about 1.8 acre of open water and a
fringe of emergent vegetation. The pond lies at the confluence of several grassy drainage
ways and is about 0.35 mile from the nearest road. The following discussion summarizes
the habitat preferences of trumpeter swans, the availability of suitable habitat within and
near the Project Area and the potential risk to swans of turbine collisions.
7.4.1 Trumpeter Swan Habitat Preferences
Trumpeter swans nest in clear, quiet, ponded water bodies (e.g., ponds, lakes,
marshes, sloughs) with relatively static levels, no obvious currents or constant wave
action, and shallow margins that facilitate digging and foraging for the roots and
tubers of aquatic plants (Travsky and Beauvais, 2004). In Montana, trumpeter swans
were observed to nest in extensive beds of marsh vegetation such as sedges,
bulrushes, cattails and Juncus (Belrose, 1978). In Alaska, sedges (Carex spp.) and
horsetails (Equisetum spp.) dominate nesting marshes. Isolation from humans has
been cited as an important factor in nest site selection (Hansen et al. 1971).
Trumpeter swans avoid acidic, stagnant, or eutrophic waters (Mitchell 1994). In
North Dakota, foraging trumpeter swans strongly preferred wetlands with sago
pondweed (Earnst 1994).
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Open flight lanes of at least 100 meters are needed for takeoff and landing, making
small water bodies and forested wetlands unsuitable for nesting habitat (Travsky and
Beauvais, 2004). Nest territory sizes range from 6 to 150 acres (Hansen et al. 1971).
Trumpeter swans build their nests on top of emergent vegetation or small islands,
usually in water less than 1 meter deep. Muskrat (Ondatra zibethicus) and beaver
(Castor canadensis) lodges are often used as nest substrate (Banko 1960; Alaska
Department of Fish and Game 1986; Henderson 1981; Earnst 1994). Non-breeding
birds (typically less than 4 years old) usually gather in small flocks and remain
together throughout the summer on water bodies not occupied by breeding pairs.
The AWA Goodhue Project Area appears to encompass very little habitat potentially
suitable for nesting trumpeter swans. The Project Area does encompass a number of
small impounded farm ponds but most appear unsuitable for trumpeter swan nesting
because they are too small for cygnets to take flight and/or lack emergent vegetation.
These ponds differ from the pond on which the new nest is located. The pond with
the nest is slightly larger, has a fringe of emergent aquatic vegetation and has
sufficient open water (i.e. 1.8 acre) for swans to take flight. The Project Area also
encompasses two larger reservoirs that have sufficient size and open water to support
use by breeding swans but have minimal emergent vegetation for potential nest sites.
There is another reservoir and a farm pond ¼ to ½ mile west of the northwest corner
of the Project Area that could provide suitable nesting habitat for swans. However,
these water bodies are not located between any proposed turbine locations and other
suitable swan habitat. The remaining wetlands in and around the Project Area are
virtually all wet meadows or scrub shrub wetlands located along ditches or drainage
ways. These wetland types lack both open water and aquatic emergent vegetation
that would be suitable for nesting for foraging.
Muskrat houses and beaver lodges that might provide nest sites are similarly scarce.
Due to the paucity of flooded emergent vegetation from which to build houses,
muskrats in the Project Area typically utilize burrows in the banks of water bodies.
Beaver lodges are built from peeled sticks and mud. No beaver lodges have been
observed in open water within the Project Area but lodges likely exist along and
within the banks of the larger reservoirs. It is possible that beaver bank lodges could
be used as swan nest sites but, due to their exposure to predators, would be less
suitable than beaver lodges located in open water away from shore.
During migration trumpeter swans stopover habitat consists of freshwater marshes,
ponds, lakes, rivers, and brackish estuaries (Gale et al. 1987, Lockman et al. 1987,
Bailey et al. 1990). They travel in family groups, and high-quality resting and
feeding sites are especially critical to young birds which cannot travel as far as adults.
Stopover use is limited by ice, forage availability, and disturbances. It is possible that
migrating trumpeter swans could utilize the reservoirs and larger farm ponds as
migration stopover habitat but such use has not been documented in the Project Area
to date. If trumpeter swans are observed moving through the Project Area during
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Avian and Bat Protection Plan – AWA Goodhue Wind Project
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migration period field surveys, we will document any observed flight paths and
attempt to determine whether the swans utilize water bodies or cropland in the area.
Good winter habitat is characterized by open water bordered by level and open
terrain, such as unobstructed snowfields or meadows, which does not impair the
vision or mobility of resting swans (Travsky and Beauvais 2004). Level terrain is
especially important next to smaller water bodies because trumpeter swans need long,
open air lanes for takeoff and landings. During the mild weather of early winter
swans may be widely dispersed, feeding in various water bodies, wetlands, and
flooded agricultural fields. Potential wintering habitat within and near the Project
Area appears to be negligible due to the lack of open water and exposed crop residue
during winter.
7.4.2 Collision Risk to Trumpeter Swans
The risk of a trumpeter swan collision with a wind turbine appears low. The recently
documented nest site is 1.8 miles from the nearest turbine and there are no open water
bodies on the intervening land. No suitable trumpeter swan nesting habitat is
apparent between the nest site and any of the turbines within the Project Area. It is
possible that swans may fly through the Project Area during migration periods.
However, the only specific landscape features that appear to afford potential stopover
habitat are the reservoirs in and adjacent to the northwestern corner of the Project
Area. Harvested crop fields may also be used for foraging during migration periods
but there is no way to predict which fields would be most likely to be used. The crop
planted and harvest dates vary from year to year and such fields are the predominant
landscape feature in an around the Project Area. Which crop fields might receive use
by swans (if any) would depend on conditions on the specific dates that swans might
move through the area.
Assuming the swan nest is active in 2012, the potential collision risk to breeding
swans will be re-assessed after nesting season observations have been completed. In
addition, any observed movements and habitat use of swans during fall, winter and
spring survey periods will be documented and included in the re-assessment of
collision risk.
7.5 Bats
AWA Goodhue has minimized the potential for effects on bats by siting wind turbines
away from woodlands wherever practicable. The primary bat species of concern identified
by the USFWS during a telephone conference on June 9, 2011 is the northern long-eared
bat. On January 21, 2010, the Center for Biological Diversity submitted a petition to the
U.S. Secretary of the Interior to list the eastern small-footed bat (Myotis leibii) and northern
long-eared bat (Myotis septentrionalis) as threatened or endangered under the Endangered
Species Act (Center for Biological Diversity 2010). The petition identified threats to these
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Avian and Bat Protection Plan – AWA Goodhue Wind Project
December 15, 2011
species consisting of white-nose syndrome; agricultural and residential development;
logging; oil, gas, and mineral development; wind energy development; and mine closures.
7.5.1 White-Nose Syndrome
White-nose syndrome has no direct relationship to wind power, but the fatal effects of
this disease on bats has alarmed biologists and exacerbated concerns regarding
potential effects of wind energy on bat populations. White-nose syndrome is a fungus
that grows on the muzzles and wings of affected bats while they hibernate in caves. It
was first discovered in New York State during the winter of 2006-2007. In five years
it has affected nine species of bats, killed more than a million bats of six species,
spread into more than 17 states, and moved as far west as Indiana, Missouri, and
Oklahoma (Bat Conservation International 2011a, 2011b). The potential for whitenose syndrome to reach Minnesota may be limited because bat hibernacula are more
widely dispersed in the Upper Midwest than they are to the south and southeast.
Species with potential to occur in the project area and affected by white-nose
syndrome in include the big brown bat, tri-colored bat, little brown bat, and northern
long-eared bat. Wildlife mortality factors such as white-nose syndrome and collisions
with wind turbines can be either compensatory or cumulative. Because bats have
relatively few offspring and long lives, many biologists suspect that bat mortality
factors are likely to be cumulative or additive rather than compensatory.
7.5.2 Risk of Turbine-Related Bat Fatality
Although some bat fatality is expected to result from collisions with turbines at the
project, review of pertinent bat fatality monitoring studies does not allow prediction
of the precise extent of bat fatality anticipated. Baerwald et al. (2008) suggested that
more bat fatality is caused by barotrauma, a result of air pressure changes around
turbine blades, than collision with turbines.
A compilation of bat fatalities at wind projects across North America (Arnett et al.
2008) indicated that bat fatalities were lowest at wind projects in the Rocky
Mountains and Pacific Northwest regions, and highest in the eastern United States. In
the eastern region where turbines have been placed on forested ridges, fatalities have
averaged 37.0 bats/turbine/year and 37.1 bats/MW/year. Data from Arnett et al.
(2008) indicates that fatalities in the Midwest have averaged 3.3 bats/turbine/year and
4.2 bats/MW/year.
The perceived fatality rate of bats at wind farms has increased as more studies are
published. Prior to 2007, the overall average fatality rate for U.S. wind projects was
estimated at 3.4 bats/turbine/year, and 4.6 bats/MW/year (Johnson 2004). Early
studies indicate most wind farms in grassland and agricultural landscapes tended to
have lower fatality, ranging from 0.74 to 2.32 bats/turbine/year (Erickson et al. 2002,
Johnson 2004).
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Recent studies have shown that bat fatality rates cannot be reliably predicted based on
project area vegetation and topography. Relatively high fatality rates have been
documented in agricultural areas at wind projects in Iowa (8.59 bats per MW per
year, Jain 2005), Wisconsin (24.57 bats/MW/year, Gruver et al. 2009), and Alberta
(10.27 bats/MW/year, Brown and Hamilton 2006). In southern Alberta, two wind
projects located near one another and with similar vegetation and topography had
dramatically different bat fatality rates (Arnett et al. 2008).
The annual peak of bat fatalities at wind projects is correlated with the fall migration
period. Bat fatality at wind farms has been associated primarily with dispersing and
migrating bats, and has typically involved solitary, tree-roosting species such as
Silver-haired, Hoary and Eastern Red Bats (Erickson et al. 2002, Johnson 2004). As
indicated in section 5.6.3, all three of these species were detected in the project area
during the initial month on acoustic monitoring. One national overview indicates that
the Hoary Bat and Eastern Red Bat together account for 64.4% of the bat fatalities at
wind projects (National Research Council 2007). Conversely, the other four species
of bats detected in the project area are susceptible to white-nose syndrome.
8.0 IMPACT AVOIDANCE AND MINIMIZATION
8.1 Overall Avian Community
8.1.1 Pre-Construction
Pre-construction efforts to avoid and minimize avian and bat impacts have focused on
siting turbines on cropland to minimize impacts to forest stands, grasslands and
wetlands that provide suitable habitat for sensitive species birds and bats. Turbines
have been sited to maximize distances to high quality habitats and likely flight
corridors. These avoidance and minimization efforts have been informed by a series
of past and ongoing pre-construction avian and bat studies and surveys described in
sections 3.1.1 and 5.0 of this ABPP.
8.1.2 Construction
8.1.2.1 Minimize Construction Disturbance
Construction practices to be followed by the contractor will be documented in a
manual which will be presented during construction phase environmental
training (see Section 9.1.2). AWA Goodhue will minimize the area of
construction disturbance to the extent practicable. The majority of access road,
turbine pad, and electrical collection line construction will occur within
cultivated agricultural fields. The project design minimizes habitat
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fragmentation and habitat disturbance by virtue of its location in a landscape
dominated by corn and soybean fields. Temporary construction areas that occur
in areas of natural vegetation, such as underground electrical cable routes and
construction crane paths, will be restored to pre-construction contours and
grassland vegetation.
The construction contractor will implement practices to maintain a safe and
orderly construction site during project construction. The potential for wildfire
will be minimized by properly storing petroleum chemicals and clearing
combustible vegetative materials from construction zones where appropriate.
Wildfire is a potential threat that can affect bird and bat habitat. The
accumulation of garbage and related food waste will be limited by use of proper
solid waste disposal activities so that garbage does not attract birds and bats.
The introduction and spread of invasive plant species will be limited by
emphasizing native seed mixes, avoiding unnecessary soil disturbance, and
stabilizing disturbed soils with approved seed mixes or other erosion control
measures as soon as appropriate.
8.1.2.2 Minimize Vegetation Removal
Project construction will minimize clearing of perennial vegetation and
disturbance of potential avian nesting cover. Substantial nesting cover impacts
are not anticipated because the project layout avoids most grasslands. To avoid
and minimize potential effects on grassland nesting birds, areas with planned
grassland disturbance will be mowed or tilled during the late fall or early spring
(outside of the nesting season) so that temporary disturbance areas do not
provide attractive nesting cover.
8.1.2.3 Minimize Wetland Impacts
The Project has been designed to minimize impacts to wetlands. Permanent
wetland impacts were quantified at 0.225 acre. Access road alignments,
collector cable routes and crane paths were refined to avoid wetland impacts
wherever possible.
8.1.3 Post-Construction
8.1.3.1 Minimize Turbine and Facility Lighting
AWA Goodhue will minimize operational turbine lighting to the extent
practicable in an effort to avoid attracting birds and bats to turbines. Lights can
attract and confuse migrating birds (Gehring et al. 2009, Manville 2005, 2009)
and bats sometimes feed on concentrations of insects at lights (Fenton 1997).
The USFWS recommends strobed, strobe-like or blinking incandescent lights,
preferably with all lights illuminating simultaneously, to avoid disorienting or
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attracting birds and bats (USFWS 2010a). The USFWS states that only
minimum intensity, maximum “off-phased” duel strobes are preferred. No
steady burning lights, such as L-810 steady-burning obstruction lights, will be
used. The USFWS recommends use of medium intensity flashing white lights
(L-685) on a previous wind project and the Federal Aviation Administration
(FAA) lists these lights as an option for wind turbines. However, AWA
Goodhue does not propose to utilize such lights because they are substantially
brighter than red lights and more noticeable to humans. The lighting of specific
turbines at the project will be in accordance with FAA standards for cluster
turbine configurations (FAA 2007), which recommend:
1. synchronized flashing red lights (L864);
2. perimeter lighting that defines the periphery of the project with gaps of
no more than 0.5 mile (0.8 km) between lights;
3. lighting gaps of no more than 1 horizontal mile (1.6 km) or 100 vertical
feet (30.5 m) of terrain across the cluster; and
4. lighting of isolated turbines that are distant from cluster groups.
The Goodhue project lighting plan is under review by the FAA and is consistent
with several of the USFWS recommendations. The met towers were approved
for a dual lighting system that consists of red lights for nighttime and medium
intensity flashing red lights for daytime and twilight. This lighting plan will
remain the same when project layout is finalized and alternate turbines are
eliminated.
Lighting of operations, maintenance, and substations facilities will be at a
minimum level for safety and security purposes. Use of motion or infrared light
sensors and switches will be considered to enable lights to be kept off when they
are not required. Lights on the maintenance facility may be shielded to
minimize skyward illumination.
8.1.3.2 Follow APLIC Guidelines for Transmission Lines
The Avian Power Line Interaction Committee (APLIC) has developed practices
for addressing electrocution risk factors and other interactions between birds and
power lines (APLIC 2006). AWA Goodhue will ensure that the transmission
lines connecting its project to the grid are designed in a fashion consistent with
APLIC guidelines. Transmission line engineers are generally familiar with the
design specifications and guidelines developed to reduce the potential for avian
electrocutions. Consequently, modern transmission structure designs are
generally consistent with APLIC recommendations on dimensions and
configurations that reduce the risk of bird fatality.
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8.2 Bald Eagles
8.2.1 Pre-Construction
8.2.1.1 Turbine Siting
To the degree possible, turbines have been sited in open agricultural fields that
have unobstructed views and are away from natural food sources, such as
riparian corridors and streams. The number of turbines has also been reduced by
8 percent from 52 to 48. All turbines have been sited at least one mile from the
nearest bald eagle nest. Neither the current USFWS ECP guidelines nor the
2003 Service Interim Guidance for Avoiding and Minimizing Impacts from
Wind Turbines contain any recommendation for a spatial buffer distance from
bald eagle nests.
8.2.1.2 Continued Bald Eagle Monitoring/Risk Modeling
Point count surveys for bald and golden eagles will be continued, and USFWS
risk assessment modeling results will be updated throughout the pre-operational
phase of the Project.
8.2.1.3 Initiation of Food Base Management
The January 2011 Draft Eagle Conservation Plan Guidance recommends a
number of management practices intended to manage the availability of both
artificial and natural eagle food sources within the footprints of wind power
projects. AWA Goodhue will pursue the following USFWS recommended food
base management measures in conjunction with O & M activities on the Project:
1. If rodents and rabbits are attracted to project facilities, the activities that
may be attracting them will be identified and eliminated.
2. Vegetation or landscape management that might indirectly result in
raptors being attracted to turbine locations (e.g. seeding forbs or
maintaining rock piles that attract rabbits and rodents) will be avoided.
3. Stored parts and equipment, which may be utilized by small mammals
for cover, will be kept away from wind turbines.
4. If fossorial mammals burrow near tower footprints, where feasible on a
case-by-case basis, burrows will be filled and the surrounding pad
covered with gravel at least 2 inches deep and out to a perimeter of at
least 5 feet.
5. Carcasses that have the potential to attract raptors to the Project Area
and, in particular, turbine locations will be immediately removed.
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6. Responsible livestock husbandry will be encouraged among both
participating landowners and neighbors (e.g. removing and properly
disposing of livestock carcasses, fencing out livestock).
7. Artificial and/or natural habitats near turbine locations that attract prey
species may be undertaken if eagles exhibit risky flight behavior after the
forgoing measures are in place.
8. Prey-base enhancements and/or land acquisition and management to
draw eagles out of a project footprint may be undertaken, if eagles
exhibit risky flight behavior after the foregoing measures are in place.
Both of the two new bald eagle nests identified in 2011 were directly associated
with artificial feeding activities involving the disposal of livestock carcasses.
Both new nesting locations are unusual and appear sub-optimal due to their
minimal forest cover, the predominance of surrounding cropland and their
substantial distances to perennial water (and hence, natural food) sources.
Regardless of whether eagles would have nested in these locations naturally,
artificial feeding activity encourages bald eagles to forage and nest in locations
that might otherwise be sub-optimal or unsuitable eagle habitat. It is
inappropriate to encourage bald eagles to become dependent on an artificial food
source that might be discontinued at a critical point in their life cycle. As stated
above, the USFWS Draft ECP Guidance recommends against the improper
disposal of livestock carcasses when it recommends “…responsible livestock
husbandry (e.g. removing carcasses, fencing out livestock)… if grazing occurs
around turbines.”
Exposed surface disposal of livestock carcasses is also illegal in Minnesota
under Minn. Stat. § 35.82, which provides that livestock carcasses must either be
trucked to a rendering facility or buried out of reach of scavengers. The Board
of Animal Health (BAH) is responsible for enforcing this statute. It is also an
acceptable practice to fully compost livestock carcasses using a process
developed and approved by the BAH. Properly composted livestock carcasses
are so decomposed that they do not represent a potential food source for
scavengers.
Road kills also represent a food source for bald eagles, and there is evidence that
some road kills have been disposed of in one or more of the locations used for
livestock carcass disposal. Eagles feed opportunistically on road kills anywhere
they occur, in turn exposing the birds to the risk of being struck by vehicles. In
2008, 2009 and 2010, the Wisconsin DNR analyzed the cases of injury or
mortality for 110, 150 and 120 sick, injured, or dead eagles (Wisconsin
Department of Natural Resources 2008, 2009 and 2010). In each of these years,
the leading cause of death was collision with a vehicle. Most vehicle collisions
were reported to have occurred when eagles were scavenging car-killed deer.
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The 2011 USFWS Draft Eagle Conservation Plan Guidance also recognizes
vehicle collisions as a source of fatalities and recommends immediate removal
of “…carcasses (other than those applicable to post-construction fatality
monitoring; see below) that have the potential to attract raptors from roadways
and from areas where eagles could collide with wind turbines. AWA Goodhue
will undertake a multi-step process to address problems with artificial feeding of
bald eagles and risks posed by eagles feeding on road kills:
1. AWA Goodhue will work directly with landowners who are currently
known or thought to be improperly disposing of livestock carcasses, in
an effort to gain voluntary compliance with Minn. Stat. § 35.82. If
compliance cannot be obtained through informal coordination, the BAH
will be contacted and asked to conduct necessary inspections and, if
appropriate, subsequent enforcement action.
2. AWA Goodhue will work with the BAH, Goodhue County Agricultural
Extension Service and Goodhue County law enforcement to provide
educational resources to landowners regarding proper livestock carcass
disposal techniques.
3. AWA Goodhue will fund the establishment of an appropriately sited and
managed central road kill disposal location that will not attract bald
eagles to the project footprint.
4. AWA Goodhue O & M staff will work with state, county and township
road and law enforcement authorities to encourage and facilitate rapid
pick up and proper disposal of road kills. AWA Goodhue O & M staff
having valid MDNR possession permits may also directly engage in the
removal and disposal of road kills within the Project Area.
8.2.2 Construction
8.2.2.1 Continued Bald Eagle Monitoring/Risk Modeling
Point count surveys for bald and golden eagles will be continued, and USFWS
risk assessment modeling results will be updated throughout the construction
phase of the Project.
8.2.2.2 Construction Phasing to Minimize Disturbance
All of the currently known active bald eagle nests in and around the Project Area
are in excess of one mile from the nearest turbine. Accordingly, no special
construction phasing measures appear to be required to avoid constructionrelated disturbance to eagles during the nesting period.
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8.2.2.3 Continued Food Base Management
The construction management staff for the project will be trained to recognize
likely signs of artificial feeding activity of eagles (e.g. concentrated eagle
movements around farmsteads or locations lacking perennial water, defense of
such locations against turkey vultures, etc.) and report such observations to
AWA Goodhue. Where such activity is observed or suspected, the same
resolution process described in Section 8.2.1.2 will be undertaken. Construction
workers and logistics contractor drivers will also be provided instructions for
immediately reporting road kills to construction management staff, who will
then report them to AWA Goodhue. Road kills will either be removed by AWA
Goodhue staff or will be reported to the appropriate road authority with a
request for rapid pick up and proper disposal at the central disposal facility
described above.
8.2.2.4 Road Kill Minimization in Construction Traffic Plan
AWA Goodhue recently engaged in a study of road structure suitability to
determine which county and township roads are best suited to handle heavy
construction traffic. AWA Goodhue is now in the process of working with
Goodhue County and the townships to develop a plan for construction traffic
routing. AWA Goodhue will include road kill minimization as a factor in this
traffic routing plan. The construction traffic routing plan will include
conservative speed limits for all construction traffic, as well as a road kill
reporting process. All construction staff and drivers of vehicles hauling
equipment and turbine parts will all be provided instructions regarding the rapid
reporting of road kills. Prior to construction, on-site staff and the wildlife
consultant for the project will obtain the necessary possession permits from
MDNR to facilitate the rapid removal and disposition of road kills. Road kill
reporting instructions will provide contact information for these individuals. A
central road kill burial site (to be identified in the construction traffic plan) will
be established either within the Project Area or at a nearby landfill.
The construction traffic plan will be submitted to the USFWS and MDNR for
review prior to issuance to construction staff, the construction contractor and the
logistics contractor.
8.2.3 Post-Construction
8.2.3.1 Continued Bald Eagle Monitoring/Risk Modeling
Point count surveys for bald and golden eagles will be continued, and USFWS
risk assessment modeling results will be updated for two years after the Project
becomes commercially operational.
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8.2.3.2 Continued Food Base Management
After construction is complete, O & M staff will continue monitoring the project
area for likely signs of artificial feeding activity of eagles and will pursue the
same resolution process described in Section 8.2.12. AWA Goodhue will
continue to fund the central road kill disposal location for the life of the project
and O & M staff will continue to report road kills to the appropriate road
authority with a request for rapid pick up and proper disposal at the central
disposal facility described above. Where feasible and appropriate, O & M staff
may pick up and dispose of road kills in the course of their duties to assist road
authorities.
8.2.3.3 Curtailment
Curtailment of wind turbine operation by idling or braking turbines to prevent
blades from spinning has been suggested as a possible mitigation measure to
minimize or avoid impacts to eagles. For the reasons set forth below,
curtailment is considered a last resort measure for reducing turbine collision
risks for bald eagles.
Curtailment as a mitigation tool is typically applied to sites where large-scale
bird activity has been previously identified. A literature and internet search
found no instances where curtailment was targeted specifically towards bald
eagles or any other large avian species in the United States. Examples of sites in
the United States where curtailment is being used include Penascal and Gulf
Wind I Wind Farms, both of which are in the gulf coast in Texas. These
locations have been identified as having high risk of avian mortality due to their
proximity to major avian migration corridors or landscape features that act to
concentrate large numbers of birds during certain weather events or periods of
broad-front migration. These locations are at the south end of the central flyway
and see flocks of thousands of migrating birds. These large flocks are
particularly at risk when migration flights occur at night or during periods when
poor weather limits visibility. The AWA Goodhue project area does not
experience concentrated bird migration movements that approach the magnitude
occurring at these coastal sites.
The USFWS Draft Eagle Conservation Plan (USFWS 2011, page 7) states that
significant numbers of bald eagles have not been documented at U.S. wind
projects. An internet search revealed only one incident of bald eagle mortality at
a wind project in North America – at the Erie Shores facility in Ontario, Canada.
Turbines in this facility are sited in strings rather than clusters and are oriented
parallel to and within 0.25 mile of the Lake Erie shoreline – a landscape feature
that attracts foraging and nesting eagles and funnels their movements during
migration periods. This situation starkly contrasts with turbines sited in clusters
on an agricultural landscape.
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More recently, USFWS staff members have suggested as many as five bald
eagle fatalities associated with North American wind farms. Documentation
regarding these reported fatalities was requested from the USFWS to facilitate
comparison with the circumstances at the AWA Goodhue project site. The
information requested included: (a) which wind projects were involved; (b) at
what time of year did the alleged fatality occur; (c) how close was the collision
site to the nearest eagle nest or other important eagle use area; and (d) contact
information for the developers of these wind farms or their consultants. The
USFWS indicated that it was unable to supply the requested documentation.
Accordingly, other than the Erie Shores fatality, these reports must still be
considered anecdotal and unverified. Even if the correct number of documented
bald eagle fatalities is five, this is still an extremely low number given that more
than 45,000 MW of wind power is currently operational in North America. It is
possible that the extremely low number of bald eagle fatalities is partially a
result of avoidance behavior, described in more detail below.
An important factor that needs to be considered in any decision to curtail
turbines is the fact that some bird species, including bald eagles, appear to
actively avoid moving turbines. This “barrier effect” has been documented in a
number of avian studies around the world (particularly off-shore wind
developments) and is a phenomenon acknowledged by the USFWS. 1 Bald
eagles displayed avoidance behavior after the construction and operation of a 3turbine wind facility in Pillar, Alaska (Kodiak Island), where eagles
discontinued use of previously utilized areas of the mountain ridge in order to
avoid crossing the ridge among the turbines (Sharp et al. 2010). Presumably, the
barrier effect observed around a cluster of turbines would be at least as great as
for three turbines along a ridge. If turbines are shut down, then it is questionable
whether the barrier effect will fade and eagles would start moving through a
turbine cluster they might otherwise avoid. If curtailment is applied to address a
specific movement pattern in a given location, it may be most prudent to curtail
only the turbine nearest the movement rather than the entire cluster. This would
have a similar effect to pylons, which are discussed on page 66 of the USFWS
Draft Eagle Conservation Plan Guidance2, while maintaining motion to preserve
the barrier effect. Pylons could be used prior to undertaking partial curtailment,
in an effort to create the perception of a different turbine cluster boundary and
encourage avoidance behavior. However, the pylons would need to be designed
so as not serve as perches.
For the AWA Goodhue Wind Project it is expected that foraging activities
would represent the largest risk for bald eagles and other raptor species. Food
1
http://www.fws.gov/windenergy/docs/Barrier_Effect.pdf
The USFWS recommend that developers “[c]onsider using pylons at the ends of turbine rows, place pylons in ridge
dips or leave dips undeveloped.”
2
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base management that would remove incentives for eagles to approach or enter
turbine clusters seems to represent the best day-to-day option for collision
prevention. Some food sources are landscape features that cannot be moved
while others are temporary and highly transitory. With food sources that are
immobile, flight patterns are likely to be relatively consistent and siting turbines
away from known movement corridors is the probably the most effective impact
avoidance approach. Using the locations of nests and fixed food sources known
data collected on nest locations AWA Goodhue has done this to the extent
practicable based on applicable turbine setbacks, locations of known nests and
fixed food sources (e.g. the Belle Creek Watershed District Reservoir) and eagle
movement data collected during the breeding season.
With transitory food sources, neither turbine siting nor curtailment offers a
practical approach to preventing collisions. Artificial baiting of eagles in the
Project Area (which has been documented in multiple locations and is ongoing)
and the unpredictable timing and distribution of road kills make it impossible to
predict which turbines would most put eagles at risk on any given day. Because
they are opportunistic feeders, eagle flight patterns will change every time a
food source is introduced or removed. Focusing on the removal of these food
sources would be more effective in preventing collisions than curtailing specific
turbines that may or may not represent a risk. Because flights related to
transitory food sources are unpredictable, curtailment is not a valid mitigation
measure to address them. Effective use of a curtailment program to address
these flights would require real-time knowledge of an individual bird or flock’s
location, flight height, flight speed, flight direction, and a systematic approach to
determine potential for collision with an operational wind turbine.
Avian radar systems are being used at the Penescal and Gulf Wind I Wind
Farms (mentioned above) to curtail turbines when a large number of birds are
identified during broad-front migratory events occurring and weather conditions
impair visibility or concentrate avian activities in high risk areas. While radar
systems have been effective in these types of applications, the technology does
not allow for the identification of a target species and is not an effective
mitigation tool for large raptors, including eagles. Other large avian species,
such as turkey vultures, can and do occur in areas with bald eagles, and current
radar system technology cannot accurately differentiate the reflective signatures
produced by these species. Radar could not be practicably used to inform
curtailment decisions in response to eagle movements.
As described in Section 7.2, AWA Goodhue proposes to use curtailment as a
last resort measure in specific instances when a collision risk identified through
modeling or field observations cannot otherwise be satisfactorily resolved.
Curtailment would be pursued if: (1) field survey and/or collision modeling
results indicate a collision risk problem that would cause AWA Goodhue to
potentially exceed a take threshold set forth in an ITP and (2) all other measures
listed in Section 7.2 fail to reduce the predicted collision risk below that
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threshold. After all other measures have failed to resolve a turbine-specific
collision risk, temporary curtailment of the nearest turbine in the nearest cluster
to the problematic movement pattern would be undertaken. To avoid
diminishing the barrier effect, this turbine would be preferably slowed rather
than totally shut down. Based on continued biologist observations, such
curtailment would cease when the problematic movements have been resolved.
Stepwise expansion of curtailment would only be undertaken if ongoing surveys
or collision risk modeling continues to indicate a collision risk that would cause
an ITP threshold to be exceeded. Ongoing coordination will be maintained with
the USFWS regarding updated survey and modeling results and measures being
taken to avoid exceeding a take threshold.
8.3 Golden Eagles
The impact avoidance, minimization and adaptive management measures applicable to bald
eagles will apply to golden eagles as well. These are described in Sections 7.2 and 8.2.3.
Through ongoing pre-operational point counts, we will develop a better picture of the
collision risk to golden eagles. Westwood will also maintain ongoing coordination with
Minnesota Audubon and the National Eagle Center to obtain and analyze the satellite
telemetry data being collected of radio-tagged golden eagles. If any radio-tagged golden
eagles utilize the project footprint, information will be assessed and included in the
monthly monitoring reports. Like bald eagles, golden eagles will scavenge livestock
carcasses and road kills. Accordingly, the prey-base management measures described for
bald eagles would apply equally to golden eagles. These measures are intended to foster
reliance on natural food sources, which in turn would be associated with higher quality
habitats away from proposed turbine locations.
8.4 Loggerhead Shrikes
8.4.1 Pre-Construction
Throughout the site permit process, AWA Goodhue revised its turbine layout a
number of times to reduce potential environmental and human impacts associated
with the project. In addition to moving individual turbine locations to avoid and
minimize impacts, AWA Goodhue also reduced the overall number of proposed
turbine locations from 52 to 48 by switching from the GE 1.5 MW turbine model to
the GE 1.6 MW turbine.
AWA Goodhue’s primary strategy for protecting loggerhead shrikes was to avoid
highly and very highly suitable shrike habitat through its micro-siting process. Given
the connected nature of wind energy infrastructure (turbine arrays, access roads, cable
routes, crane paths), some minor effects on potential shrike habitats are expected.
Implementation of mitigation measures is expected to aid in minimizing potential
effects on shrikes.
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8.4.1.1 Turbine Layout Revisions to Minimize Effects
A proactive approach to siting turbines and related improvements increased the
compatibility of the project with loggerhead shrike habitat. AWA Goodhue
adjusted turbine locations to avoid highly suitable and very highly suitable
loggerhead shrike habitat. Between October 21, 2010 and June 30, 2011,
proposed turbine locations were revised several times, and a number of turbines
were moved out of suitable habitats into habitats ranked unsuitable to minimally
suitable. Turbines proposed in higher quality habitats (ranks 3-5) were shifted
within those areas to avoid habitat features that contribute to high suitability
rankings. Avoidance of suitable shrike habitat was balanced against multiple
constraints that affected acceptable turbine siting locations, including landowner
acceptance, property boundary setbacks, residence setbacks, wind resources,
raptor nest setbacks, wetlands, cultural resources, construction feasibility, site
access, telecommunications signals, radar, and aircraft flight navigation.
However, even given these other constraints, only three turbine locations are in
highly or very highly suitable habitat based on the coarse filter habitat model.
Closer review using a turbine-centered habitat model indicates that all three of
these turbines are sited in cropland. None of the turbines meet the criteria of the
turbine-centered model for highly suitable shrike habitat, which include:
1. area within a 40-meter radius is dominated by grassland,
2. area within a 200-meter radius is over 40% grassland, and
3. perches exist on over 40% of the area within a 200-meter radius.
The following is a summary of recent additional layout changes designed to
avoid quality shrike habitat.
After the June 13, 2011 field investigation, the following turbines were
eliminated or moved to minimize potential effects on loggerhead shrikes:
Turbine 16 was eliminated from the layout because it was located in grassland
within a quarter section ranked very highly suitable for loggerhead shrikes.
Turbine 28 was renamed Alt-28 and moved 1,025 feet south-southeast to a
location of disturbed land along a field road because it was located in grassland
within a quarter section ranked very highly suitable for loggerhead shrikes.
After meeting with the MDNR and MDOC on August 18, 2011, the following
turbine location adjustments were made to minimize potential effects on
loggerhead shrikes:
1. Turbine Alt-28 was eliminated because it was located in an area of grazed
grassland within a quarter section ranked very highly suitable for
loggerhead shrikes.
2. Turbine 6 was moved 735 feet south-southeast, increasing the distance
from a 15-acre grassland within an unsuitable ranked quarter section
from 60 feet to 340 feet.
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8.4.2 Construction
Turbines have all been sited in locations that do not provide highly or very highly
suitable shrike habitat. Accordingly, construction activities associated with turbines
are expected to have little to no effect on shrikes. As access roads and collector cable
routes have also been designed to avoid and minimize effects on highly suitable
shrike habitats. If any access roads or collector cables routes coincide with shrike
breeding locations that may be noted during avian surveys, routes will be modified or
construction timing staged to avoid or minimize disturbance to the birds during
nesting.
If construction activities will occur between April and July within 200 meters of
habitat considered “Highly Suitable” or “Very Highly Suitable” by the MDNR, preconstruction loggerhead shrike surveys will be conducted in those areas to determine
whether breeding shrikes are present. Based on a review of the turbine layout and
shrike habitat rankings, only turbines 17 and 18 lie within areas ranked “Highly
Suitable” or “Very Highly Suitable” for shrikes and appear to be within 200 meters of
the habitat that generated these rankings. Turbines 25, 26 and A52 lie within areas
ranked “Highly Suitable” or “Very Highly Suitable” for shrikes but appear to be more
than 200 meters of the habitat that generated these rankings.
Construction activities will be staged to avoid causing a potential disturbance-related
“take” of loggerhead shrikes. Coordination will be undertaken with the MDNR to
review the final plans for the project, confirm the boundaries of potentially sensitive
shrike breeding habitat near the turbines mentioned above and will obtain
concurrence on site specific activities and time periods that must be avoided if
breeding shrikes are observed. The results of this coordination will be reported at the
Preconstruction Meeting to ensure contractor awareness of the sensitive areas. If
possible, construction activity in such areas will be staged to avoid the April-July
period entirely. If construction in such areas is proposed during this time period, such
construction will not be commenced until it has been confirmed that breeding shrikes
are not present.
8.4.3 Post-Construction
AWA Goodhue avoided effects on loggerhead shrikes through siting turbines almost
exclusively in crop fields and away from highly suitable shrike habitat. The turbine
layout has been modified multiple times in response to MDNR input and the MDNR
has formally concurred that all turbines are sited in a manner that avoids highly and
very highly suitable shrike habitat. Accordingly, the implementation of additional
mitigation measures will be balanced with other ecological mitigation measures
discussed in this plan.
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AWA Goodhue is considering several mitigation measures to help fill knowledge
gaps regarding shrike ecology and maintain and enhance loggerhead shrike habitats.
Various sources contributed to the development of the practices listed below,
including but not limited to Dechant et al. (2002), Pruitt (2000), and WDNR (2011).
Implementation of the following additional mitigation measures will depend upon
construction timing, wildlife agency assistance, and landowner relations:
1. Keep fence lines intact to the extent practicable.
2. Record any loggerhead shrikes observed during point counts conducted for
continued monitoring of bald eagle activity in the project area.
3. Report observed loggerhead shrikes and/or shrike nesting activity, if any, to
the MDNR Natural Heritage Program.
4. Record locations of incidental loggerhead shrike observations in relation to
turbine locations during post-construction avian fatality monitoring.
5. Consider implementing a program of periodic behavioral observations to
assess the risk to any breeding shrikes that may be detected in the vicinity of
wind turbines.
6. Educate landowners on measures that enhance loggerhead shrike habitat,
including: periodic burning or mowing of ungrazed grasslands to discourage
succession to woodland and maintain open grassland with scattered small
trees and shrubs; rest-rotation grazing to provide preferred habitat by
shortening tall grasslands; tree and shrub nest site and perch site protection
from grazing and rubbing by livestock; use of fencing or other methods to
protect old shelterbelts and nest trees from cattle; planting or protecting low
shrubs and trees along fences and in otherwise open pastures and fields;
maintaining and diversifying shelterbelts adjacent to grassland by
incorporating thorny trees and shrubs; and avoiding creation of continuous
linear strips of woody vegetation.
8.5 Trumpeter Swans
Trumpeter swans were considered extirpated in Minnesota as of the mid-1800s due to
overhunting. Through recovery efforts, Minnesota now supports 2,400 free-flying
trumpeter swans. However, continued threats to the trumpeter swan population in
Minnesota include loss or degradation of wetland habitat, lead poisoning, power line
collisions, and illegal shooting. Lead poisoning is the primary man-induced cause of
trumpeter swan mortality. It is estimated that lead poisoning from ingestion of lead shot
and fish sinkers is responsible for more than half of the mortality of Midwestern trumpeter
swans (Gillette and Shea 1995). Powerline collisions are a less prevalent, but still
important, source of trumpeter swan mortality. Of 75 trumpeter swan deaths recorded from
1958 to 1973, 19% of the fatalities were due to powerline collisions (Weaver and St. Ores
1974).
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At this time, the potential for construction disturbance or turbine collision risk to trumpeter
swans from the AWA Goodhue Wind Project is considered low, given that; (1) only one
breeding pair has been documented in the general area; (2) the nest site is outside the
Project Area and is 1.8 miles from the nearest turbine; and (3) no proposed turbine
locations lie between the nest site and other potentially suitable aquatic foraging habitat.
The MDNR species profile for trumpeter swans describes their nesting habitat as follows:
“During the breeding season, trumpeter swans select small ponds and lakes
or bays on larger water bodies with extensive beds of cattails, bulrush,
sedges, and/or horsetail. Ideal habitat includes about 100 m (328 ft.) of open
water for take-off, stable levels of unpolluted, fresh water, emergent
vegetation, low levels of human disturbance, and the presence of muskrat
(Ondatra zibethicus) houses and American beaver (Castor canadensis)
lodges for use as nesting platforms.”
http://www.dnr.state.mn.us/rsg/profile.html?action=elementDetail&selected
Element=ABNJB02030
No suitable trumpeter swan nesting habitat, as described by the MDNR, has been observed
within the AWA Goodhue Project Area. Potential breeding season foraging habitat for
trumpeter swans is likewise extremely limited within the Project Area. The only water
body observed within the project area that might offer swans a foraging opportunity is the
reservoir in the northwest part of the Project Area. However, this water body lacks
emergent vegetation and does not appear to offer any suitable nesting opportunities for
trumpeter swans. Trumpeter swans do forage in crop fields during the migration periods.
Row crops are the predominant land cover in and around the Project Area and crops change
from year-to-year. Accordingly, while it is possible that the swans utilizing the recently
documented nest site could utilize the Project Area for foraging, it is not possible to predict
what areas they might use or during what time periods. If crops fields within the Project
Area are used for fall foraging, it is likely that such use would be transitory and short-term.
Given the above factors, it appears unlikely that any specific impact avoidance,
minimization or adaptive management measures specific to swans will be necessary.
However, this conclusion will be re-visited during the spring and fall of 2012 after more
data has been collected on the movements of nesting and migrating swans (assuming they
return to nest in the same area). If that data suggests that impact avoidance, minimization
or adaptive management measures might be warranted, such measures will be explored in
coordination with MDNR. Specific examples of impact avoidance, minimization or
adaptive management measures that might be explored under such circumstances are:
1. If the nest is active in 2012, route construction traffic away from roads nearest the
nest location;
2. If the nest is active in 2012, stage construction activity in the southwest corner of
the Project Area to avoid the trumpeter swan nesting period;
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3. Install bird diverters on the interconnection transmission line at the north end of the
Project Area. While this will not traverse any potentially suitable aquatic habitat,
foraging or migrating swans could potentially pass through this area en route to the
Mississippi River;
4. While existing electric distribution lines in the immediate area of the nesting pair
are unrelated to the AWA Goodhue Wind Project, additional bird diverters could be
installed on lines in that area to minimize the potential for collisions;
5. With the permission of the landowner, signs could be posted around the known
nesting location to alert humans that swans might be present and must not be
disturbed or shot; and
6. If trumpeter swans are observed foraging in crop fields near turbines during the
migration periods, temporary activities could be employed to divert the birds to
crop fields farther from turbines.
Again, whether any of the above adaptive management measures might be necessary will
be determined based on 2012 field survey data and coordination with MDNR and USFWS.
Any decision to undertake such measures will be communicated to the MPUC prior to
being undertaken. Also, if temporary activities are needed to divert swans from crop fields
near turbines, USFWS will be contacted in advance to obtain any necessary depredation
permit. For the reasons set forth in Section 8.2.2.3 with regard to bald eagles, curtailment
is not considered a practicable adaptive management with regard to trumpeter swans.
8.6 Raptor Nests
8.6.1 Pre-Construction
Throughout the design of the Project, efforts have been made to site turbines 0.25
mile or more from active raptor nests. With the current turbine layout, all proposed
turbine locations are more than 0.25 mile of raptor nests. The raptor nest nearest to a
turbine is 0.37 mile away. During the March 2012 aerial raptor nest survey, we will
determine if any new nests have been built closer than 0.25 mile from a turbine. If
any such nests are found, Westwood will coordinate with USFWS and MDNR to
discuss whether the birds using the nest appear to be at risk and, if so, the best
management approach. If the habitat between the nest and the turbine consists
entirely of cropland, no management may be necessary. If suitable habitat exists
around the turbine such that foraging raptors may be attracted to it, AWA Goodhue
may pursue habitat modification to minimize its attractiveness to prey species. As a
last resort, removal of such nests at a time when they are inactive may encourage any
returning raptors to build in locations farther from the turbine.
8.6.2 Construction
No construction-related impact avoidance or minimization measures are proposed for
turbines more than 0.25 mile from the nearest raptor nest. For the three turbines that
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lie within 0.25 mile of possible raptor nests, if nests are left in place, construction will
be staged and conducted in a manner that will minimize disturbance to raptors during
the nesting period. Potential examples of such measures would include:
1. Monitor the activity status of each nest to determine whether any impact
minimization measures are necessary and, if so, for how long;
2. Stage construction activity within 0.25 mile of active nests so as to avoid the
period when the nest is active; and
3. Route construction traffic away from roads nearest the nest location to the
maximum degree possible during the active nesting period.
8.6.3 Post-Construction
After construction is complete, O & M personnel will monitor the area around each
turbine and document any observed raptor nesting activity. If new nests are observed,
they will be visited to confirm whether they are raptor nests and GPS located to
determine whether they are within 0.25 mile of a turbine. If so, the presence and
location of the nest will be included in the next post-construction fatality monitoring
report submitted to the agencies. If any post-construction raptor fatality occurs that
appears attributable to a nearby nest, coordination will be undertaken with the
USFWS and MDNR to determine whether the nest should be removed during a
period when it is inactive.
8.7 Bats
8.7.1 Pre-Construction
AWA Goodhue designed the project to avoid and minimize effects on bats and bat
habitats to the extent practicable. Turbine siting avoids woodland habitats preferred
by many bat species by up to 2,500 feet and an average of 777 feet. Land cover
mapping indicates the project area is only about 4% forested. Although turbine siting
avoids woodlands, the woodlands that do exist in relative proximity to proposed
turbines consist mostly of small woodlots, tree lines, and farmstead shelterbelts that
are not large enough to appear as forest land on land cover mapping.
8.7.2 Construction
Project construction will avoid and minimize disturbance of preferred bat habitats and
roost sites such as woodlands, water bodies, wetlands, caves, and rock formations.
Because turbines are sited in open areas and primarily in cropland, woodlands will be
disturbed only where necessary for construction of access roads and electrical
collection cables.
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8.7.3 Post-Construction
AWA Goodhue has implemented turbine siting and construction practices that will
continue to help avoid and minimize effects on bats after construction. Postconstruction monitoring of bat fatalities will help expand understanding concerning
the variability of bat fatalities at wind projects and assess the potential need for postconstruction impact minimization practices.
8.7.4 Potential Federal Listing of Northern Long-eared Bat
Westwood will contact the Twin Cities Field Office of the USFWS on a monthly
basis to obtain updates on the federal listing status of the Northern Long-eared Bat.
The Federal Register and USFWS Region 3 web-site will also be monitored regularly
for updates. If this species is listed under the Endangered Species Act (ESA), we
anticipate that it would occur after all required permits in place and the project is
either under construction or built and operational. If listing occurs, AWA Goodhue
would undertake informal coordination with the USFWS to discuss the perceived risk
of a “take” of this species and whether a Habitat Conservation Plan and ESA
Incidental Take Permit (ITP) are warranted. Because the AWA Goodhue project
would not involve a federal action, we do not see any basis for Section 7 consultation
under the Endangered Species Act.
If the Northern Long-eared Bat becomes federally listed, additional surveys would be
needed to determine which portions of the project area are being used by this species.
Potential adaptive management strategies will be developed on a turbine-by-turbine
basis. Surveys would likely include mist netting and additional Anabat monitoring.
Potential adaptive management strategies would be developed through coordination
with the USFWS and could include: (1) enhancement and/or preservation of roosting
and foraging habitat in parts of the project site away from turbines; (2) identification
and preservation of potential hibernacula in the area; and (3) turbine-specific
operational measures, such as increasing turbine cut-in speed in higher risk locations
(i.e. where surveys indicate bats are present and foraging in the RSZ) during higher
risk conditions (i.e. during night time hours, temperatures above 50 degrees, high
humidity and low wind). If operational mitigation measures are found necessary,
they would be subject to periodic adjustment based on fatality monitoring results and
coordination with the USFWS.
9.0 ABPP IMPLEMENTATION
9.1 Training
AWA Goodhue believes that employee and contractor training is an important aspect of
implementing the ABPP for the Project. Consequently, AWA Goodhue staff involved in
the daily implementation, planning and engineering process for the project will be trained
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in the specific requirements of the ABPP and in avian and bat issues that are of concern on
the AWA Goodhue Project site. Some staff members, particularly those implementing the
ABPP, may receive external training courses on avian and bat identification, protection
planning and practices to reduce collision fatality or risk of electrocutions. AWA Goodhue
ABPP training will include the following components:
9.1.1 Development Stage Environmental Training
Wind project development team members who have been involved in the design and
permitting of the AWA Goodhue Wind Project have received informal training in the
avian and bat issues associated with the Project Area. Certain issues have arisen or
evolved during the development and permitting process, making such training an
ongoing, iterative process. Throughout the design and permitting processes, there has
been ongoing coordination among the developer, construction contractor, project
team design engineers and environmental professionals and wildlife agency staff
members to ensure that avian and bat issues described in this ABPP have been
properly addressed in the design of and construction planning for the project.
However, because the preparation of this ABPP is occurring near the conclusion of
the project design and permitting processes, no formal development stage ABPP
training courses have occurred or are being proposed.
9.1.2 Construction Stage Environmental Training
All construction staff will receive training on the environmental constraints and issues
specific to the site, including sensitive habitats to be avoided (such as buffers around
raptor nests or habitat of sensitive species) and how they are marked in the field,
practices to minimize impacts to wildlife (such as project-specific speed limits), and
procedures for handling injured or dead birds and other wildlife. Materials to support
this training will include maps showing sensitive areas to be avoided. As they are
most familiar with the avian and bat issues associated with the Project Area,
construction stage training will be provided by the wildlife biologists responsible for
pre-operational surveys and studies and who prepared this ABPP. Training materials
will be provided to USFWS and MDNR biologists for advance review and agency
biologists will be invited to attend and participate in the construction stage training
session(s).
9.1.3 Operations Stage Environmental Training
Training in the key components of this ABPP will be part of the training provided to
each new operations staff within 90 days of hire. In addition, all operations contractor
staff who operate the AWA Goodhue Wind Project and remote operations staff will
be trained as well. This training will include a general orientation to state and federal
wildlife laws and procedures for handling and reporting dead or injured birds.
Training in bird and bat identification will be provided, with emphasis on state and
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federally listed species. Materials to support this training will include a flowchart
showing how dead or injured birds and bats should be handled, as well as projectspecific posters showing species that are of particular conservation concern or that
have special status that may be present at the site. Again, operations stage training
will be provided by the wildlife biologists who provided construction stage training.
Again, training materials will be provided to USFWS and MDNR biologists for
advance review and agency biologists will be invited to attend and participate in the
operations stage training session(s).
It should be noted that all formal surveys, fatality monitoring and report preparation
activities will be performed by trained biologists and not O & M staff. The purpose
of operations stage environmental training is to facilitate proper documentation and
reporting of O & M staff observations during the day-to-day operation of the wind
farm. A Special Miscellaneous Permit will be obtained from the USFWS for any
staff member who will be handling the carcasses of migratory birds.
9.1.4 External Training:
Operations and Maintenance (O & M) staff may receive future training on avian
protection planning and practices or specific wildlife management techniques. Such
training is offered by the Avian Power Line Interaction Committee (www.aplic.org)
and occasionally by state and federal wildlife agencies. Refresher courses on bird and
bat identification may also be warranted for O & M staff to ensure accurate
characterization and reporting of fatality incidents.
9.2 Quality Control and Adaptive Management
9.2.1 Quality Control
Compliance with this project-specific ABPP will be reviewed and audited by AWA
Goodhue on an annual basis. Audit information will be supplied to DOC-EFP and
the MPUC for review and will be e-filed to the docket for the project. Any noted
deficiencies and recommendations will be addressed through corrective action plans,
which will be implemented on a schedule that matches the urgency of the deficiency.
A corrective action plan may be recommended by AWA Goodhue based on audit
results but the decision whether such a plan is required would be made by the MPUC
with DOC-EFP input. A corrective action plan would set forth: (1) the specific
actions needed to correct the identified deficiency; (2) a schedule for completing
those actions; (3) the parties who would be responsible for implementing those
actions; and (4) the process for confirming that the corrective action has adequately
addressed the deficiency. If a corrective action plan becomes necessary, it would sent
to DOC-EFP and the MPUC for review and, after approval, progress would be
reported on a quarterly basis and progress reports would be e-filed to the project
docket.
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Annual audits will be carried out to ensure that: (1) ABPP compliance is satisfactory;
(2) O & M staff members have adequate training and training materials; (3) that avian
and bat fatality incidents are being properly documented and reported. AWA
Goodhue will continually seek to improve plan performance, study protocols, and
mitigation approaches to reduce future wind-related wildlife risks and update the
ABPP to the extent necessary.
9.2.2 Adaptive Management
Adaptive management:
“… involves exploring alternative ways to meet management objectives,
predicting the outcomes of alternatives based on the current state of
knowledge, implementing one or more of these alternatives, monitoring
to learn about the impacts of management actions, and then using the
results to update knowledge and adjust management actions. Adaptive
management focuses on learning and adapting, through partnerships of
managers, scientists, and other stake-holders who learn together how to
create and maintain sustainable resource systems.” (USDOI, 2009)
Adaptive management strategies that would be pursued by AWA Goodhue have been
described throughout this ABPP. Specific adaptive management strategies for the
species discussed in this plan are discussed in the sections applicable to each species.
If adaptive management is found necessary (e.g. collision risk modeling predicts
more eagle fatalities than allowed under an ITP), specific measures to be undertaken
will be developed in coordination with DOC-EFP, USFWS and MDNR and will only
be implemented with agency concurrence. Also, as the process of documenting and
reporting on monitoring and fatality results proceeds, AWA Goodhue will continually
look for ways to streamline and improve the process. If the USFWS and/or MDNR
develop electronic procedures for fatality reporting, AWA Goodhue will work with
the agencies to adopt and implement the new reporting procedures.
9.2.3 Avian and Bat Reporting to MPUC, DOC-EFP, USFWS and MDNR
9.2.3.1 Eagles
The results of spring, summer, fall, and winter eagle point count surveys will be
reported quarterly within one month after the end of each season for two years.
The activity status of each bald eagle nest identified in or within two miles of
the Project Area will be reported in the spring report for two years.
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9.2.3.2 Bats
Anabat data collection will occur on one temporary met tower from July 22 to
November 22, 2011 and on one or two permanent met towers from May 1 to
November 15, 2012. The results of the 2011 and 2012 Anabat monitoring and
federal listing status of Northern Long-eared Bat must be submitted to MPUC
by December 15, 2011 and 2012, respectively.
9.2.3.3 Loggerhead Shrike
Because all turbines have been sited in locations that do not constitute highly or
very highly suitable loggerhead shrike habitat, no Loggerhead Shrike Protection
Plan is required. If any loggerhead shrike fatalities are found during postconstruction fatality surveys or during the course of O & M activities, it will be
reported to the MPUC, USFWS and MDNR within 24 hours of discovery (as
required by the Site Permit).
9.2.3.4 Trumpeter Swans
If any trumpeter swans fatalities are found during post-construction fatality
surveys or during the course of O & M activities, it will be reported to the DOCEFP, MPUC, USFWS and MDNR within 24 hours of discovery (as required by
the Site Permit).
9.2.3.5 Informal Avian and Bat Injury Fatality Reporting
Observations of avian and bat injuries or fatalities in the normal course of O &
M activities are to be reported through the informal avian and bat injury and
fatality reporting procedure using the Wildlife Incident Reporting Form, which
includes turbine number, date fatality or injury was discovered, species of bird
or bat involved and other relevant information (Appendix H). All informal
reports will be emailed to DOC-EFP, MPUC, USFWS and MDNR, with
electronic and paper copies kept on file by the site manager and the project
wildlife consultant. Individual wildlife incident reports will not be e-filed to the
project docket. Such observations are separate and distinct from those collected
during formal avian and bat fatality surveys. In order to ensure accurate and
timely reporting of wildlife fatalities, all informal reporting will be done within
24 hours through the project wildlife consultant and AWA Goodhue Site
Manager. O & M staff will thus be relieved of the responsibility of definitively
confirming the species of bird or bat killed and the appropriate reporting time
frame under the MPUC Site Permit.
There are three types of proposed reporting for avian and bat fatality: (1) 24hour reporting of certain fatality events; (2) quarterly reporting of avian and bat
fatalities observed during day-to-day O & M activities on site; and (3) reporting
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of fatality survey results over the first two years of operation. These reporting
requirements are described in more detail as follows:
24-Hour Reporting
If any of the following occur during the course of site activities during facility
operations, the occurrence will be reported to the MPUC, USFWS and MDNR
within 24 hours of discovery:
1. Five or more dead or injured non-protected avian or bat species within a
reporting period (i.e. within a quarter);
2. One or more dead or injured migratory avian or bat species (including
any species of eagle);
3. One or more dead or injured state threatened, endangered or special
concern species; or
4. One or more dead or injured federally listed species.
“Non-protected” avian species have been assumed to include non-native species
such as European starlings and house sparrows and non-migratory species that
are not otherwise protected as threatened or endangered (e.g. non-migratory
game birds). All native migratory bird species will be treated as “protected”.
Quarterly Fatality Reporting
Avian and bat fatalities observed by the AWA Goodhue Site Manager or O & M
staff in the course of their duties on the wind farm must be reported on a
quarterly basis. Again, these reports are separate from reporting of the results of
more intensive fatality surveys described below. Quarterly reports on day-today avian and bat fatality observations are due on January 15, April 25, July 15
and October 15 of every year for the life of the Site Permit. Reports are to
include species of dead or injured bird or bat species found, location of find by
turbine number, date of find, potential cause of fatality and any steps taken to
avoid future occurrence. Quarterly reports will reported to the DOC-EFP,
MPUC, USFWS and MDNR by email and will be e-filed to the project docket.
9.2.3.6 Formal Fatality Survey Result Reporting
As described previously in this ABPP, fatality surveys will be conducted two
times per week at 10 turbines for the first two years of project operation. The
results of these surveys will be reported quarterly on January 15, April 25, July
15 and October 15 for the first two years of facility operation. An annual report
will be also be submitted with the January 15th quarterly summary and will use
the format provided in the MDNR Fatality Report Guidelines (Appendix F of
Mixon et al, 2011).
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9.3 Key Resources
AWA Goodhue will develop a list containing names, contact information and
responsibilities of key development team members and agency staff to facilitate
communication and reporting throughout the life of the ABPP. This list will be distributed
at least 10 days prior to at the pre-construction meeting.
10.0 PROJECT DECOMMISSIONING
Prior to commercial operation, AWA Goodhue will submit a Decommissioning Plan to the
MPUC that documents the manner in which AWA Goodhue anticipates decommissioning the
project in accordance with Minn. Rules Part 7854.0500, subp.13. AWA Goodhue will ensure
that it carries out its obligations to properly decommission the project at the appropriate time.
Upon expiration of the Site Permit or termination of project operation, whichever occurs earlier,
AWA Goodhue will dismantle and remove from the site towers, turbine generators, transformers,
overhead and underground cables, foundations, buildings and ancillary equipment to a depth of 4
feet. Access roads will be removed unless written approval is given by the affected landowner
requesting that one or more roads, or portions thereof, be retained. Any agreement for removal
to a lesser depth, or for no removal, will be recorded with the county and will show the locations
of all foundations. In accordance with the Site Permit, the site will be restored within 18 months
after expiration. The project will be considered a discontinued use after 1 year without energy
production unless a plan is developed and submitted to the MPUC outlining the steps and
schedule for returning the project to service.
AWA Goodhue will restore and reclaim the site to its pre-project topography and topsoil quality
using BMPs consistent with those outlined by the Wind Turbine Guidelines Advisory Committee
(WTGAC 2010). The goal of decommissioning will be to restore natural hydrology and plant
communities to the greatest extent practical while minimizing new site disturbance and removal
of native vegetation.
Some of the decommissioning BMPs that will be employed on the project to the extent
practicable with the intent of meeting this goal include:
1. restore topsoil to assist in establishing and maintaining preconstruction native plant
communities to the extent possible;
2. vegetate exposed soils, that are not agricultural land, with native plants appropriate for
the soil conditions and adjacent habitat using local seed sources;
3. restore surface water flows to pre-disturbance conditions, including removal of stream
crossings, roads, and pads, consistent with storm water management objectives and
requirements;
4. install erosion control measures, following decommissioning, within disturbance areas
with potential for erosion, consistent with storm water management requirements; and
5. remove fencing installed for the project unless pertinent to existing landowner operations.
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11.0 LITERATURE CITED
Alaska Department of Fish and Game. 1986. Alaska habitat management guide: life histories
and habitat requirements of fish and wildlife. Alaska Department of Fish and Game,
Juneau, Alaska, USA.
APLIC (Avian Power Line Interaction Committee). 2006. Suggested Practices for Avian
Protection on Power Lines: The State of the Art in 2006. Edison Electric Institute,
APLIC, and the California Energy Commission. Washington, D.C. and Sacramento, CA.
Arnett, E.B., J.P. Hayes, and M.M.P. Huso. 2006. An Evaluation of the Use of Acoustic
Monitoring to Predict Bat Fatality at a Proposed Wind Facility in South-central
Pennsylvania. An annual report submitted to the Bats and Wind Energy Cooperative. Bat
Conservation International. Austin, TX.
Arnett, E. B., K. Brown, W. P. Erickson, J. Fiedler, T. H. Henry, G. D. Johnson, J. Kerns, R. R.
Kolford, C. P. Nicholson, T. O’Connell, M. Piorkowski, and R. Tankersley, Jr. 2008.
Patterns of bat fatalities at wind energy facilities in North America. Journal of Wildlife
Management 72(1):61-78.
Baerwald, E.F., G.H. D'Amoour, B.J. Klug & R.M.R. Barclay. 2008. Barotrauma is a significant
cause of bat fatalities at wind turbines. Current Biology 18:695-696.
Bailey, T.N., M.F. Porter, E.E. Bangs, W.W. Larned, R.A. Richey, and R.L. Delaney. 1990.
Summer and migratory movements of trumpeter swans using the Kenai National Wildlife
Refuge, Alaska. Page 91 in D. Compton (editor). Proceedings and Papers of the 11th
Trumpeter Swan Society Conference. Trumpeter Swan Society, Maple Plain, Minnesota,
USA.
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Avian and Bat Protection Plan – AWA Goodhue Wind Project
December 15, 2011
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64
© 2011 Westwood Professional Services, Inc.
Legend
Project Area
Proposed Turbine Locations
(As of 8/19/2011)
Proposed AlternateTurbine Locations
(As of 8/19/2011)
S
"
)
19
Proposed Permanent Met Towers
Existing Met Tower
S
"
)
Proposed Interconnect Substation
Proposed Substations
Proposed Laydown
Yard Options
Municipality
Trunk Highway
Road
County Hwy 1
3 2
1
Proposed
Substation
and O&M
Building
A49
M1
17 18
19
16
4
5
8
7
A50
9
6
County Hwy 6
15
20
10
12
Met
24
11
21
13
22
14
23
County Rd 47
County Hwy 7
M2
Goodhue
County Hwy 9
27
26
29
30
ty
un
Co
Proposed
Substation
Proposed Laydown
Yard Options
A52
y
Hw
35 36 37
A51
8
38 39
28
25
32 33
58
34
County Hwy 16
31
County Rd 50
52
40
42
43
47
48
44
45 46
41
Map Document: (P:/20081147/gis/Post_Permit/Post ALJ/20081147proj01B_loc.mxd)
12/15/2011 9:41:15 AM
52
Zumbrota
Data Source(s): MNDOT (2010); ESRI (2009); AWA Goodhue (2011); Westwood (2011).
AWA Goodhue, LLC
±
Goodhue County, Minnesota
Miles
0
1
MPUC Approved Project Area and Proposed Facilities
Exhibit 1
© 2011 Westwood Professional Services, Inc.
Project
!
!! !
!
!
! !!
!
!
!! !
!
!
!
!
!
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!
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!!!
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!!
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Legend
Map Document: (P:/20081147/gis/20081147site01A_buffer.mxd)
9/29/2011 1:01:37 PM
!
Proposed Turbine Locations
Approximate Operational
Project Boundary
Two Mile Buffer Surrounding
Operational Project Boundary
Used in Wildlife Surveys
Data Source(s): USGS (2011), Westwood (2011), MN DNR (2008)
AWA Goodhue, LLC
Goodhue County, Minnesota
±
Miles
0
2
Approximate Operational
Project Boundary
EXHIBIT 2
Map Document: (P:/20081147/gis/Post_Permit/Post ALJ/20081147nest02B_BAEA2011.mxd)
12/15/2011 8:09:46 AM
© 2011 Westwood Professional Services, Inc.
County Rd 51
!
.
325th St
3 2
ty Hw
y1
A49
1
220th
175th Ave
C oun
165th Ave
White Ro
ck Tr
County Hwy 1
!
.
19
17 18
16
4
5
350th St
Tr
Wh
e
at
352nd St
ay
W
ve
A
360th St
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h
!
.
17
360th St
165th Ave
15
10
362nd St
11
12
20
24
21
13
22
14
23
370th St
!
.
!
.
County Hwy 9
Goodhue
!
.
!
.
385th St
29
30
35 36 37
A51
390th St
A52
Stat e Hw
38 39
28
25
32 33
y 58
135th Ave
171
County Rd 47
County Hwy 7
26
190th Ave
st A
ve
370th St
27
County Hwy 6
7
A50
347th St
9
6
180th Ave
8
34
400th St
400th St
County Rd 50
!
.
County Hwy 16
31
40
410th St
410th St
42
43
47
48
44
ry
165th Ave
ar
Qu
52
St
o
ne
wy
420th St
200th Ave
420th St
Tr
41
190th Ave
420th St
US
H
46
County Hwy 6
45
!
.!
.
Zumbrota
Project Area
Proposed Turbine Locations
(As of 8/19/2011)
Proposed AlternateTurbine Locations
(As of 8/19/2011)
Municipality
2011 Nest Observations
!
.
!
.
Nest Active or Presumed Active:
- Nest active in 2010 and 2011
- Nest constructed and active in 2011
!
.
Alleged Bald Eagle nest
in this vicinity does not exist
or is Red-tailed Hawk nest
Bald Eagle Point Count Plots
Nest Inactive:
- Nest constructed in 2011 but inactive
- Nest active in 2010; inactive in 2011
Township Boundary
Road
Data Source(s): USDA AFPO NAIP (2009), MnDNR PLSS (1980), MnDOT Basemap (2010), AWA Goodhue (2011) and Westwood (2011).
±
AWA Goodhue, LLC
Goodhue County, Minnesota
Miles
0
1
Bald Eagle Nests and Monitoring Clusters
Exhibit 3
Map Document: (P:/20081147/gis/2011Eagles/June-July Monitoring/Results/Loc1-Turbs10-14.mxd)
12/15/2011 7:45:24 AM
© 2011 Westwood Professional Services, Inc.
Proposed Turbine Locations
(As of 8/19/2011)
100-m Buffer of Proposed Turbines
!
.
Monitoring Observation Point
800-meter Radius
Approximate Flight Altitude
Below RSH ( < 38.75m)
15
Within RSH (38.75 - 121.25m)
Above RSH ( >121.25m)
Wh
ea
tT
r
Road
10
362nd St
362nd St
CSAH 7
11
12
145th Ave
!
.
13
14
370th St
Cluster 1: 32 hours of monitoring in June-July 2011.
One flight observed - an immature (2nd or 3rd year bird) thermaling
very high with 2 Red-tailed Hawks.
There were no flights below or with the RSH observed at this location.
Additionally, observed flights did not overlap proposed turbine clusters.
±
0
Feet
800
Data Source(s): AWA Goodhue (2011) and Westwood (2011).
Note: Eagle flight path observations are approximate. Flight
locations and altitudes were estimated using landscape features
and known heights of towers. Observers monitored from a fixed
location. Every effort was made to have the best view possible in
all directions; however, terrain and landscape features reduced
visibility in some areas. Flight paths were recorded on this map
view. In some cases, eagles were observed outside the map view,
however, those flights were distant to the monitored turbine clusters.
AWA Goodhue, LLC
Goodhue County, Minnesota
2011 Breeding Season Bald Eagle Monitoring
Results - Turbine Cluster 1
EXHIBIT 4
Map Document: (P:/20081147/gis/2011Eagles/June-July Monitoring/Results/Loc1a-Turbs2-8.mxd)
12/15/2011 7:46:08 AM
© 2011 Westwood Professional Services, Inc.
Proposed Turbine Locations
(As of 8/19/2011)
1
100-m Buffer of Proposed Turbines
!
.
2
Monitoring Observation Point
Approximate Flight Altitude
Below RSH ( < 38.75m)
3
ve
135th A
800-meter Radius
Within RSH (38.75 - 121.25m)
4
Above RSH ( >121.25m)
Road
5
8
6
9
CSAH 7
347th St
7
!
.
352nd St
15
Cluster 1A: 14.5 hours of monitoring in August 2011.
Four flights observed - two adult and two juvenile flights.
A portion of one flight was within the RSH while gaining altitude and
lasted only a few minutes.
Generally, eagles were observed thermaling and soaring very
high at this location.
362nd St
±
0
Feet
800
Data Source(s): AWA Goodhue (2011) and Westwood (2011).
Note: Eagle flight path observations are approximate. Flight
10
locations and altitudes were estimated using landscape features
and known heights of towers. Observers monitored from a fixed
location. Every effort was made to have the best view possible in
all directions; however, terrain and landscape features reduced
visibility in some areas. Flight paths were recorded on this map
view. In some cases, eagles were observed outside the map view,
however, those flights were distant to the monitored turbine clusters.
AWA Goodhue, LLC
Goodhue County, Minnesota
2011 Breeding Season Bald Eagle Monitoring
Results - Turbine Cluster 1A
EXHIBIT 5
Map Document: (P:/20081147/gis/2011Eagles/June-July Monitoring/Results/Loc2 -Turbs26-28.mxd)
12/15/2011 7:47:14 AM
© 2011 Westwood Professional Services, Inc.
Proposed Turbine Locations
(As of 8/19/2011)
St
0th
7
100-m 3Buffer
of Proposed Turbines
!
.
Monitoring Observation Point
800-meter Radius
Approximate Flight Altitude
Below RSH ( < 38.75m)
Within RSH (38.75 - 121.25m)
Above RSH ( >121.25m)
Road
CS
AH
8
CSAH 9
27
26
!
.
135th Ave
390th St
±
0
Feet
800
Data Source(s): AWA Goodhue (2011) and Westwood (2011).
Cluster 2: 58.5 hours of monitoring during June-August 2011.
A52
Fifteen flights observed - all were adults.
A portion of four flights were within the RSH while gaining altitude
either to or from the reservoir. Observed flight paths did not overlap
proposed turbine clusters.
Eagles were routinely observed flying to and from the reservoir from
the north and are likely the Belle Creek nest pair. Most flights were
low and direct to and from perches along the reservoir tree line.
Note: Eagle flight path observations are approximate. Flight
locations and altitudes were estimated using landscape features
and known heights of towers. Observers monitored from a fixed
location. Every effort was made to have the best view possible in
all directions; however, terrain and landscape features reduced
visibility in some areas. Flight paths were recorded on this map
view. In some cases, eagles were observed outside the map view,
however, those flights were distant to the monitored turbine clusters.25
AWA Goodhue, LLC
Goodhue County, Minnesota
2011 Breeding Season Bald Eagle Monitoring
Results - Turbine Cluster 2
EXHIBIT 6
Map Document: (P:/20081147/gis/2011Eagles/June-July Monitoring/Results/Loc3 -Turbs35-39.mxd)
12/15/2011 7:48:00 AM
© 2011 Westwood Professional Services, Inc.
Proposed Turbine Locations
(As of 8/19/2011)
CSAH 9
100-m Buffer of Proposed Turbines
!
.
Monitoring Observation Point
800-meter Radius
Approximate Flight Altitude
Below RSH ( < 38.75m)
Within RSH (38.75 - 121.25m)
Above RSH ( >121.25m)
Road
37
180th Ave
35
36
390th St
!
.
38
39
Cluster 3: 54.5 hours of monitoring during June-August 2011.
Twenty-nine flights observed - twenty-six adult and three
juvenile flights.
A portion of four flights were within the RSH while gaining altitude.
Observed flight paths within the RSH did not overlap proposed
turbine clusters.
Generally, observed flights at this location were low and local flights
in the vicinity of a farmstead on the east side of 180th Avenue.
400th St
±
0
Feet
800
Data Source(s): AWA Goodhue (2011) and Westwood (2011).
Note: Eagle flight path observations are approximate. Flight
locations and altitudes were estimated using landscape features
and known heights of towers. Observers monitored from a fixed
location. Every effort was made to have the best view possible in
all directions; however, terrain and landscape features reduced
visibility in some areas. Flight paths were recorded on this map
view. In some cases, eagles were observed outside the map view,
however, those flights were distant to the monitored turbine clusters.
AWA Goodhue, LLC
Goodhue County, Minnesota
2011 Breeding Season Bald Eagle Monitoring
Results - Turbine Cluster 3
EXHIBIT 7
Map Document: (P:/20081147/gis/2011Eagles/June-July Monitoring/Results/Loc4 -Turbs45-49.mxd)
12/15/2011 7:48:45 AM
© 2011 Westwood Professional Services, Inc.
Proposed Turbine Locations
(As of 8/19/2011)
100-m Buffer of Proposed Turbines
!
.
Monitoring Observation Point
800-meter Radius
Approximate Flight Altitude
410th St
Below RSH ( < 38.75m)
Within RSH (38.75 - 121.25m)
Above RSH ( >121.25m)
Road
42
48
47
46
45
!
.
St
on
e
Q
ua
rr
y
Tr
420th St
41
165th Ave
Cluster 4: 50.5 hours of monitoring during June-August 2011.
Five flights observed - four adult and one juvenile flights.
A portion of one flight was within the RSH while gaining altitude
after harassing a Red-tailed Hawk.
Generally, observed flights at this location were very high soaring
flights where the adults would drift north after gaining altitude over
the North Fork of the Zumbro River (out of the monitoring mapping
extent).
±
0
Feet
800
Data Source(s): AWA Goodhue (2011) and Westwood (2011).
Note: Eagle flight path observations are approximate. Flight
locations and altitudes were estimated using landscape features
and known heights of towers. Observers monitored from a fixed
location. Every effort was made to have the best view possible in
all directions; however, terrain and landscape features reduced
visibility in some areas. Flight paths were recorded on this map
view. In some cases, eagles were observed outside the map view,
however, those flights were distant to the monitored turbine clusters.
AWA Goodhue, LLC
Goodhue County, Minnesota
2011 Breeding Season Bald Eagle Monitoring
Results - Turbine Cluster 4
EXHIBIT 8
Map Document: (P:/20081147/gis/2011Eagles/June-July Monitoring/Results/Avian_PostCon_Monitoring.mxd)
12/15/2011 7:50:27 AM
County Rd 51
© 2011 Westwood Professional Services, Inc.
325th St
2
3
ty Hw
y1
A49
1
19
4
17 18
5
A50
347th St
9
6
350th St
Tr
Wh
e
at
352nd St
W
ve
A
h
360th St
4t
!
.
17
360th St
ay
165th Ave
15
10
20
362nd St
24
11
12
21
County Hwy 6
7
16
180th Ave
8
220th
175th Ave
C oun
165th Ave
White Ro
ck Tr
County Hwy 1
!
.
13
22
14
23
370th St
27
Goodhue
171
s
County Rd 47
County Hwy 7
tA
ve
190th Ave
370th St
County Hwy 9
!
.
26
385th St
29
36 37
35
A51
30
390th St
135th Ave
Stat e Hw
A52
28
25
38 39
y 58
32 33
34
400th St
400th St
County Hwy 16
!
.
County Rd 50
31
40
410th St
410th St
42
43
47
48
44
420th St
200th Ave
St
o
Project Area
165th Ave
ar
Qu
52
ne
wy
420th St
ry
Tr
41
190th Ave
420th St
US
H
County Hwy 6
45 46
!
.
Proposed Turbine Locations
(As of 8/19/2011)
Proposed AlternateTurbine Locations
(As of 8/19/2011)
Municipality
Road
!
.
Zumbrota
Active Bald Eagle Nest in 2011
Bald Eagle Point Count Plots
Post-construction Fatality Monitoring Turbine
Post-construction Fatality Monitoring Plot
(160m by 160m)
!
.
Trumpeter Swan Nest
Data Source(s): USDA AFPO NAIP (2009), MnDNR PLSS (1980), MnDOT Basemap (2010), AWA Goodhue (2011) and Westwood (2011).
±
Miles
0
1
AWA Goodhue, LLC
Goodhue County, Minnesota
Bald Eagle Point Count Plots, Post-construction Fatality Monitoring
Turbines, and Trumpeter Swan Nesting Site
Exhibit 9
© 2011 Westwood Professional Services, Inc.
Project
!
!! !
!
!
! !!
!
!
!! !
!
!
!
!
!
! !
!
!
! !
!
!
!
!
!
!!!
!
!
!!
!
!
!
!!
!
!
!
!
!
! !
!!
!
Legend
!
Proposed Turbine Locations
Map Document: (P:/20081147/gis/20081147flt01A.mxd)
12/15/2011 9:49:30 AM
Helicopter Survey Transect
Two Mile Buffer Surrounding
Proposed Project Boundary
Data Source(s): USGS (2011), Westwood (2011), MN DNR (2008)
AWA Goodhue, LLC
Goodhue County, Minnesota
±
Aerial Survey Transects
Miles
0
2
EXHIBIT 10
© 2011 Westwood Professional Services, Inc.
325th St
AH
CS
1
150 Ave Way
175th Ave
165th Ave
CSAH 7
White Rock Rd
t
135
335th St
Cart Rd
White Rock Tr
Lo
uis
Tr
Note: All roads within two-mile buffer of project
area will be driven and visually inspected.
340th St
hA
ve
347th St
CR-52
360th St
362nd St
370th St
180th Ave
Way
370th St
375th St
375th St
CSAH 9
CSAH 6
120th Ave
362nd St
171st Ave
124 Ave
t
360th S
190th Ave
Wh
ea
tT
r
355th St
145th Ave
St
350th
350th St
352nd St
400th St
CR-50
400th St
390th St
CSAH 7
AH
CS
135th Ave
390th St
8
410th St
410th St
Two-mile project area buffer
52
S
430th St
52
Data Source(s): USGS (2011), Westwood (2011), MNGeo (2011)
H
440th St
Map Document: (P:/20081147/gis/20081147rd01A.mxd)
12/15/2011 7:55:51 AM
420th St
T
US
r
dT
oo
w
r
e
Sh
Tr
M-93
US
TH
ne
to
rry
ua
Q
165th Ave
420th St
190th Ave
415th S
t
AWA Goodhue, LLC
Goodhue County, minnesota
±
0
Miles
1.75
Road Survey Routing
EXHIBIT 11
© 2010 Westwood Professional Services, Inc.
Project Area
Proposed Turbine Locations
(As of 8/19/2011)
Proposed AlternateTurbine Locations
(As of 8/19/2011)
See Exhibits 10, 11, 12 For Additional Detail*
A49
1
3 2
4
19
16
Habitat Rank
0 - Unsuitable
1 - Minimally Suitable
5
8
17 18
A50
2 - Slightly More Suitable
6 9
3 - Moderately Suitable
7
4 - Highly Suitable
5 - Very Highly Suitable
15
20
10
11
24
21
12 13
22 23
14
27
29
26
A52
30
35 36
A51
28
37
38 39
25
32 33
34
31
40
42
43
Map Document: (P:/20081147/gis/Post_Permit/Post ALJ/20081147losh01A_2011.mxd)
12/15/2011 7:58:32 AM
44
47
45
48
46
41
±
0
Miles
1.25
Data Source(s): AWA Goodhue (2011) and Westwood (2011).
*Note: WTGs located in very highly suitable and
highly suitable shrike habitat based on the
coarse habitat model (WTGs 7, 18, 25 26, A52)
are located in cropland (see Exhibits 10,11 and 12).
AWA Goodhue, LLC
Goodhue County, Minnesota
Loggerhead Shrike Coarse Filter Habitat Model
(August 19, 2011)
Exhibit 12
© 2011 Westwood Professional Services, Inc.
Map Document: (P:/20081147/gis/Post_Permit/Post ALJ/20081147HSI_16_18.mxd)
12/15/2011 8:00:49 AM
16
Turbine
Eliminated
(Grassland)
17
(Cropland)
18
(Cropland)
Legend
Project Area
Habitat Rank
3 - Moderately Suitable
HSI Boundary
0 - Unsuitable
4 - Highly Suitable
Proposed Turbine Locations
1 - Minimally Suitable
5 - Very HighlySuitable
ProposedTurbine Eliminated
2 - Slightly More Suitable
Data Source(s): AWA Goodhue (2011) and Westwood (2011).
AWA Goodhue, LLC
Goodhue County, Minnesota
±
Field Review Turbine Cluster A
0
Feet
400
Exhibit 13
© 2011 Westwood Professional Services, Inc.
26
(Cropland)
Map Document: (P:/20081147/gis/Post_Permit/Post ALJ/20081147HSI_26_28.mxd)
12/15/2011 8:01:57 AM
28
Turbine
Eliminated
(Grassland)
Legend
Project Area
Habitat Rank
3 - Moderately Suitable
HSI Boundary
0 - Unsuitable
4 - Highly Suitable
Proposed Turbine Location
1 - Minimally Suitable
5 - Very Highly Suitable
Proposed Turbine Eliminated
2 - Slightly More Suitable
Data Source(s): AWA Goodhue (2011) and Westwood (2011).
AWA Goodhue, LLC
Goodhue County, Minnesota
±
Field Review Turbine Cluster B
0
Feet
400
Exhibit 14
© 2011 Westwood Professional Services, Inc.
A52 (Cropland)
Map Document: (P:/20081147/gis/Post_Permit/Post ALJ/20081147HSI_25_52.mxd)
12/15/2011 8:02:54 AM
25 (Cropland)
Legend
Habitat Rank
Project Area
3 - Moderately Suitable
HSI Boundary
0 - Unsuitable
4 - Highly Suitable
Proposed Turbine Locations
1 - Minimally Suitable
5 - Very Highly Suitable
2 - Slightly More Suitable
Data Source(s): Westwood (2011) and AWA Goodhue, LLC (2011).
AWA Goodhue, LLC
Goodhue County, Minnesota
±
Turbine-Centered Habitat Model Review
0
Feet
400
Exhibit 15
Map Document: (P:/20081147/gis/Post_Permit/Post ALJ/20081147bat01B_110824.mxd)
12/15/2011 8:45:42 AM
© 2011 Westwood Professional Services, Inc.
Legend
Project Area
!
(
Proposed Turbine Locations (As of 8/19/2011)
!
(
Proposed AlternateTurbine Locations (As of 8/19/2011)
#
*
#
*
Proposed Permanent Met Towers - 2012 Bat Monitoring
Existing Met Tower - 2011 Bat Monitoring
Direction and Distance to Nearest Woodland*
Municipality
Trunk Highway
Road
2006 Land Cover Data (% Within Project Area)
County Hwy 1
Open Water (0.1%)
Low Intensity Residential (2.4%)
High Intensity Residential (1.4%)
Commercial/Industrial/Transportation (<0.01%)
#
*
!
(
!
(
!
(
!
(
Bare Rock/Sand/Clay (<0.01%)
!
(
!
(
!
(
Forest (3.9%)
!
(
!
(
Grassland/Herbaceous (19.5%)
Pasture/Hay (12.3%)
!
(
!
(
!
(
Row Crops (60.3%)
Woody Wetlands (<0.01%)
!
(
!
(
Emergent Herbaceous Wetlands (<0.01%)
!
(
!
(
County Hwy 6
!
(
#
*
!
(
!
(
!
(
!
(
!
(
!
(
!
(
!
(
County Rd 47
County Hwy 7
#
*
!
(
Goodhue
County Hwy 9
!
(
!
(
!
(
!
(
!
(
!
(
!
(
!
(
!
(
!
(
!
(
!
(
!
(
!
(
!
(
58
!
(
County Hwy 16
!
(
County Rd 50
!
(
!
(
!
(
!
(
!
(
!
(
!
(
!
(
!
(
52
Zumbrota
Data Source(s): USGS National Land Cover Database (2006); MNDOT (2010); ESRI (2009); AWA Goodhue (2011); Westwood (2011).
±
AWA Goodhue, LLC
Goodhue County, Minnesota
0
Feet
4,500
*Note: Some woodlands may not be visible on this
map due to the coarse resolution of dataset.
Land Cover and
Bat Monitoring Locations
Exhibit 16
2
4
6
8
10
12
14
16
18
20
22
24
26
28
30
32
34
36
38
40
42
44
46
48
50
52
54
56
58
60
62
64
66
68
70
72
74
76
78
80
82
84
86
88
90
92
94
96
98
100
102
104
106
108
110
112
114
116
118
120
122
124
126
128
130
132
134
136
138
140
142
144
146
148
150
152
154
156
2
4
6
8
10
12
14
16
18
20
22
24
26
28
30
32
34
36
38
40
42
44
46
48
50
52
54
56
58
60
62
64
66
68
70
72
74
76
78
80
82
84
86
88
90
92
94
96
98
100
102
104
106
108
110
112
114
116
118
120
122
124
126
128
130
132
134
136
138
140
142
144
146
148
150
152
154
156
158
160
AWA Goodhue Wind Project Turbine-Centered Fatality Seach Plot (160 x 160 m)
Search Transect
0
4
8
12
16
20 m
AWA Goodhue, LLC
Goodhue County, Minnesota
Fatality Search Plot Schematic
Exhibit 17
158
160
Appendix A: Site Selection Factors
Siting wind turbines is an iterative process that balances a number of factors, including site
control, wind speeds, turbine characteristics, environmental concerns and community and
landowner considerations. When siting the project, AWA Goodhue worked to place wind
turbines on the most productive and efficient sites and avoid or minimize environmental and
other impacts. A key to achieving this goal was first to select a project area that is compatible
with wind development. AWA Goodhue selected the original project boundaries for a number of
reasons, including the following:
Wind Resource
Wind speeds in the Project Area show a strong wind resource that supports a commercially
viable wind project. The United States Department of Energy (DOE) and the Minnesota
Department of Commerce (DOC) have conducted wind resource assessment studies in
Minnesota for more than twenty years, and, since 2006, the DOC has produced wind speed maps
for Minnesota. In the project vicinity, the mean annual wind speeds are mapped as 13.7 to 17.7
miles per hour (mph) (6.14 to 7.95 meters per second) at 80 meters above ground and 15.3 to
19.0 mph (6.83 to 8.50 m/s) at 100 meters above ground, both of which support commercial
wind projects. In addition to reviewing publicly available wind data, AWA Goodhue installed a
temporary meteorological tower within the project boundary to gather onsite wind data. Using
over a year of onsite data gathered at this location, AWA Goodhue has prepared estimated
energy production calculations using the proposed turbine layout. These calculations confirm
that the area has a strong wind resource that supports the project’s viability.
Participant interest
AWA Goodhue has signed wind lease and easement agreements and participation agreements
with over 200 landowners in the project footprint, representing approximately 12,000 acres of
site control. Much of the land signed into the project is cropland used for corn and soybeans.
The available leased area provides sufficient land area to site the proposed 48 turbines while still
meeting the setback and other conditions of the MPUC site permit.
Availability of Transmission Capacity
For new renewable energy generation to be brought to market, available transmission
infrastructure needs to already exist or new transmission must be built. The study, engineering,
and permitting process for new transmission infrastructure takes many years and sometimes
decades. For the state to meet its renewable energy goals, it makes sense to try and first develop
renewable resources that have access to existing available transmission infrastructure.
The location of this project was selected in part to take advantage of existing transmission
infrastructure that could accommodate additional energy generation without the need for
significant system upgrades. By siting the project at this location, AWA Goodhue is able to add
76.8 additional MWs of wind energy to Minnesota’s system without building significant
additional transmission lines.
Environmental Setting
Most of the project area is agricultural land. Land cover mapping for the project area was
obtained from the U.S. Geological Survey National Land Cover Database. Cultivated cropland
consisting primarily of corn and soybeans is the predominant land cover and accounts for
approximately 60% of the project area. Grasslands, pastures, and hay fields cover up to half of a
square mile in certain areas and account for about 31.8% of the land cover in the project area.
Wetlands are scattered throughout and primarily isolated around intermittent streams. There are
221 wetlands that cover approximately 319 acres in the project area (< 1% of the project area).
Woodlands are limited primarily to farmsteads that are scattered throughout the area and some
ravines and hillsides in the western and northeastern portions of the project area.
AWA Goodhue designed the boundaries of this project to exclude sensitive environmental
features and wildlife habitat as much as practicable. There are no DNR WMAs, SNA, WPAs,
State Parks or State Forests within the boundary. A portion of the Douglas State Trail lies within
the project boundary but lies at least 1,760 feet (1/3 mile) from the nearest proposed turbine.
Appendix B. Acronyms and Abbreviations Used in ABPP
Table 1.1: Definitions of Acronyms and Abbreviations used in this ABPP
Abbreviation
ABPP
APLIC
AWA
Goodhue
AWEA
BGEPA
BMPs
BOP/EPC
CRP
EFP
ESA
FAA
FSA
ft
HCP
kW
LWECS
m
MBTA
MDNR
MESA
MPUC
MW
NHIS
NRCS
Definition
Avian and Bat Protection Plan, described above.
Avian Power Line Interaction Committee, a nonprofit organization of utilities
and resource agencies that develops educational resources, research, and
management options designed to reduce avian interactions with utilities.
AWA Goodhue, LLC, a Minnesota limited liability company
American Wind Energy Association, a national trade association representing
wind power project developers and others involved in the wind industry.
United States Bald and Golden Eagle Protection Act, see Section 1.3 below.
Best Management Practices are activities designed to minimize effects of
development and land management on the natural environment, including
erosion control and storm water management practices.
Balance of Plant/Engineering Procurement and Construction, a term used to
describe the general construction contractor or the final planning and
construction phase of a major project.
Conservation Reserve Program, a federal farm program that gives agricultural
producers annual payments for retiring cropland to perennial vegetation under
10- to 15-year contracts administered by the FSA.
1. Energy Facility Permitting office of the Minnesota Department of Commerce
United States Endangered Species Act, see Section 1.3 below.
Federal Aviation Administration, an agency within the U.S. Department of
Transportation that regulates and oversees all aspects of civil aviation.
Farm Service Agency, an agency within the U.S. Department of Agriculture.
Feet, a unit of distance measure equivalent to 12 inches or 0.305 meter.
Habitat Conservation Plan, see Section 1.3 below.
Kilowatt, a unit of power measurement equivalent to one thousand watts.
Large Wind Energy Conversion System, wind turbines and associated facilities
with the capacity to generate 5 megawatts or more of electricity.
Meter, a unit of distance measure equivalent to 100 centimeters or 3.28 feet.
United States Migratory Bird Treaty Act, see Section 1.3 below.
Minnesota Department of Natural Resources, a state agency charged with
management of the state's natural resources, including state parks, forests,
trails, wildlife areas and hunting regulations, lands and minerals, and waters.
Minnesota Endangered Species Act, see Section 1.3 below.
Minnesota Public Utilities Commission, a state agency that regulates electric,
natural gas and telephone service, ensuring safe, reliable service at fair rates.
Megawatt, a unit of power measurement equivalent to one million watts.
Natural Heritage Information System, a continually updated database that is the
most complete information source on Minnesota's rare plants, animals, native
plant communities, and other significant natural features.
Natural Resources Conservation Service, an agency within the U.S.
Department of Agriculture.
Table 1.1: Definitions of Acronyms and Abbreviations used in this ABPP
Abbreviation
NWCC
DOC
project
RD
RIM
RSH
RSZ
SCADA
SGCN
SNA
SWCD
USACE
USFWS
USGS
Westwood
WMAs
WPAs
WSR
WTG
WTGAC
Definition
National Wind Coordinating Collaborative, a neutral forum formed in 1994 to
pursue development of environmentally, economically, and politically
sustainable commercial markets for wind power in the U.S.
The Minnesota Department of Commerce.
AWA Goodhue wind project.
Rotor Diameter, 82.5 m (271 ft) on a GE 1.6-82.5 ESS wind turbine.
Reinvest in Minnesota, a state program that retires environmentally sensitive
lands from agricultural production under conservation easements administered
by the Minnesota Board of Water and Soil Resources.
Rotor-swept height, or a distance measured from the turbine base beginning
38.75 m above the base and ending 121.25 m above the base, based on the
height and diameter of the blades on a GE 1.6-82.5 ESS wind turbine.
Rotor-swept zone, the rotor-swept area of the wind turbine blades based on the
circumference of the rotor-swept height.
Supervisory control and data acquisition, a centralized system of computer
hardware and software that monitors and controls the infrastructure and
facility-based processes of a wind project.
Species of Greatest Conservation Need, species whose populations are rare,
declining, or vulnerable.
Scientific and Natural Area, state-owned lands set aside to preserve and
perpetuate the ecological diversity of Minnesota's natural heritage.
Soil and Water Conservation District, local units of government that manage
and natural resource programs with an emphasis on agriculture and soils.
United States Army Corps of Engineers, the federal agency charged with
administering wetland regulations under Section 404 of Clean Water Act.
United States Fish and Wildlife Service, an agency within the U.S. Department
of Interior.
United States Geological Survey, an agency within the U.S. Department of
Interior.
Westwood Professional Services is a company that provides leading wind and
solar energy development consulting, land development consulting, and
authored this document in coordination with AWA Goodhue.
Wildlife Management Areas, state lands established to provide wildlife
production, public hunting, trapping, fishing, and compatible recreational uses.
Waterfowl Production Areas, federal lands purchased for the purpose of
increasing the production of migratory birds, especially waterfowl.
Wild and Scenic River, free-flowing rivers set aside and preserved for their
outstanding natural, cultural, and recreational values.
Wind Turbine Generator, a rotary device that converts wind energy into
electricity.
Wind Turbine Guidelines Advisory Committee, an interdisciplinary expert
committee appointed by the Secretary of the Interior to recommend measures
that avoid or minimize wildlife impacts of land-based wind energy facilities.
Appendix C. Applicable Wildlife Laws
MPUC Site Permit Conditions
The following sections of the MPUC Site Permit issued on August 23, 2011 contain
requirements regarding wildlife with which AWA Goodhue must comply:
Section 6.1: Biological and Natural Resource Inventories
Section 6.7: Avian and Bat Protection Plan
Section 13.1: Avian and Bat Protection Plan Special Conditions regarding Eagles, Bats
and Loggerhead Shrikes
Detailed discussions regarding the specifics of these requirements and how they will be complied
with is provided in the ABPP.
Federal Endangered Species Act (ESA)
The federal ESA (16 USC 1531-1544, as amended) sets forth three species list designations:
endangered, threatened and candidate. Species listed as endangered or threatened cannot be
legally “taken.” A “taking” includes (among other things) harassing, harming, pursuing,
hunting, shooting, wounding, trapping, killing, capturing, or collecting listed species within the
United States and its territorial seas. The U.S. Fish and Wildlife Service (USFWS) defines harm
in the definition of “take” to mean:
“an act which actually kills or injures wildlife. Such an act may include significant
habitat modification or degradation where it actually kills or injures wildlife by
significantly impairing essential behavioral patterns, including breeding, feeding, or
sheltering.” [http://library.findlaw.com/1999/Jan/1/241467.html].
Candidate species are animals and plants for which the USFWS has sufficient biological status
and risk factor information to propose them as endangered or threatened, but for which a
proposed listing regulation is precluded by other higher priority listing activities. Candidate
species receive no statutory protection under the federal ESA.
Projects that have federal involvement trigger Section 7 of the ESA. Under Section 7, the
USFWS provides informal or formal consultation and may provide a Biological Assessment and
Biological Opinion. Where the Section 7 process applies, it typically ends when the USFWS
makes an endangered or threatened species determination of no effect, may effect, or adverse
effect. The Project does not trigger Section 7 of the ESA because it does not involve federal
funding, federal land, or major federal permits, and there are no federally-listed species within
the project area.
Private actions that might incidentally harm or “take” threatened or endangered species may
obtain an incidental take permit under Section 10 of the ESA even if they do not have federal
involvement. The incidental take permit and Habitat Conservation Plan (HCP) process includes
a “no surprises” clause, under which the project proposer agrees to implement endangered
species mitigation measures in return for protection from prosecution under the ESA. In order to
obtain an incidental take permit, a private project proposer must prepare an HCP and the USFWS
must approve the HCP. An HCP and incidental take permit is not warranted for the Project
because the Ecological Risk Assessment and Pre-construction Avian Survey for Goodhue
documented no occurrences of federally endangered or threatened species within the project
area.
On June 28, 2011, the USFWS announced that the Northern Long-eared Bat may warrant federal
protection as a threatened or endangered species. The announcement followed an initial review
of a petition initiated by the Center for Biological Diversity seeking to protect the species under
the ESA. The petition indicates that the species may be threatened by several factors, including
habitat destruction and degradation, disturbance of hibernation areas and maternity roosts, and
impacts related to white-nose syndrome (USFWS 2011). The finding was published in the
federal register on June 29, 2011 with a 60-day comment period which ends August 29, 2011.
The Project falls within the occupied range of the Northern Long-eared Bat and a small number
of individuals of this species were recorded in the project area during the first month of acoustic
bat monitoring.
Migratory Bird Treaty Act (MBTA)
The MBTA is a federal criminal statute that prohibits, unless permitted by regulations, activities
that "pursue, hunt, take, capture, kill, attempt to take, capture or kill, possess, offer for sale, sell,
offer to purchase, purchase, deliver for shipment, ship, cause to be shipped, deliver for
transportation, transport, cause to be transported, carry, or cause to be carried by any means
whatever, receive for shipment, transportation or carriage, or export, at any time, or in any
manner, any migratory bird, included in the terms of this Convention . . . for the protection of
migratory birds . . . or any part, nest, or egg of any such bird." (16 USC 703). The MBTA does
not contain provisions for “incidental take” permits. Technically, any migratory bird mortality
caused by humans would be considered a violation of the MBTA.
The MBTA protects most avian species that inhabit the central United States. Exceptions
include non-migratory gallinaceous game birds (e.g., pheasants, grouse, quail) and introduced
species (e.g., European starlings, rock pigeons and house sparrows).
According to the USFWS (2003), the MBTA is a “strict liability statute,” meaning that proof of
intent to harm or kill a migratory bird is not required for an action to be considered a violation of
the MBTA. The USFWS recognizes, however, that some birds may be harmed or killed even if
all reasonable measures to avoid bird fatality are implemented.
With regard to wind power, the USFWS considers a developer’s good faith efforts to comply
with applicable USFWS guidance when exercising prosecutorial discretion under the MBTA.
The USFWS is more likely to prosecute entities that have failed to implement adequate measures
to prevent the reasonably foreseeable incidental take of migratory birds. Goodhue Wind has
engaged in pro-active consultation with the USFWS, and such consultation generally reduces the
potential risk of MBTA prosecution in the future.
Bald and Golden Eagle Protection Act (BGEPA)
The BGEPA (16 U.S.C. 668-668c), enacted in 1940, and amended several times since then,
prohibits anyone without a permit from the Secretary of the Interior, from “taking” bald or
golden eagles, including their parts, nests, or eggs. The BGEPA provides criminal penalties for
persons who “take, possess, sell, purchase, barter, offer to sell, purchase or barter, transport,
export or import, at any time or any manner, any bald eagle ... [or any golden eagle], alive or
dead, or any part, nest, or egg thereof.” The BGEPA defines “take” as “pursue, shoot, shoot at,
poison, wound, kill, capture, trap, collect, molest or disturb.” “Disturb” means:
“to agitate or bother a bald or golden eagle to a degree that causes, or is likely to cause,
based on the best scientific information available, 1) injury to an eagle, 2) a decrease in
its productivity, by substantially interfering with normal breeding, feeding, or sheltering
behavior, or 3) nest abandonment, by substantially interfering with normal breeding,
feeding, or sheltering behavior.”
In addition to immediate impacts, this definition also covers impacts that result from humaninduced alterations initiated around a previously used nest site during a time when eagles are not
present, if, upon the eagle’s return, such alterations agitate or bother an eagle to a degree that
interferes with or interrupts normal breeding, feeding, or sheltering habits, and causes injury,
death or nest abandonment.
As of the preparation of this document, no developer of a wind power project had been
prosecuted under the BGEPA (WTGAC 2008b). However, the USFWS has prosecuted
transmission utilities for violation of the BGEPA. A first offense violation of the BGEPA can
result in a fine of $100,000 ($200,000 for organizations), imprisonment for one year, or both.
Penalties increase substantially for additional offenses, and a second violation of the BGEPA is a
felony.
On September 11, 2009, the USFWS finalized permit regulations to authorize limited take of
bald eagles (Haliaeetus leucocephalus) and golden eagles (Aquila chrysaetos) under the BGEPA,
where the take to be authorized is associated with otherwise lawful activities (USFWS 50 CFR
Parts 13 and 22). The regulations also establish permit provisions for intentional take of eagle
nests under particular and limited circumstances.
In January 2011, the USFWS released Draft Eagle Conservation Plan Guidance (Draft ECP
Guidance), which explains the USFWS’s approach to issuing programmatic take permits. The
purpose of the guidance document is to assist project developers in avoiding, minimizing, and
mitigating adverse effects on bald and golden eagles. The Draft ECP Guidance calls for surveys,
monitoring, assessment, and research to be proportionate to the risk to eagles, and provides a
process by which developers can follow that could allow for a programmatic permit authorizing
unintentional take of eagles at wind energy facilities. Under the Draft ECP Guidance, Eagle
Conservation Plans (ECP) can be developed in five stages, with each of the stages building upon
the previous. The process provides an increasingly intensive evaluation of the likely effects of
the configuration, development, and operation of a particular wind project site on eagles
(USFWS 2011).
Evolving USFWS Bald and Golden Eagle Conservation Plan (ECP) Guidance
The USFWS Draft ECP Guidance continues to evolve, and is part of the Department of the
Interior’s ongoing efforts to improve siting and permitting of renewable energy projects. The
guidelines were officially published in the Federal Register on February 18, 2011, and were open
for public comment for 90 days ending May 19, 2011. A total of 124 individuals, companies,
agencies, and organizations, including the American Wind Energy Association (AWEA),
submitted written comments on the Draft ECP Guidance. The USFWS has not announced
formal revisions to the Draft ECP Guidance.
Effective November 10, 2009, the USFWS adopted rules establishing an incidental take permit
process under the BGEPA, and has prepared Implementation Guidance for Eagle Take Permits
(USFWS 2010b). To apply for a taking under the BGEPA, the applicant must complete permit
application Form 3-200-71, which requires information such as: 1) a detailed description of the
activity that will cause the disturbance or take of eagles; 2) the species and number of eagles that
will be taken and the likely means by which they would be taken; 3) and an explanation of why
avoidance of the take is not possible (USFWS 50 CFR Parts 13 and 22).
The USFWS reviews the taking applications and makes a determination as to whether a taking is
or is not likely to occur under the circumstances described. If the USFWS determines that take is
not likely to occur, they may issue the permit if specific permit issuance criteria are met. The
mission of the USFWS is to reduce the possibility of eagle take, and to only issue permits when
taking is likely and cannot be avoided with practicable means (USFWS 50 CFR Parts 13 and 22).
Minnesota Endangered Species Act (MESA)
The Minnesota Endangered Species Act (Minn. Stat. 84.0895) states that:
“[n]otwithstanding any other law, a person may not take, import, transport, or sell any
portion of an endangered species of wild animal or plant, or sell or possess with intent
to sell an article made with any part of the skin, hide, or parts of an endangered species
of wild animal or plant, except as provided in subdivisions 2 and 7 [of this Chapter].”
The Minnesota ESA requires the Commissioner of the DNR to develop lists of species that are:
(1) endangered, if the species is threatened with extinction throughout all or a significant portion
of its range; (2) threatened, if the species is likely to become endangered within the foreseeable
future throughout all or a significant portion of its range; and (3) species of special concern, if
although the species is not endangered or threatened, it is extremely uncommon in this state, or
has unique or highly specific habitat requirements and deserves careful monitoring of its status.
Species on the periphery of their range that are not listed as threatened may be included as
special concern, along with species that were once threatened or endangered but now have
increasing or protected, stable populations.
Species listed by the state as endangered, threatened and special concern are identified in Minn.
Rules Chapter 6134. Minn. Rules Chapters 6212.1800-6212.2300 set forth regulations for
permits involving the taking or possession of listed species. Neither the Minnesota ESA nor the
implementing regulations contain provisions regarding “incidental take” of listed species or any
enforcement procedures relating to such “incidental takes.”
The risk of the Project adversely affecting state threatened and endangered species is considered
to be low. No state threatened or endangered species were observed in the project area during
the Pre-construction Avian Survey. Two state-threatened loggerhead shrikes were observed
along power lines and fence lines in the project area during the October 24, 2009 field
verification of the loggerhead shrike habitat model. A brood of state-threatened trumpeter swans
was observed by others approximately a half-mile west of the southern part of the project area
and reported to the MDNR on August 18, 2011. The only two state special concern species
observed in the project area were the bald eagle and the Franklin’s gull. The Franklin’s gull was
recorded as an incidental observation during the 2010 spring migration survey, but it is
considered unlikely to breed in the project area due to the lack of available habitat. The bird was
observed flying through the area but was not observed landing or using any habitat within the
Project Area. Bald eagles nest in and around the Project Area and are discussed in detail under
sections 3.1.1.3 and 5.1 of this document.
Appendix D: Biological Inventories
Geographical Constraint Analysis
AWA Goodhue completed a geographic constraint analysis for the initial project area, which
covered approximately 24.4 square miles. The geographic analysis included geographic
information system (GIS) data that were compiled and analyzed for the project area and a report
that explained data and site development factors that could not be fully articulated in the
mapping. Thirty-five sources of GIS data were reviewed during the analysis to assess potential
constraints. The GIS data was verified and supplemented by an onsite field review of the project
area on August 22, 2008. The field review consisted of driving public roads in the project area
and corroborating GIS data to evaluate constraints for wind energy development.
Using a qualitative scale of low, medium, and high, the wind project site was found to have an
overall medium risk of affecting sensitive resources. The project area was found to have a
number of intermittent drainages and streams, but public roads and upland crop fields appeared
to provide sufficient access to largely avoid and minimize effects on wetlands. None of the
streams in the project area were designated trout streams, but those in the western and
northeastern portions were in the headwaters of streams that have trout water in their
downstream reaches. The project area contained some wetlands, which were mostly associated
with the above-mentioned drainages.
A large proportion of the project area was in cropland. The good road access provided the
potential to avoid and minimize effects on most grasslands and woodlands. No federally listed
threatened or endangered species were known or identified as likely to occur in the project area.
Avian species of conservation status are discussed under the Desktop Avian and Bat Risk
Assessment below. Two state special concern bat species were found to occur in Goodhue
County. Their vulnerability when concentrated in hibernacula (usually caves or old mines) was
considered a concern. No sites potentially suitable for hibernacula were observed, but several
old quarries were identified in the southwest portion of the project area that might offer some
limited habitat. Follow up field investigations were recommended for wetlands, wildlife, native
plant communities, and cultural resources to aid in the avoidance and minimization of effects on
these sensitive resources.
Desktop Avian and Bat Risk Assessment
AWA Goodhue completed a desktop avian and bat risk assessment in October 2009 to assess the
risk of the proposed project affecting birds, bats, species of conservation status, and their
important habitats. Between August 2008 and October 2009, the project area increased from
24.4 to 50.5 square miles. The predominant land use was agricultural, consisting of corn and
soybeans, hay and pasture. Grasslands, woodlands, and wetlands covered smaller areas.
Listings for Goodhue County include seven state-listed threatened, endangered, or special
concern avian and bat species (Table D-1). The Goodhue Wind Project bird list included 211
avian species recorded in Goodhue County as both migrants and breeders. Many of the avian
species with conservation status were associated with woodlands or wetlands, which are
somewhat limited in the project area.
Many avian species considered likely to nest in the project area were grassland breeding birds.
Almost one-third of the project area was grassland or pasture. Bats likely to use the project area
were considered fairly common in abundance and distribution. The risk of direct avian and bat
fatalities due to collisions with wind turbines was estimated based on available post-construction
studies of wind projects in similar environments. Although the project area is located within the
broad corridor of the Mississippi Flyway, the closest turbine is located about 15 miles west of the
Mississippi River. Review of land cover data suggested that the most suitable migration
stopover habitats in Goodhue County were outside the project area. These were the Richard
Dorer Memorial Hardwood State Forest, and the Mississippi and Cannon River corridors.
Despite the predominance of cropland, the risk assessment advised that the USFWS and the
MMDNR routinely recommend pre- and post-construction wildlife field studies.
Table D-1. Goodhue County Birds of Conservation Status1
Potential to
Common
Scientific Name State Status2 Occur in
Name
Project Area3
Haliaeetus
Bald Eagle
SC
Confirmed
leucocephalus
Redshouldered
Buteo lineatus
SC
Moderate
Hawk
Peregrine
Falco peregrines THR
Moderate
Falcon
Acadian
Empidonax
SC
Moderate
Flycatcher
virescens
Loggerhead
Lanius
THR
Confirmed
Shrike
ludocicianus
Cerulean
Dendroica
SC
Low
Warbler
cerulean
Henslow’s
Ammodramus
END
Low
Sparrow
henslowii
Comments
Confirmed nest in
project area
More likely to nest along
Mississippi or Cannon
Rivers
More likely to nest along
Mississippi River
Potential suitable habitat
Suitable habitat in
project area
Lack of suitable habitat
Lack of suitable habitat
1
Information adapted from MDNR (2008).
Status of state-listed species (THR=Threatened, END=Endangered, SC=Special Concern); MDNR (2007).
3
Species listed as confirmed were documented in the project area during field studies.
2
Seven species of bats are known to occur in Minnesota (ASM 2001, BCI 2003). Table D-2 lists
the species recorded in the state and their distribution and conservation status according to
MDNR (2007). All bat species known to occur in Minnesota were detected in the project area
during the acoustic bat monitoring discussed in Section 5.6.1. The Big Brown Bat, Silver-haired
Bat, Eastern Red Bat, Hoary Bat, and Little Brown Bat were initially considered the most likely
to occur in the project area. Of the seven bat species, three roost primarily in trees, one in manmade structures, one in trees and structures, and two in caves or rock crevices. Land cover
mapping indicates the project area is about 4% forested and no caves or mines have been noted
in the project area. More abundant roosting habitat for tree roosting bats is available north of the
project area in the Richard Dorer Memorial Hardwood State Forest and along the Mississippi
River, which generally runs north-south approximately 15 miles east of the project area.
Table D-2. Distribution and Status of Bat Species Known to Occur in Minnesota1
Common
Name
Scientific
Name
Minnesota
Distribution
Occurrence
Big Brown
Bat
Eptesicus
fuscus
Statewide
Common
Confirmed
Man-made structures
and hollow trees
Silver-haired
Bat4
Lasionycteris
noctivagans
Statewide
Common
Confirmed
Under bark and in
hollow trees
Eastern Red
Bat4
Lasiurus
borealis
Statewide
Common
Confirmed
Trees
Hoary Bat4
Lasiurus
cinereus
Statewide
Common
Confirmed
Trees
Little Brown
Bat
Myotis
lucifigus
Statewide
Common
Confirmed
Man-made structures
Northern
Long-eared
Bat
Myotis
Statewide
septentrionalis
Species of
Special
Concern
Confirmed
SC
Caves and mines
Tri-colored
Bat
Pipistrellus
subflavus
Species of
Special
Concern
Confirmed
SC
Rock Crevices
Southeast ¼ of
state
Potential to Occur Species
in Project Area2
Status3
Typical Roosting
Habitat
1
Information adapted from ASM (2001), BCI (2003), and MDNR (2007).
Species listed as confirmed were documented in the project area during field studies.
3
SC = Special Concern; MDNR (2007).
4
Solitary, tree-roosting bat species, typically more affected by wind energy projects.
2
Initial Pre-Construction Avian Surveys
2010 Spring Migration Point Counts
AWA Goodhue completed a pre-construction avian migration survey at the Goodhue Wind
Project from April 5 to May 24, 2010. A field ornithologist conducted 5-minute point counts at
20 locations along roadside transects, recorded other observations of rare birds, and documented
locations of raptor stick nests visible from the survey route. Point counts were established at
approximate 2-mile intervals throughout the project area in representative habitats and area of
proposed turbines. This avian study characterized the spring avian community and quantified
flight patterns and collision risk.
Westwood observed a total of 2,927 birds of 58 species in the project area during the 8-week
spring survey. Generally, species observed are common in distribution and/or abundance.
Overall mean bird use was 18.3 birds per 5 minutes. The most frequently seen species was the
Red-winged Blackbird. The avian community was dominated by passerines (songbirds), most of
which are common and/or abundant in an agricultural landscape during migration and/or
breeding seasons. Waterfowl/waterbirds were notably absent, presumably due to the lack of
water features these birds characteristically utilize during migration and breeding.
No federally listed species were observed. The only two state listed special concern species
recorded include the Bald Eagle and the Franklin’s Gull. At the time of the Pre-construction
Avian Survey, three Bald Eagles nests existed at distances of 0.25, 1.0 and 3.5 miles outside the
project area, but no bald eagles nests were observed inside the project boundary during these
initial surveys. One Franklin’s gull was recorded as an incidental observation during the first
week of the avian survey. The incidental Franklin’s gull observation was recorded outside of the
point counts and Franklin’s gulls are considered unlikely to breed in the project area due to the
lack of suitable habitat. The project area has limited public wildlife lands, contiguous tracts of
grassland, and water features that typically supports rare species. It also has limited suitable
migration stopover habitat for birds in general.
Observations of large flocks of migrating birds, such as warblers, sparrows, and ducks and geese,
were fewer than expected. Of 1,114 avian observations recorded, only 27 (2.4%) involved
groups of more than 10 birds, and only one involved more than 25 birds. Only about 5% of
flights were above the RSH where migratory flights typically occur, few flocks were observed,
and few species known to breed further north were recorded. High flights were generally of
raptors. However, high raptor flights do not necessarily indicate migratory behavior because
raptors soar on thermals or hot air pockets that facilitate effortless flight, even in their daily
movements. The lack of flock and non-breeding bird observations may be partially attributed to
the uncharacteristically early spring in 2010.
There were 38 species of birds observed in flight. Only 12 of these species had a measurable
index of collision hazard (I > 0.001). The species with the highest indices of collision hazard
were Brown-headed Cowbird (0.02), Common Grackle (0.015), and American Crow (0.011).
Only 15% of flights were within the rotor-swept height (RSH).
Nationwide, passerines have been the most abundant bird fatality at wind-energy facilities, often
accounting for over 80% of avian fatalities at wind projects outside of California (Erickson et al.
2002, NWCC Wildlife Workgroup 2010). However, high passerine use has not been clearly
correlated with high mortality (Erickson et al. 2002). Passerines accounted for 88% of the
individual birds observed at Goodhue. Most passerines were generalist species that are adapted
to the agricultural landscape.
2010 Leaf-off Raptor Nest Survey
Westwood conducted a leaf-off raptor nest survey in conjunction with the migration period point
counts. Raptor nests were identified and mapped on March 24, 2010, and nests were monitored
during April 5-19, 2010 to assess raptor activity and species use. Raptor nests were identified by
driving the point count survey route and other roads within the project area and observing
forested areas, woodlots and tree lines through a spotting scope and binoculars. Nest clumps and
raptor activity suggestive of a nest were mapped and documented.
At the time the 2010 nest survey was completed, the project area was found to contain seven
active Red-tailed Hawk nests and one active Great Horned Owl nest. Additional raptor nests
identified include one Red-tailed Hawk nest and one Great-horned Owl nest located outside the
project area and 13 other possible raptor nests with no documented raptor nesting activity. These
13 nests could either be inactive or used by crows, squirrels or raptors. Visual obstructions
caused by vegetation and rolling terrain limited the potential for observation of raptor activity
during this initial raptor nest survey.
2010 Bald Eagle Nest Monitoring
An AWA Goodhue avian field biologist surveyed the project area and a 2-mile buffer to verify
the status of the three bald eagle nests identified by wildlife agencies and to search for other
eagle nests in and near the project area. The USFWS had recommended monitoring of bald
eagle nests within 2 miles of the project area, and later revised their recommendation to include
an additional nest approximately 3.5 miles from the project boundary.
Monitoring of active eagle nests focused on flight paths of eagles to and from nests to assess
potential local food sources and roost sites. Observed flight paths were recorded on aerial
mapping, along with notes on eagle behavior (i.e., material carry for nest repair, food carry,
territory defense, etc.). Monitoring occurred at each active nest for two half-day (4 hour)
intervals between March 24 and April 16, 2010. Each nest was monitored for one morning and
one afternoon. The monitoring timing corresponded to the eagle incubating and early brood
rearing period. Compilation of flight paths and behavioral clues helped highlight potential flight
path corridors, local food sources, and roost sites.
At the time of the 2010 avian surveys, three bald eagle nesting territories were known to exist
near the drainages of Belle Creek, Zumbro River, and Hay Creek. These nests are located 0.25,
1.0 and 3.5 miles outside the project area boundary, respectively. The raptor nest survey
conducted in March and April 2010 did not reveal any other eagle nests within 2 miles of the
project area and there were no confirmed citizen reports of new bald eagle nests during 2010.
Observations of bald eagle flights to and from nests indicated they were mainly utilizing the
stream corridors in the vicinity of their nests. No local food source concentrations or preferred
roost sites were observed during these initial observations. No eagle flight paths were observed
through the project area during 2010.
One eagle fatality occurred on May 12, 2010 when an eagle was struck by a motor vehicle on
U.S. Highway 52 as it fed on a road-killed raccoon. The eagle fatality was located 2.4 miles
west of the southwestern part of the project and 3.1 miles from the nearest proposed turbine
location. The eagle carcass was reportedly delivered to the Raptor Center at the University of
Minnesota by a private citizen.
Loggerhead Shrike Habitat Assessment
Methods
AWA Goodhue’s Loggerhead Shrike Habitat Assessment (Westwood Professional Services
2009) identified and ranked suitable shrike breeding habitat based on an adaptation of a
previously developed shrike habitat model for Minnesota (Brooks and Temple 1990). The
assessment and related work were designed to:
assess the suitability of loggerhead shrike habitat in the project area;
assess the compatibility of the Goodhue Wind Project with loggerhead shrikes; and
demonstrate wind turbine siting that avoids and minimizes effects on loggerhead shrikes.
AWA Goodhue enlisted the assistance of Ms. Bonnie (Brooks) Erpelding to complete the
loggerhead shrike habitat assessment. Ms. Erpelding is an authority on loggerhead shrikes in
Minnesota. She completed her M.S. on loggerhead shrikes in Minnesota and previously served
as the MDNR Nongame Wildlife Specialist for southeastern Minnesota.
Known records of shrike observations near the project area were reviewed during the initial
phase of the habitat assessment. Most recorded shrike observations in Goodhue County occur in
the northwest portion of the county, with others distributed throughout the county. There is one
breeding season record within two miles of the project area, indicating potential suitable
breeding habitat in the project vicinity. Brooks and Temple (1990) found substantial suitable,
but unoccupied habitat in Minnesota, strongly suggesting that availability of breeding habitat is
not limiting the Minnesota shrike population.
The habitat suitability model was modified from Brooks and Temple (1990) to efficiently
evaluate the project area and apply the expert opinion of Ms. Erpelding. The project area was
divided into 207 quarter sections and each quarter section was ranked for breeding loggerhead
shrike habitat suitability based on interpretation of 1”=550’ scale 2008 aerial photography.
Preliminary rankings for some quarter sections were revised after field verification. The habitat
model was referred to as a “coarse filter” because it relied primarily on interpretation of aerial
photography, and because the 160-acre sampling frame is much larger than the reported shrike
territory size of 10-30 acres per pair in the Midwest (Kridelbaugh 1982). The habitat rankings
were based on the criteria listed in Table D-3.
Table D-3. Loggerhead Shrike Coarse Filter Breeding Habitat Ranking
Rank
1
Description
Per 160 Acres (Quarter Section; 65 ha)
Grass/Pasture (ac) Nest Sites1
Perches
0
Unsuitable
< 20
<8
NA
1
Minimally Suitable
20-30
>8
NA
2
Slightly Suitable
30-40
> 10
NA
3
Moderately Suitable
40-50
> 12
Available
4
Highly Suitable
50-60
> 15
Available throughout
5
Very Highly Suitable
> 60
> 15
Available throughout
A potential nest site was defined as isolated low growing trees, or tree rows or windbreaks only
one tree wide.
Results
The coarse filter model indicated that 58.5% of the project area is unsuitable or minimally
suitable for loggerhead shrikes (Table D-4). Roughly a third (30.9%) of the project area
contains habitat at least moderately suitable for shrikes (ranks 3-5). Quarter sections containing
suitable habitat are dispersed throughout the project area. Notably, due to the “coarse filter”
characteristics of the assessment, quarter sections ranked moderately suitable may contain up to
120 acres of unsuitable shrike habitat such as cropland and woodland. Quarter sections ranked
highly suitable or very highly suitable may contain up to 110 acres of unsuitable shrike habitat.
Eastern red cedar trees, which are generally preferred by shrikes, were observed in grasslands,
mostly in the northern half of the project area. Field verification resulted in decreased
preliminary habitat suitability rankings for 28 of 207 quarter sections due to a lack of suitable
nest sites. This suggests a need for caution during aerial photograph interpretation due to the
potential to overestimate nest site availability and habitat suitability.
During the October 24, 2009 field verification, the observation of two loggerhead shrikes along
power lines and fence lines in habitats ranked 3 and 4 confirmed that loggerhead shrikes are
present in the project area during fall migration and helped to validate the habitat model. The
lack of previous records of shrikes in the project area is likely due to a lack of surveys or reports
of sightings rather than an absence of shrikes.
Table D-4. Coarse Filter Habitat Rankings for Project Area and Turbine Locations
Habitat
Rank
1
Project Quarter Sections
2010 Turbine Layout1
2011 Turbine Layout1
No.
%
No.
%
No.
%
0
88
42.5
28
56.0
29
60.4
1
33
16.0
4
8.0
2
4.2
2
22
10.6
8
16.0
7
14.6
3
35
16.9
4
8.0
4
8.3
4
16
7.7
1
2.0
1
2.1
5
13
6.3
5
10.0
5
10.4
Total
207
100.0
50
100.0
48
100.0
The turbine layout was revised several times to address multiple constraints. Turbine layouts
include alternate turbine locations. The 2010 layout was the layout before the MPUC on
October 21, 2010 and the 2011 layout was shown at the MPUC public hearing on June 30, 2011.
Alternate turbine locations were not included in this analysis.
Wetland Delineation
Westwood delineated and located parts of 45 wetlands in proximity to proposed construction
zones within the project area. Wetland delineations were performed within a 2,624-acre (4.10
square mile) area encompassing the Project Construction Area. The Project Construction Area
encompasses all areas that would potentially incur temporary or permanent disturbance during
construction of wind turbines, access roads, underground electrical collection cables, crane paths
and substations for the project. The Project Construction Area is larger than the ultimate zone of
disturbance, the latter being dictated by the final design of the project. Delineation field work
was performed on June 16-17, July 28, August 2-3, and October 10, 2010. Of the 45 wetland
areas, 40 were associated with creeks, ditches, or drainages. The remaining five delineated
wetlands were Type 1, 2, or 3 wetlands that are not associated with ditches, creeks, or drainages
and are believed to be isolated basins. All but two wetlands have been substantially disturbed by
previous ditching, sedimentation and/or tillage.
The wetland delineation is being updated to include additions to the Project Construction Area
that may result from relocation of turbines in response to MPUC Site Permit conditions or other
constraints.
Native Prairie Survey
Throughout the various field surveys that performed in the project area, Westwood biologists
have field reviewed areas to be affected by construction and found no native prairie remnants.
Primary patches of grassland in the project area were reviewed during field verification for the
loggerhead shrike habitat assessment and the only potential prairie remnant identified was later
determined to be enrolled in the Conservation Reserve Program, indicating it had been retired
from cropland and seeded to native grasses. A final survey for native prairie remnants will be
performed as part of detailed micrositing of turbines, access roads and collection cables. Effects
on any native prairie remnants that may be identified will be avoided and minimized to the extent
practicable. If it becomes apparent that impacts to native prairie remnants are unavoidable, a
prairie management plan will be prepared. At least ten days prior to construction, AWA
Goodhue will report the results of its native prairie avoidance efforts to DOC EFP and MDNR.
If a prairie management plan is required, it will be submitted at that time.
Appendix E: Summary of Agency Coordination to Date
AWA Goodhue initiated wildlife agency consultation and coordination activities in
October 2008, when initial comments were requested from USFWS and MDNR. An initial
Natural Heritage Inventory System (NHIS) database search was conducted on October 24,
2008. The project boundary was subsequently enlarged and supplemental consultation
letters were sent to these agencies in December 2008. An updated NHIS search was
conducted on September 30, 2009. USFWS provided a comment email on November 25,
2008, and MDNR provided comment emails on November 4, 2008 and January 13, 2009.
USFWS provided an additional comment letter on July 9, 2009.
Westwood conducted a loggerhead shrike habitat assessment, desktop avian and bat risk
assessment and avian and bat assessment protocols between November 15, 2009 and
January 15, 2010. Westwood responded to USFWS and MDNR comments on January 18,
2010 and conducted a meeting with these agencies on February 2, 2010. USFWS
submitted a supplemental comment letter on February 19, 2010. Westwood submitted
initial and revised avian field survey protocols to USFWS on March 31, 2010 and May 12,
2010. Over the summer and fall of 2010, Westwood prepared a pre-construction avian
survey and risk assessment report and final loggerhead shrike habitat assessment, both of
which were provided to USFWS and MDNR on October 10, 2010.
On October 5, 2010, Goodhue County adopted a wind power ordinance with setbacks that
would have precluded siting most of the turbines AWA Goodhue proposed in the MPUC
Site Permit application. On October 21, 2010, the MPUC held a hearing to consider
approving the Site Permit for the Project. In its deliberations, the MPUC remanded to an
Administrative Law Judge (ALJ) the question of whether good cause existed not to apply
the county ordinance. Given the uncertain future of the AWA Goodhue project, most
agency coordination and avian survey and monitoring work (along with other project
development activity) were suspended from October 21, 2010 until the ALJ’s
recommendation was issued on April 29, 2011. During this period of suspended activity,
AWA Goodhue and Westwood did conduct a November 18, 2010 meeting with the MDNR
to discuss the results of the loggerhead shrike habitat assessment.
Shortly after issuance of the ALJ’s recommendation on April 29, 2011, agency
coordination, avian surveys and field studies were reinitiated by AWA Goodhue and
Westwood. Coordination was re-initiated with USFWS regarding bald eagles the first
week of May 2011 in response to citizen reports of new bald eagle nests in or near the
Project Area, and monitoring on two new eagles nests was initiated. On June 9, 2011,
AWA Goodhue and Westwood participated in a meeting and conference call with staff
from the DOC- EFP, USFWS and MDNR to discuss the results of nest monitoring
activities and plans for ongoing monitoring. USFWS recommended that monitoring be
shifted from the new nests to four turbine clusters in nearest proximity to active nests.
Westwood immediately implemented this change. On June 13, 2011, Westwood met onsite with the MDNR and USFWS and conducted a field review of two specific turbine
locations that were of concern with regard to loggerhead shrikes (both of which were
subsequently deleted from the project layout). A subsequent meeting and conference call
was held with staff from the DOC- EFP, USFWS and MDNR on July 29, 2011 to discuss
the results of turbine cluster monitoring and modifications being made to the turbine layout
in response to MPUC Site Permit Conditions and MDNR concerns about loggerhead
shrikes. Extensive and frequent agency coordination has occurred during the preparation
of this ABPP written comments on a draft of the ABPP from DOC-EFP, USFWS and
MDNR as well as meetings involving AWA Goodhue, Westwood and the three agencies
on August 12, 15, 18, 22 and 29, 2011. An additional meeting was held with DOC-EFP
and the USFWS to discuss eagle surveys and issues on December 1, 2011.
Appendix F: Minnesota DNR Fatality Monitoring Report Forms
Appendix G: Eagle Collision Risk Modeling – 2011 Breeding Season Data
PREDICTED NUMBER OF EAGLE-TURBINE COLLISIONS: AWA Goodhue Wind Farm -- 2011 Breeding Period Data Only -- 100 m Buffer around WTGs
Step
1
2
3
4
5
6
7
8
9
10
11
12
13
BAND ET AL (2007) MODEL STAGE 1
Units
Comments
Plot Observation Time
minutes
100
31415.92654
18
565486.6776
175
98960168.59
48
41.25
2
0.94
754373.3651
0.007623
12,600
14
Observation Time Birds Spent in Flight w/in Risk Volume (Vw)
minutes
2.04
15
Proportion of flights at RSH
16
Observation Time Birds Spent at RSH w/in Risk Volume (Vw)
seconds
36.3528
17
Observation Time Birds Spent at RSH w/in Critical Volume
seconds
0.277117394
18
Daylight hours in a year in Project Area
hours
4468
Per U. S. Naval Observatory
19
Percentage of Hours Turbines Operational
0.85
Conservative estimate
20
Potential total bird occupancy
21
Proportion of Total Bird Occupancy represented by Obs Time
22
Bird occupancy at RSH of Critical Volume (Vr) per Year
bird-seconds/yr
5.01160
23
Flight speed
meters/second
15.00000
24
25
Time taken for transit through rotors
seconds
0.19600
Number of transits through rotors/year
transits/year
25.56940
26
BAND Collision % of transits (From Stage 2 results)
collisions/transit
0.09100
27
Collisions per annum w/o avoidance/displacement factor
collisions/year
2.32682
28
Avoidance factor (for golden eagles from Whitfield 2009)
29
Predicted collisions per annum
collisions/year
0.02327
30
Years between predicted collisions
years/collision
42.97720
Point Count Plot radius
m
Area of Point Count Plot
m2
Number of Plots
2
Total Plot Area
m
Plot Height
m
Risk Volume (Vw) (Total Observation Plot Volume)
m3
Number of turbines
Rotor radius
m
Rotor depth
m
Bird length
m
Critical Volume (Vr) (Total Rotor Swept Volume for 48 turbines)
m3
Proportion of Risk Volume Occupied by Critical Volume
0.297
minutes per year
227868
100 meter buffer around each of 18 turbines withi n 800 meter survey plots
There are 18 turbine locations (including 100 m radius buffer) within the five 800 m survey plots
Total rotor swept volume/total survey plot volume
5 plots monitored for average of 242.3 minutes each
1835 meters of flight observed within 100m radius turbine buffers/15 meters per second = 122.3 seconds = 2.04 minutes
From flight lengths collected during breeding season point counts = 544m/1835m = 0.297
Portion of observation time birds would be w/in rotor swept volume
Minutes per year birds could be interacting with moving turbine rotors
0.055295171
Seconds per year that birds would be within total rotor swept volume
15 m/sec = 33.6 mph (estimated average flight speed per Whitfield (2009))
From Stage 2 spreadsheet for GE 1.6 MW WTG - Bird flapping, not gliding
0.01000
1 collision every 43 years
PREDICTED NUMBER OF EAGLE-TURBINE COLLISIONS: AWA Goodhue Wind Farm -- 2011 Breeding Period Data Only -- 800 m Radius Plot around Observation Point
BAND ET AL (2007) MODEL STAGE 1
Units
Plot Observation Time
minutes
800
2010619.298
5
10053096.49
175
1759291886
48
41.25
2
0.94
754373.3651
0.000428794
12,600
Observation Time Birds Spent in Flight w/in Risk Volume (Vw)
minutes
177
Point Count Plot radius
m
Area of Point Count Plot
m2
Number of Plots
Total Plot Area
m2
Plot Height
m
Risk Volume (Vw) (Total Observation Plot Volume)
m3
Number of turbines
Rotor radius
m
Rotor depth
m
Bird length
m
Critical Volume (Vr) (Total Rotor Swept Volume for 48 turbines)
m3
Proportion of Risk Volume Occupied by Critical Volume
0.3579
Proportion of flights at RSH
Comments
800 meter survey plot around each observation point
Total rotor swept volume/total survey plot volume
5 plots monitored for average of 242.3 minutes each
159,304 meters of flight observed/15 meters per second = 10,620 seconds = 177
minutes
From flight lengths collected during breeding season point counts
Observation Time Birds Spent at RSH w/in Risk Volume (Vw)
seconds
3800.898
Observation Time Birds Spent at RSH w/in Critical Volume
seconds
1.629801307
hours
4468
Per U. S. Naval Observatory
0.85
Conservative estimate
Daylight hours in a year in Project Area
Percentage of Hours Turbines Operational
Potential total bird occupancy
minutes per year
227868
Portion of observation time birds would be w/in rotor swept volume
Minutes per year birds could be interacting with moving turbine rotors
0.055295171
Proportion of Total Bird Occupancy represented by Obs Time
Bird occupancy at RSH of Critical Volume (Vr) per Year
bird-seconds/yr
29.47457
Seconds per year that birds would be within total rotor swept volume
Flight speed
meters/second
15.00000
15 m/sec = 33.6 mph (estimated average flight speed per Whitfield (2009))
seconds
0.19600
transits/year
150.38045
collisions/transit
0.09100
Time taken for transit through rotors
Number of transits through rotors/year
BAND Collision % of transits (From Stage 2 results)
Collisions per annum w/o avoidance/displacement factor
13.68462
Avoidance factor (for golden eagles from Whitfield 2009)
0.01000
Predicted collisions per annum
0.13685
Years between predicted collisions
7.30747
From Stage 2 spreadsheet for GE 1.6 WTG - Bird flapping, not gliding
1 collision every 7.3 years
CALCULATION OF COLLISION RISK FOR BIRD PASSING THROUGH ROTOR AREA
Only enter input parameters in blue
K: [1D or [3D] (0 or 1)
1
NoBlades
3
MaxChord
2.8 m
Pitch (degrees)
15
W Band
12/14/2011
Calculation of alpha and p(collision) as a function of radius
Upwind:
r/R
c/C
radius
chord
collide
alpha
length
p(collision)
Downwind:
contribution
collide
from radius r
length
contribution
p(collision)
from radius r
BirdLength
0.94 m
0.025
0.575
13.89
53.83
1.00
0.00125
52.99
1.00
0.00125
Wingspan
2.29 m
0.075
0.575
4.63
18.22
0.61
0.00455
17.39
0.58
0.00435
F: Flapping (0) or gliding (+1)
Bird speed
0
15 m/sec
RotorDiam
82.5 m
RotationPeriod
6.00 sec
Bird aspect ratioo:
0.41
0.125
0.702
2.78
12.14
0.40
0.00506
11.12
0.37
0.00463
0.175
0.860
1.98
9.78
0.33
0.00571
8.54
0.28
0.00498
0.225
0.994
1.54
8.41
0.28
0.00630
6.96
0.23
0.00522
0.275
0.947
1.26
6.81
0.23
0.00624
5.44
0.18
0.00499
0.325
0.899
1.07
5.70
0.19
0.00617
4.39
0.15
0.00476
0.375
0.851
0.93
4.87
0.16
0.00609
3.64
0.12
0.00454
0.425
0.804
0.82
4.23
0.14
0.00599
3.06
0.10
0.00434
0.475
0.756
0.73
3.72
0.12
0.00588
2.62
0.09
0.00415
0.525
0.708
0.66
3.29
0.11
0.00577
2.27
0.08
0.00397
0.575
0.660
0.60
2.94
0.10
0.00564
1.98
0.07
0.00380
0.625
0.613
0.56
2.64
0.09
0.00549
1.75
0.06
0.00364
0.675
0.565
0.51
2.37
0.08
0.00534
1.55
0.05
0.00350
0.725
0.517
0.48
2.14
0.07
0.00518
1.39
0.05
0.00336
0.775
0.470
0.45
1.94
0.06
0.00500
1.25
0.04
0.00324
0.825
0.422
0.42
1.75
0.06
0.00481
1.14
0.04
0.00313
0.875
0.374
0.40
1.61
0.05
0.00470
1.07
0.04
0.00312
0.925
0.327
0.38
1.51
0.05
0.00465
1.03
0.03
0.00319
0.975
0.279
0.36
1.41
0.05
0.00458
1.01
0.03
0.00327
Overall p(collision) =
Upwind
10.4%
Average
Downwind
7.7%
9.1%
NOTES
Max chord 2.8m from estimate
Pitch 15 deg from estimate
Bird length female maximum 0.94 m - from natureserve.org
Wingspan female maximum 2.29 m from natureserve.org
Bird speed 15 m/s (34mph) - per Whitfield (2009) for golden eagles
Rotor diameter 82.5m for GE 1.6 xle WTG
Rotational period 6 sec for GE 1.6 WTG operating at 8m/s (10 RPM; 700kW; average output for site)
11:54 AM12/14/2011
P:\20081147\docs\Envir\ABPP\FINAL FINAL ABPP 12-08-2011\AWA Goodhue Band Stage 2 .xls
CALCULATION OF COLLISION RISK FOR BIRD PASSING THROUGH ROTOR AREA
Only enter input parameters in blue
K: [1D or [3D] (0 or 1)
1
NoBlades
3
MaxChord
2.8 m
Pitch (degrees)
15
W Band
12/14/2011
Calculation of alpha and p(collision) as a function of radius
Upwind:
r/R
c/C
radius
chord
collide
alpha
length
p(collision)
Downwind:
contribution
collide
from radius r
length
contribution
p(collision)
from radius r
BirdLength
0.94 m
0.025
0.575
13.89
42.27
1.00
0.00125
41.43
1.00
0.00125
Wingspan
2.29 m
0.075
0.575
4.63
14.37
0.48
0.00359
13.53
0.45
0.00338
F: Flapping (0) or gliding (+1)
Bird speed
1
15 m/sec
RotorDiam
82.5 m
RotationPeriod
6.00 sec
Bird aspect ratioo:
0.41
0.125
0.702
2.78
9.83
0.33
0.00410
8.81
0.29
0.00367
0.175
0.860
1.98
8.13
0.27
0.00474
6.89
0.23
0.00402
0.225
0.994
1.54
7.12
0.24
0.00534
5.68
0.19
0.00426
0.275
0.947
1.26
5.76
0.19
0.00528
4.39
0.15
0.00402
0.325
0.899
1.07
4.81
0.16
0.00521
3.50
0.12
0.00380
0.375
0.851
0.93
4.10
0.14
0.00512
2.86
0.10
0.00358
0.425
0.804
0.82
3.55
0.12
0.00503
2.38
0.08
0.00338
0.475
0.756
0.73
3.11
0.10
0.00492
2.01
0.07
0.00319
0.525
0.708
0.66
2.74
0.09
0.00480
1.72
0.06
0.00301
0.575
0.660
0.60
2.44
0.08
0.00467
1.48
0.05
0.00284
0.625
0.613
0.56
2.17
0.07
0.00453
1.29
0.04
0.00268
0.675
0.565
0.51
1.95
0.06
0.00438
1.13
0.04
0.00254
0.725
0.517
0.48
1.74
0.06
0.00421
0.99
0.03
0.00240
0.775
0.470
0.45
1.56
0.05
0.00404
0.88
0.03
0.00228
0.825
0.422
0.42
1.40
0.05
0.00385
0.79
0.03
0.00217
0.875
0.374
0.40
1.61
0.05
0.00470
1.07
0.04
0.00312
0.925
0.327
0.38
1.51
0.05
0.00465
1.03
0.03
0.00319
0.975
0.279
0.36
1.41
0.05
0.00458
1.01
0.03
0.00327
Overall p(collision) =
Upwind
8.9%
Average
Downwind
6.2%
7.6%
NOTES
Max chord 2.8m from estimate
Pitch 15 deg from estimate
Bird length female maximum 0.94 m - from natureserve.org
Wingspan female maximum 2.29 m from natureserve.org
Bird speed 15 m/s (34mph) - per Whitfield (2009) for golden eagles
Rotor diameter 82.5m for GE 1.6 xle WTG
Rotational period 6 sec for GE 1.6 WTG operating at 8m/s (10 RPM; 700kW; average output for site)
11:55 AM12/14/2011
P:\20081147\docs\Envir\ABPP\FINAL FINAL ABPP 12-08-2011\AWA Goodhue Band Stage 2 .xls
AWA Goodhue Wind Project -- 2011 Breeding Bald Eagle Flight Calculations
Location 1a
Location 1
Location 2
Location 3
Location 4
Total
Total Flight Length (m)
Flight Length within 100m of Turbine
Below
Within
Above
Total
Below
Within
Above
Total
2688
2782
29241
34711
512
418
244
1174
0
0
4489
4489
0
0
0
0
32297
9156
4548
46001
0
0
0
0
5826
44585
9549
59960
278
0
0
278
2281
488
11374
14143
0
126
257
383
43092
57011
59201
159304
790
544
501
1835
Location 1a
Location 1
Location 2
Location 3
Location 4
Proportions of Flights within 100m of Turbine - per location
Below
Within
Above
0.190476 0.150252 0.008344
within / total length of 1a
0
0
0
0
0
0
0.047717
0
0
0 0.258197 0.022595
within / total length of 4
Proportions of Flights within 100m of Turbine - all flights per location
Location 1a
Location 1
Location 2
Location 3
Location 4
0.033822
0
0
0.004636
0.027081
All flights - proportion within 100m of turbine
Below
Within
Above
0.018333 0.009542 0.011519
1.80%
0.95%
1.15%
overall proportion of flights overlapping 100m of turbines
0.011519
1.15%
overall proportion of flights overlapping 100m of turbines AND within RSH
0.003415
0.34%
0.012042
0.008909
Appendix H: Wildlife Incident Reporting Form
Wildlife Incident Reporting Form
AWA Goodhue Wind Project
SECTION NO. 1 - DISCOVERY DATA
Report Date:
(Date on which the animal(s) was found and the report completed)
Injury/Fatality
(Circle appropriate choice)
Complete/Dismembered/Feathers
(Circle appropriate description. Complete would indicate a complete and intact carcass or injured animal.
Dismembered would indicate a missing or amputated wing or other appendage. Feathers would indicate that only
feathers were found.)
Notification to:
(See notification requirements below)
Date/Time:
Note: All notifications must occur within 24 hours of discovery to ensure permit compliance.
For Injured Animals that are not raptors, notify Wildlife Rehabilitation Center of Minnesota (651-4869453) and Wildlife Consultant (952-937-5150) or AWA Goodhue Site Manager (Phone # TBD).
For injured raptors, notify the Raptor Clinic at the University of Minnesota Raptor Center ( 651-4869453) and Wildlife Consultant (952-937-5150) or AWA Goodhue Site Manager (Phone # TBD). If
the injured animal is found after normal weekday office hours, protect the animal and report it the Wildlife
Rehabilitation Center of Minnesota or Raptor Clinic at the Minnesota Raptor Center on the next available
working day.
For Fatalities, Notify Wildlife Consultant (952-937-5150) and/or AWA Goodhue Site Manager (Phone
# TBD).
SECTION NO. 2 - LOCATION OF FIND
Structure:
________________________________________________________________________
(Include turbine number, Pole number, or other landmark feature if nothing is nearby)
Location Remarks:
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
(Include closest turbine number, distance from turbine, and general direction [for ex, 50 feet south of turbine A-1].
Include any other details, such as –found on the road, power lines overhead, etc.)
SECTION NO. 3 - WILDLIFE IDENTIFICATION
Species:
_________________________________________________________________________
(If known, write the species. If not sure, write Unidentified.)
Field marks used: ________________________________________________________________
(Identification marks that helped you determine the species of the bird, if you are not sure and have an educated
guess, put it here. For example, red tail and white chest)
Number of Photos Attached: ______________
(Print digital photos and attach to Wildlife Incident Reporting Form – include both in situ and close up photos that
allow confirmation of diagnostic characteristics).
SECTION NO. 4 – OBSERVATIONAL DATA
Physical condition:
_________________________________________________________________________
_________________________________________________________________________
_________________________________________________________________________
(Describe the physical condition at the time of discovery, including broken wings, all appendages attached?, all
pieces found?, skeleton visible?, infested with anything?, etc)
Estimated Time since Death or Injury (days): _____________ (<1, <4, <7, <14, <30, >30)
(Use your best judgment. Carcasses less than a few days old will have round, fluid filled eyes and will lack insect
infestation. Carcasses with maggots are probably one to two weeks old. If bones are visible, the carcass is probably
over 30 days old. Bones visible indicate over 30 days. Keep in mind that in cold weather carcasses will look fresh
for much longer than in warmer weather.)
Other Field Notes:
________________________________________________________________
(Note anything else relevant to incident such as presence of other fatalities in the area, evidence of electrocution
details, extreme weather conditions, or other details).
Ultimate Disposition of the Bird or Bat:
___________________________________________________
(Taken to rehab center, Left in the field, or Placed in avian freezer)
SECTION NO. 5 - RESPONDENT
Respondent Name: _____________________________________________ Date________
Signature: _____________________________________________________Date________
All Wildlife Incident Reporting Forms should be sent to Wildlife Consultant and AWA Goodhue Site Manager at
the end of each calendar year.
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