BAT LETTER ! DEIS

Mr. Richard Edsall May 29, 2009
Town of Cape Vincent Planning Board Chairman
P.O. Box 680
Cape Vincent, NY 13618

Dear Sir:

I have a comment about St. Lawrence wind’s SDEIS regarding the report on the Indiana bat.
Jefferson County is home to the northernmost colony of Indiana brown bats, a federally listed endangered species, that are undergoing a serious population decline. There are hibernacula in Glen Park, New York approximately 20 miles from Cape Vincent. The Indiana brown bat typically moves between 12 and 40 miles to roost locations. SLW’S Indiana bat study reports that Cape Vincent provides summer colony habitat, roosting and foraging areas for the Indiana Brown bat and also it documented that there is a maternity roost location in this same area. This is significant because Indiana bats have strong fidelity to summer colony areas, roosts and foraging habitat (USFWS1999). Radio telemetry studies in NY have shown this to be true for maternity roost locations as well where the Indiana bat forms maternity colonies of 20 to 100 members.
I am concerned that the Cape Vincent Indiana bat studies are insufficient. The length of time may not be sufficient to determine bat presence because weather conditions change from year to year and this could very well affect bat activity. The Cape Vincent test was conducted in July/August of 2007 but the report is not clear as to how many days were spent in the field and under what conditions.
I also noticed that the report on Indiana Bat Roost Trees and Emergence Counts on bats captured outside Cape Vincent, New York sampling by Sanders Environmental Inc. has a date of July & August, 2007. Upon going over the report prepared for the Horse creek wind farm in neighboring Clayton, New York, I noticed they reported in their study that they trapped their first Indiana bat on June 02, (although a gap in netting activities indicates that bats could have been present in late May) and the last radio telemetry location occurred on August 09. After July 31, capture rates significantly decreased. Depending on when the Cape Vincent studies were done this may have had an effect on the results also.
Sanders Environmental did not do thermal imaging or use acoustical radar. The Indiana brown bat is difficult to distinguish from the little brown bat therefore additional mist net surveys need to be conducted during the spring and the fall migration to understand the project area number and diversity of bats passing through the project area. These are extraordinary times and they call for extraordinary measures. We have an endangered species mysteriously dying off by the thousands. The Indiana bats have been affected by white nose syndrome, the mysterious ailment that has killed thousands of these bats. White nose syndrome has been identified among Indiana bats wintering in Glen Park. The issue of the white nose syndrome, and the fact that the Indiana bat is already an endangered species requires that we must move with great caution since this could become a critical issue for the Indiana bat’s survival.
St. Lawrence Wind Power has the potential to significantly impact the future survival of the Indiana bat because the fragmentation of habitat can have a negative effect bat on an already dwindling bat population.

Within 3/4 of a mile from the shores of Cape Vincent there already is an operational 86 turbine wind power plant on Wolfe Island, Canada. In Clayton, NY, Horse Creek wind farm is proposing to erect 62 turbines and another 77 turbine project is planned for Galoo Island. BP’s Cape Vincent wind project indicates their number is up to 140 Plus, slated for the area and SLW lists 53 turbines. That is the potential for a total of ~ 86 + 62 + 77 + 140 + 53 = 418 turbines. This means that potentially if all these projects come to fruition there would be 418 wind turbines within a 25 mile radius of the Indiana bat hibernacula in Glen Park, New York. Henderson, New York is also entertaining the idea of a wind farm and if the project that is developed it would only further increase the potential damaging effect on the bat population.
Already diminished in numbers, we are then going to assault this creature by fragmenting its habitat and destroying its foraging ground. Without a more extensive detailed study in Cape Vincent there is no way of knowing how many Indiana bats are actually in the area. In the case of such a sensitive issue studies should be done by an independent company, not one who depends on their lively hood from the wind companies. Another issue to consider is pressure changes that the spinning blades have on the lungs of the bats once the turbines become operational. This will also increase the mortality rate of an already endangered species and could become a critical issue in the future survival of the bat population especially considering the cumulative effects.
Lastly, were the transmission lines routes also included as part of the area being tested? St Lawrence Wind will be irreversibly committing resources to this project, resources that will cause the destruction of habitat, foraging areas and possibly causing irrevocable damage to this federally protected species. Not only do I think that the bat studies are inadequate but I think, that due to the plight of the Indiana bat and the sensitive nature of the area, the project should not be in Cape Vincent.


cc: Timothy Sullivan (U.S. Fish and Wildlife Service)
Bill Gordon (DEC Region 6)