“The Icebreaker Windpower project can be seen as entirely moot: there will be no meaningful benefit to Ohio and its citizens. The chimera of jobs and a boosted economy will never become material; the obvious loss to bird and bat life scarcely needs a comment.”
The heat is on for supporters of the six-turbine LEEDCo Icebreaker Windpower project offshore of Cleveland.
A show of “yeas” at the November 8th public meeting of the Ohio Power Siting Board (OPSB) at Cleveland City Hall failed to make a dent in the logical and passionate opposition. A few dozen supporters at a public meeting is not material for a facility that is uneconomical and environmentally invasive–and unneeded except for a poster child of what was Obama energy policy.
It is surprising that the OPSB has not closed the file on the now called “Icebreaker Windpower.” Much of the testimony in support of the proposal centered on job creation for Ohio, something that has noticeably not materially happened worldwide with wind projects.
Block Island, the US’s first offshore project of five massive and expensive turbines, reportedly created few hundred temporary construction jobs and about six permanent at a cost of $290 million, or $150,000 per powered household. This project is a monument to waste, an argument against offshore wind, not a demonstration project of any value.
Back to Icebreaker, another sector is losing jobs as wind’s infrastructure intrudes on normal activity. The Icebreaker project is just that: designed to be a ratepayer/taxpayer-subsidized preparatory school for a thousand, perhaps as many as 1,400, turbines in the waters of Lake Erie. There is much talk about “manufacturing supply chains,” and little about the cooperation/participation of rent-seekers from overseas.
Where do those subsidies end up? LEEDCo Icebreaker is now collaborating or consulting with Norwegian turbine heavyweight: Fred Olsen Renewables.
Others at the Cleveland Public Meeting focused on Ohio’s rich biodiversity, bird life, obvious density of migration intersections, and the need to protect the drinking water for 11 million persons. Passionate reminders of the migration routes, and certain environmental devastation were captured by Kim Kaufmann of BSBO (Black Swamp Bird Observatory), Pat Hersch and Tom Wasilewski, members of Great Lakes Wind Truth, all speaking strongly for the opposition, which must be in the millions.
Indeed, much of the opposition’s submissions and comments with the the US Department of Energy (DOE), US Army Corps of Engineers (USACE), and OPSB has centered around this inappropriateness of location and migration, migration, migration.
Needless to say, the entire Great Lakes and Region is inappropriate (if one can locate any appropriate placement), and if we use Wolfe Island as a gauge of the environmental damage, the prediction of substantial and “unacceptable” bird and bat kills in any of the Lakes, is irrefutable.
Objections have been reaching the OPSB regularly now for years. Despite the former Chairman Todd Snitchler’s formidable list of omissions, errors and evasions in process by LEEDCo (now FILE number: 16-1871 EL-BGN), a Draft EA to the DOE has been submitted via “Icebreaker Windpower,” consulting now with Norway’s Fred Olsen Renewables. Prior OPSB objections included ice throw, ecological considerations, noise, lack of appropriate technical data, as well as “contradictions, biases, omissions, and minimal assessments.”
Additional serious omissions or errors were noted in the environmental review materials provided by Kerlinger and Associates on behalf of LEEDCo. Letters from ODNR and FWS indicate numerous “Contradictions, biases, omissions, and minimal assessments.” Points 19 and 20 relate to the unscientific, biased, and facile studies given to the OPSB by LEEDCo. 19. The boat surveys monitoring birds appear to be biased relative to the results provided through the acoustic surveys. 20. It was suggested that risks to birds migrating in the project area were minimal. Based on the pelagic bird surveys conducted by the Division of Wildlife during 2011 and 2012, the results suggest that the area proposed is within areas of larger numbers of ring-billed and herring gulls. Both migrating water birds and waterfowl may be impacted by this wind facility through direct impact as well as displacement. (See the recent NA-PAW letter and comments re the EA to the DOE here.)
Master Resource reported on the sequential objections to the project as far back as in 2014. This is the same project, with the same omissions and errors, but infinitely more paper work.
Selective Application to Deny Intervenor Status
Of great current interest, is the Icebreaker application to deny Intervenor status to Cuyahoga County residents Vicci Weeks, and Caryn Good Seward and Steven Seward. As lawyer John Stock points out in his application to support the petition to Intervene, this is a transparent “attempt to quash any voice of opposition,” and is “antithetical to the cornerstone of American Jurisprudence…..”
Interestingly the LEEDCo promoters did not seek to quash other intervenors in support of the turbine project: Sierra Club, Ohio Environmental Council, Indiana/Kentucky/Ohio Regional Council of Carpenters (the “Carpenters), and the Offshore Wind Business Network. Lawyer John Stock refers to this seek to quash as “manipulative” and having possible ramifications across the country, if granted.
It is fairly clear again says Mr. Stock in his application, that the OPSB suspended the Procedural Schedule, based on objections raised by his clients, Weeks and Stewards, regarding the numerous “defects” in bird and bat studies and mitigations of the applicant’s petition. Mr. Stock also references details from a survey in the Plain Dealer, where 57.87 of those surveyed disapproved of the Icebreaker project, and many more with no opinion, despite Icebreaker’s contention that 400 public meetings showed approval. As some have now pointed out, holding a meeting does not confirm approval, and may in fact demonstrate the opposite.
In an especially clear and elegant manner, Mr. Stock concludes that his clients have a superior non-self-interested reason for objecting to the Icebreaker:
The Cuyahoga Residents possess a direct, real and substantial interest in protecting Lake Erie birds—not simply the derivative interest that Icebreaker admits justifies intervention by the Sierra Club, the Environmental Council, the Carpenters, or the Offshore Wind Business Network.
Questioning “Total Impact:” Critical Components of Monitoring Missing
Additional comments to DOE regarding the Draft EA were submitted, again, from international interested persons (UK), and Canada and the US. Of equal importance are the comments from the US Fish and Wildlife Service (USFWS), outlining again, that bat and bird analyses are incomplete. It is worthwhile quoting from the letter.
Our comments in this letter address our three outstanding concerns: 1) characterizing bird and bat use of the project area; 2) evaluating collision mortality of birds and bats from the operating project; and 3) monitoring to inform items 1 and 2. Section 2.7.2 of the Draft EA references the Memorandum of Understanding (MOU) between LEEDCo and the Ohio Department of Natural Resources (ODNR) committing to pre- and postconstruction wildlife monitoring and states that LEEDCo has had discussions with ODNR and the Service to develop a sampling plan that lays out testing and analyses that will be conducted before, during, and post-construction for birds and bats.
While the Service has been engaged in discussions with LEEDCo, please note that the Service is not a party to the MOU, and that only some of the Service recommendations on pre- and post-construction monitoring have been included in the MOU or sampling plan (See Service comments dated Feb. 28, 2017, attached). Also note that the MOU and sampling protocol do not provide detailed methods for several critical components of the pre-and most components of the post-construction monitoring. We recommend that DOE condition the funding of the project on inclusion of a robust pre- and postconstruction monitoring protocol reviewed and commented on by the Service, and that specific funding be targeted for this project component.
The conclusions reached in the Draft EA regarding potential impacts to birds and bats are based on available data collected primarily outside of the project area. For example, some of the data are from the Cleveland water intake crib (located approximately 3 miles offshore of Cleveland, approximately 5 miles from the project area) or nearshore areas of the lake near Cleveland. Additional data on bird use of the airspace were generated using NEXRAD weather radar data from the Cleveland area which provides limited data about bird and bat use within the airspace that will be occupied by the turbines (the “rotor-swept zone”).
Waterfowl surveys conducted by ODNR over Lake Erie several years ago that occurred in the project vicinity are used to inform waterfowl distribution within the project area. Collision mortality estimates were generated using land-based wind projects in the U.S. and Canada. The available bird and bat data is summarized in several appendices to the Draft EA (Appendices J, K, and L). Studies of bird and bat use of the specific project area have been recommended by the Service for several years (Attachment 1, Service correspondence dated April 24, 2009, November 15, 2013, March 24, 2014, October 21, 2016, February 28, 2017, March 3, 2017) but are just starting to be implemented. A bat acoustic study within the project area was started in spring 2017 and aerial waterfowl surveys will begin in fall 2017.
Data from these site-specific studies are not available 3 for inclusion in the Draft EA, though the first quarterly report for the bat acoustic survey was recently provided to the Service. Thus, the conclusions in the Draft EA are based on assumptions that observations from other parts of Lake Erie are relevant to the project area, and that impacts at onshore wind facilities in the U.S. and Canada are relevant predictors of impacts to birds and bats at offshore wind developments in Lake Erie. These assumptions may or may not be accurate.
Because of the potential risk of bird and bat mortality, and because this project is designed to be a demonstration project to evaluate offshore wind installation in the Great Lakes, pre-construction monitoring to inform risk and post-construction monitoring to assess actual impacts are necessary components of the project that must be implemented. (Our emphasis)
Should the findings of site-specific pre-construction monitoring yield results that contradict the assumptions in the Draft EA, the findings in the Draft EA should be revisited to ensure accurate information on risk to birds and bats is publicly available. All pre- and post-construction data should be made publicly available such that this project can inform future project planning.
We note that the small size of the project (6 turbines) is driving the effects analysis relative to potential impacts to birds and bats. That is to say, because there are only 6 turbines, even if the per-turbine mortality rates for bird or bats at the project area were to be much higher than at land-based wind projects, the total impact of this project will be minor. While that may be true, one goal of this demonstration project should be to measure what the actual effect of offshore turbines is on birds and bats, to inform potential future wind development in the Great Lakes. If per-turbine impacts are not accurately measured for this precedent-setting project, risk levels of larger future projects may be substantially underestimated.…
While the density of migrating passerines over Lake Erie may be “less than half” than the density over land based on the NEXRAD analysis (Nations and Gordon 2017), there are still likely to be millions of individual birds crossing Lake Erie during spring and fall migration each year, and a proportion of these are flying at altitudes within the rotor-swept zone (our emphasis) (Horton et al. 2016, also see Attachment 2).
Weather patterns likely influence large migration events to some degree, although these patterns are probably complex (Newton, 2008). Among birds, passerines comprise the majority of mortality at wind power projects. With the available data we are unable to estimate how many passerines might be crossing through the project area while flying at altitudes within the rotor-swept zone, and thus that might be at risk of collision with the turbines. The Service recommended conducting a radar study to evaluate this risk, but implementation of the study within the project area has not occurred to date.
Birds also generally migrate at heights above rotor sweep but they still get killed regularly. This can be attributed to birds (and I’m sure butterflies) being killed during the period when gaining and losing altitude, as well as during foraging flights.
Most if not all offshore turbines would be placed fairly close to shore as they must be affixed to the substrate. Based on this and at least one observation of butterfly lake crossing in the document you attached, I suspect most if not all butterflies crossing Lake Erie would be within rotor sweep height while gaining and/or losing altitude.
Cleveland and parks nearby provide significant roosting and resting positions for migrations across Lake Erie.
We imagine that the OPSB will continue to receive comments and objections: the hundreds perhaps who have enjoined to support this ignoble proposal, are outnumbered by millions, without any exaggeration, worldwide, and especially in North America both sides of the border, crying foul and objectionable, and “intolerable,” as Craig Rucker of CFACT (Committee For a Constructive Tomorrow) indicates.
Ohio is home to serious birding efforts, creating an economy with its own magnetic economy. Birding in Northwest Ohio in one spring, accounted for a boost of $30 million. The Ohio Sea Grant reports that tourism related to birdwatching in Ohio in six natural areas along Lake Erie,
generated $26,438,398 in 2011, created 283 jobs for those living and working in these coastal communities, generated $8.9 million in personal income, and contributed $1.9 million tax revenues directed to local and state coffers. Birders visiting Lake Erie provide significant revenue infusions to the regions year around.
(Enormous public interest has occurred this week, November 12, 2017, at the home of Tania Perry, Delaware OH, where more than 500 people have gathered to get a small glimpse of Ohio’s newest celebrity: weighing less than a ping pong ball, (point zero nine of an ounce), the super star Calliope hummingbird is a “mega rarity” this side of the Rockies. This rarely seen tiny bird has its own Facebook page. Ohio naturalist Jim McCormack says this is likely the most photographed hummingbird in the world.)
Misinformation by Western EcoSystems: “few birds venture”
Mr. Gordon of Western EcoSystems, environmental agency engaged by the developer, indicates that he is a bird lover, and that there are very few birds that venture out to the project site. “We’re in a zone where there’s not many waterfowl out there,” Gordon said. This statement is patently false and in stark contrast to evidence of the well-known bird, waterfowl included, abundance, sheer abundance, on the shores and offshore of Lake Erie. Ducks Unlimited, the world leader in wetlands conservation, points to Ohio as having one of the largest concentrations of wetlands organizations in North America.
The need to protect this migration route on steroids is abundantly clear in submissions to the DOE, USACE and OPSB. One submission included this note by US wildlife and wind energy specialist, Jim Wiegand:
“…. 400 bird species have been documented in this region. Visiting birders travel to this region of northwest Ohio. Lake Erie marshes make up the largest stopover habitats in the eastern United States between coastal habitats and northern breeding areas.” “On a single aerial survey done on November 16 of this year, 201,016 water birds were counted, including ducks, geese, swans, cormorants and eagles, all within the offshore waters of western Lake Erie.”
These high numbers are very significant, and create an entirely different scenario than those given in this project’s contrived bird surveys. (Jim Wiegand, letter to DOE, 2016)
From Spain, Raptor expert Mark Duchamp writes also that Western EcoSystems are “married” to the wind industry, and should not be counted on to report accurate predictions of mortality.
Western EcoSystems are not acceptable. They are practically married to the wind industry. Consultants should not be hired by the promoter: This is a clear conflict of interest. They should bear the approval of opponents to the Project. (Email communication)
More than a hundred more signatories and environmental groups in opposition added their voices to various letters to the OPSB. The Hawk Migration Association of North America, HMANA, additionally wrote of concerns of the improper siting of the project in the well-known migration routes of the Lakes.
This cumulative objection numbers in millions of interested persons, agencies and groups in the hundreds, from Spain, Germany, Denmark, Ireland, the UK, Slovenia, Australia, France and more. Some of these letters can be viewed on Great Lakes Wind Truth. Needless to say, signatories also include residents and groups from Ohio, New York, Michigan, and Ontario, Canada.
The Icebreaker Windpower project can be seen as entirely moot: there will be no meaningful benefit to Ohio and its citizens. The chimera of jobs and a boosted economy will never become material; the obvious loss to bird and bat life scarcely needs a comment.
The DOE has the responsibility of fielding the project, determining if a “No Action” approach has more merit. It is challenged with the LEEDCo (Icebreaker) expressed and USACE defined mandate of:
None of these objectives can or will be met with this “demonstration” project. If the OPSB reflects accurately on the comments and submissions, we believe that the result will be another laundry list of requirements, perhaps this time, terminal for a misguided, massively expensive, useless, “demonstration” idea.