AN EVALUATION OF THE WILDLIFE IMPACTS OF OFFSHORE WIND DEVELOPMENT RELATIVE TO FOSSIL FUEL POWER PRODUCTION

by Christina M. Jarvis

A thesis submitted to the Faculty of the University of Delaware in partial fulfillment of the requirements for the degree of Master of Marine Policy

Fall 2005

Copyright 2005 Christina M. Jarvis All Rights Reserved

AN EVALUATION OF THE WILDLIFE IMPACTS OF OFFSHORE WIND DEVELOPMENT RELATIVE TO FOSSIL FUEL POWER PRODUCTION

by Christina M. Jarvis

Approved:

__________________________________________________________ Willett M. Kempton, Ph.D. Professor in charge of thesis on behalf of the Advisory Committee

Approved:

__________________________________________________________ Nancy M. Targett, Ph.D. Interim Dean of the Graduate College of Marine Studies

Approved:

__________________________________________________________ Conrado M. Gempesaw II, Ph.D. Vice Provost for Academic and International Programs

ACKNOWLEDGMENTS I would like to thank my advisor and committee chairperson, Dr. Willett Kempton, for his guidance and insight throughout my time in the Graduate College of Marine Studies, and for stimulating my interest in offshore wind energy. I would also like to thank my committee members, Dr. Jeremy Firestone of the University of Delaware's Graduate College of Marine Studies, and Dr. Jonathan Miles of James Madison University, for their invaluable input and for the unique perspectives they each brought to my thesis research. I am grateful to Paul Kerlinger, Ph.D., for his assistance in locating valuable references for this thesis research. I would like to thank the faculty, staff, and especially my fellow graduate students within the University of Delaware's Graduate College of Marine Studies, for making these past two years so memorable and rewarding. Lastly, my love and thanks to my family, who have supported me and believed in me throughout the entire graduate school process.

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TABLE OF CONTENTS

LIST OF TABLES............................................................................................................ vii LIST OF FIGURES ......................................................................................................... viii ABSTRACT....................................................................................................................... ix INTRODUCTION............................................................................................................. 1 1.1. 1.2. 1.3. 1.4. Context for thesis research.................................................................................. 1 Goals of research and policy significance .......................................................... 3 Research questions.............................................................................................. 4 Description of chapters ....................................................................................... 4

LITERATURE REVIEW ................................................................................................ 6 2.1. 2.2. 2.3. Growth of wind energy ....................................................................................... 6 Offshore wind facilities around the world .......................................................... 7 Offshore wind development within the United States ........................................ 8

2.4. Advantages/benefits of offshore site................................................................... 9 2.4.1 Physical advantages ........................................................................................ 9 2.4.2 Economic advantages.................................................................................... 10 2.4.3 Environmental advantages ............................................................................ 11 2.5. 2.6. 2.7. 2.8. 2.9. Disadvantages ................................................................................................... 13 Wildlife impacts of offshore wind development .............................................. 14 Current regulatory status of offshore wind development in United States....... 20 Pew Oceans Commission and the US Commission on Ocean Policy .............. 22 Impacts of Power Plants on Wildlife Species ................................................... 24

2.10. Direct impacts ................................................................................................... 24 2.10.1 Impingement ............................................................................................. 24 2.10.2 Entrainment............................................................................................... 25

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2.10.3

Thermal discharge..................................................................................... 26

2.11. Indirect impacts................................................................................................. 27 2.11.1 Oil spills .................................................................................................... 27 2.11.2 Acid precipitation...................................................................................... 30 2.11.3 Mercury contamination............................................................................. 32 2.12. 2.13. Other ................................................................................................................. 33 Summary ........................................................................................................... 35

RESEARCH METHODOLOGY .................................................................................. 36 WILDLIFE IMPACTS................................................................................................... 39 4.1. Case Study of an Offshore Wind Site ............................................................... 40 4.2. Wildlife impacts................................................................................................ 41 4.2.1. Marine mammals and sea turtles................................................................... 41 4.2.2. Fish................................................................................................................ 50 4.2.3. Benthic organisms......................................................................................... 53 4.2.4. Birds.............................................................................................................. 55 4.3. 4.4. Summary of wind-related wildlife impacts....................................................... 62 Case Study of a Fossil Fuel Burning Power Plant ............................................ 64

4.5. Wildlife impacts................................................................................................ 66 4.5.1. Direct impacts ............................................................................................... 67 4.5.2. Indirect impacts............................................................................................. 71 4.6. Summary of fossil-fuel related wildlife impacts............................................... 77

COMPARATIVE ANALYSIS....................................................................................... 79 5.1. 5.2. 5.3. 5.4. 5.5. Scaling Factors Used for Size Comparison ...................................................... 79 Wildlife Impacts of Fuel Resource ................................................................... 80 Wildlife Impacts of Site Footprint .................................................................... 84 Wildlife Impacts of Site Operation ................................................................... 88 Summary ........................................................................................................... 95

CONCLUSION ............................................................................................................... 98

REFERENCES.............................................................................................................. 105 APPENDIX.................................................................................................................... 113

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LIST OF TABLES

Table 5.1: Scaling factors used for coal, oil, and wind.................................................... 80 Table 5.2: Calculated bird mortality in Buzzards Bay as a result of oil spills, 1969-2003 ................................................................................................................................... 82 Table 5.3: Land area requirements of the Cape Wind facility......................................... 85 Table 5.4: Land area requirements for Cape Wind and Brayton Point............................ 87 Table 5.5: Life cycle emissions of wind compared to coal power plants, including manufacturing, operations, and fuel.......................................................................... 93 Table 5.6: Impacts of Cape Wind and Brayton Point on four different types of wildlife species ....................................................................................................................... 94 Table 5.7: Summary of types of impacts from Cape Wind and Brayton Point ............... 96

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LIST OF FIGURES Figure A.1: Map of southeastern Massachusetts showing Brayton Point Station and the proposed Cape Wind site. ....................................................................................... 113

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ABSTRACT Off the eastern coast of the United States lies a unique and untapped natural resource that has only recently been recognized: offshore wind energy. Hailed by many as a clean, virtually limitless source of renewable energy, offshore wind energy has great potential for reducing air pollution, lessening the United States dependence on foreign oil supply, and mitigating the impacts of global climate change. The promises of offshore wind energy, however, are not without pitfalls. Potential adverse impacts on local and migrating wildlife species are frequently cited as an important issue of concern when considering the development and siting of an offshore wind facility. These concerns are not without merit: impacts to wildlife species may occur during all phases of offshore wind development, and include habitat alteration, habitat displacement, increased levels of underwater noise and vibration, and in some cases, mortality. While public opposition to offshore wind development often focuses around concerns for wildlife species, current methods of energy production, such as fossil fuel power plants, impact wildlife species as well. These impacts include the annual entrainment and impingement of billions of aquatic organisms on a power plants cooling water intake screens, thermal pollution resulting from the discharge of heated cooling water back into the water body from which it was withdrawn, habitat alteration from the extraction, processing, and transportation of coal or oil to a power plant, heavy metal contamination of aquatic environments from air emissions, and the acidification of aquatic and terrestrial habitats.

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This thesis compares the wildlife impacts of offshore wind development to the wildlife impacts of fossil fuel power production. Such a comparison has, to date, been absent from the debate over offshore wind technology. This research attempts to better understand the wildlife impacts of offshore wind energy, and inform the debate over offshore wind power, by considering the wildlife impacts of the proposed Cape Wind facility (off Cape Cod, MA) in light of the wildlife impacts of the nearby Brayton Point power plant (Somerset, MA). These two facilities are geographically proximate and serve the same power pool. Data were obtained from existing literature, including grey literature, rather than from field measurements. Quantitative comparisons were adjusted for differences in electrical output between the two power plants. This research concludes that from a quantitative perspective, Brayton Point has a larger impact on wildlife species than Cape Wind. The former includes hundreds of birds killed by oil spills, thousands of acres of land disturbed, and billions of fish, fish larvae, and fish eggs killed annually by entrainment, impingement, and thermal discharge. The effects of acid precipitation and heavy metal contamination are also known to have long-lasting impacts on wildlife species, including habitat exclusion, physical impairment, and reduced breeding potential. While offshore wind facilities are not without their own set of adverse impacts on wildlife species, these impacts must not be viewed in isolation. It is only when the wildlife impacts of offshore wind development are compared relative to those from fossil fuel power production can they be truly understood.

Chapter 1 INTRODUCTION 1.1. Context for Thesis Research Off the east coast of the United States lies a unique and untapped natural resource that has only recently been recognized: offshore wind power. Although a complete assessment of the power-generating ability of offshore wind has yet to be undertaken, it is estimated that shallow-water areas (less than 30 meters of depth) off the New England and mid-Atlantic coast have the potential to produce 96 gigawatts (GW) of electricity per year. Put into context, this is approximately equal to the total land-based powergenerating ability of the coastal states from Maine to Maryland (Kempton et al., 2005). Harnessing offshore wind power will provide some of the largest and most energy-hungry cities of the east coast with a renewable source of energy, while reducing dependence on traditional, non-renewable sources of energy such as coal, oil, and natural gas. Replacing a portion of our non-renewable energy consumption with renewable offshore wind power may have far-reaching, long-term implications, such as the reduced operation of existing fossil fuel-fired power plants, a reduction in the number of new fossil fuel-fired power plants opened, improved human health, cleaner air, and clearer skies. The promises of offshore wind power, however, are not without pitfalls. The potential impacts an offshore wind facility may have on local and migrating wildlife

species are frequently identified by conservation groups, elected officials, and the public as an important issue of concern. Many of the areas proposed for offshore wind development provide habitat for various species of resident and migrating fish, marine mammals, marine turtles, invertebrates, and avian wildlife; however, the short-term, long-term, and cumulative impacts of offshore wind facilities on wildlife species have yet to be thoroughly studied. While public opposition to offshore wind development is focused in part on concerns for wildlife species, common methods of energy production such as fossil fuel burning power plants are not without their own impacts on wildlife species as well. Such impacts include entrainment and impingement of aquatic organisms on a power plant's cooling water intake screens; thermal pollution resulting from the discharge of heated cooling water back into the river, lake, estuary, or ocean from which it was withdrawn; habitat alteration from the extraction, processing, and transportation of coal or oil to a power plant; heavy metal (i.e., mercury) contamination of aquatic environments; and the acidification of aquatic habitats. Unfortunately, offshore wind development is frequently viewed in terms of its possible adverse impacts on wildlife species, rather than the adverse impacts on wildlife species from other sources of energy production that may be reduced by the incorporation of offshore wind technology. When considering the impacts a new technology, such as offshore wind power, may have on the environment, it is important to also consider the impacts of the existing energy-producing regime on the environment, as well as how these impacts may be lessened by incorporation of a newer technology (in this case, offshore wind). It is only

when offshore wind development is considered in this greater context can its true impacts on wildlife species be truly understood. To put this more simply, one must balance the costs of building an offshore wind facility against the costs of not building an offshore wind facility (Pasqualetti, Gipe, and Righter, 2002). 1.2. Goals of research and policy significance The overall goals of this thesis research are as follows: first, to provide a thorough synthesis of available information on interactions between wildlife species and offshore wind facilities. Such a review is currently lacking; instead, literature is available on the impacts of an offshore wind facility on a specific species of wildlife (i.e., birds or cetaceans), or from a particular aspect of offshore wind development (i.e., an increase in underwater noise and its associated impacts on marine mammals), rather than a comprehensive review of all the impacts to wildlife as a whole. Secondly, this research aims to provide a broader context for understanding the impacts of offshore wind development on wildlife species by examining similar environmental impacts of other methods of energy production methods of energy production that may be reduced or replaced by the growth of offshore wind development. This research has several important implications for the field of marine policy. First, it will be a valuable contribution to an emerging field of research, both domestically and internationally. Recent published literature and research conducted on offshore wind development has focused more on legal, regulatory, and social issues, rather than on wildlife impacts. This research aims to fill this gap. Secondly, this thesis provides a comparative analysis between the wildlife impacts of offshore wind development and the

wildlife impacts of fossil fuel power production that has not yet been done. This type of analysis will contribute to and inform the ongoing debate over offshore wind development by providing valuable information for policy makers, wind developers, Cape Cod residents, and the general public. 1.3. Research questions This research will address the following specific research questions, in order to fulfill the overall research goals stated above: What are the possible impacts (positive and negative) of offshore wind development on wildlife species? How do fossil fuel burning power plants impact wildlife species? What comparisons can be made between offshore wind facilities and fossil fuel burning power plants in terms of their impacts on wildlife?

Based on these research questions, this thesis will conclude which form of power generation has a greater impact on wildlife species. 1.4. Description of chapters Following this chapter is the literature review in Chapter 2. This chapter provides some background on offshore wind development both internationally and domestically, as well as a discussion of the current regulatory status of offshore wind development in the United States, to aid in the reader's understanding of this thesis. Chapter 2 also reviews available literature on the benefits and disadvantages of offshore wind development, the wildlife impacts of offshore wind development, and the impacts of power plants on wildlife species. Chapter 3 describes the methodology utilized for this research project.

Chapter 4 provides a discussion of the wildlife impacts of offshore wind development and fossil fuel power plants, using the Cape Wind site and the Brayton Point and Canal Electric Station Power Plants as case studies. Chapter 5 provides a comparative analysis of the wildlife impacts of Cape Wind and the wildlife impacts of Brayton Point. The final chapter summarizes the research findings of this thesis, considers the implications of this research on a broader level, and identifies areas where future research is needed.

Chapter 2 LITERATURE REVIEW The goal of this chapter is to 1) provide the reader with an overview of offshore wind development to aid in the reader's understanding of this thesis; 2) to review literature pertaining to the impacts of offshore wind development on wildlife species; and 3) to review literature on the impacts of power plants on wildlife species. In an effort to be as comprehensive as possible, the following sources were identified and searched for information relating to this thesis: peer-reviewed journal articles, published books, existing dissertations (available through the ProQuest Digital Dissertations database), and gray literature1, including government publications. A key finding of this literature search is the limited number of peer-reviewed studies and a lack of existing dissertations or published books specifically addressing the wildlife impacts of offshore wind farms. This research aims to help fill that gap. 2.1. Growth of wind energy The potential for offshore wind development has only gained nationwide attention in the United States in the past several years, although large-scale land-based wind facilities have been in operation in the United States since the early 1980s (Pasqualetti,

Gray literature is defined as "foreign or domestic open source material that usually is available through specialized channels and may not enter normal channels or systems of publication, distribution, bibliographic control, or acquisition by booksellers or subscription agents" (Source: http://www.osti.gov/graylit; accessed 15 February 2005).

Gipe, and Righter, 2002). California was the first state to develop large-scale land-based wind farms in 1981. By the mid-1990s, California was producing almost half the worldwide production of wind-generated electricity (Gipe, 1995). The American Wind Energy Association (AWEA) identifies 29 states with landbased wind facilities, ranging in size from a single turbine (e.g. Utah) that produces less than 0.5 megawatts (MW), to thousands of turbines (e.g., California) that produce more than 2000 MW. According to the AWEA, the total installed wind energy-generating capacity of the United States (as of January 2005) is 6740 MW (AWEA, 2005). 2.2. Offshore wind facilities around the world Land-based wind energy experienced worldwide growth throughout the 1980s and 1990s, with the majority of wind energy installed in European countries, notably Germany, Spain, and Denmark. Public acceptance of land-based wind facilities, however, has been hampered by opposition to the aesthetic intrusiveness wind turbines impart on the local landscape, as well as by the "not in my backyard" attitude of many residents whose communities are in close proximity to existing or planned wind facilities (Pasqualetti, Gipe, and Righter, 2002). The concept of moving wind facilities out of the "backyards" of communities and into the ocean where presumably such facilities would be less visibly obtrusive to local communities was first proposed in the 1970s, although the world's first offshore wind facility was not built for another twenty years (Manwell, McGowan, and Rogers, 2002). Denmark quickly established itself as a leader in offshore wind development with the

construction of the world's first two offshore facilities: Vindeby (1991) and Tun Knob (1995) (Clausager, 1998). The market for offshore wind power experienced tremendous growth throughout the 1990s and the early part of the 2000s. Beurskens and de Noord (2003) estimated a growth in average annual offshore wind energy capacity in Europe of 43 percent during the period 1991-2002. By 2006, installed capacity in Europe is estimated to be 3.2 to 3.4 gigawatts (GW). Offshore wind facilities are presently in operation off the coasts of Denmark, the Netherlands, Sweden, Ireland, and the United Kingdom; offshore projects are currently planned in Belgium, Finland, France, Germany, Poland, and Spain (Beurskens and de Noord, 2003). 2.3. Offshore wind development within the United States In the United States, plans for offshore wind facilities are still in the midst of development and permitting processes. Cape Wind Associates LLC (Cape Wind) and Winergy LLC (Winergy) are two developers of offshore wind facilities in the United States. Cape Wind is actively pursuing the development of a 24 square mile offshore wind farm in Nantucket Sound off the coast of Massachusetts. If it becomes operable, Cape Wind is expected to be the nation's first offshore wind facility. Totaling 420 MW, the Cape Wind site will consist of 130 turbines. A draft environmental impact statement (DEIS) for the Cape Wind site was released by the United States Army Corps of Engineers (USACE) in December 2004. The final environmental impact statement is expected to be released in 2006, and if approved, construction on the Cape Wind site will likely commence in 2006 or 2007(Capewind, 2005).

Winergy has identified approximately fourteen potential offshore wind farm sites along the east coast of the United States, and is in the process of applying for permits to these sites from the USACE. The fourteen sites are located off the coasts of Massachusetts, New York, New Jersey, Delaware, Maryland, and Virginia. The fourteen proposed sites total more than 8000 MW (Winergy, 2005). Two other potential developers of offshore wind power in the United States include the Long Island Power Authority (LIPA) and the Bald Eagle Power Company, Inc. (BEPC). LIPA is sponsoring the development of a 52 square nautical mile offshore site south of Long Island, New York, consisting of approximately 40 turbines (3.6 MW each). In late January 2003 LIPA issued a request for proposal from various developers for the actual development of this site (LIPA, 2005). The contract has since been awarded to FPL Energy, LLC (pers. comm. between Phillip Whitaker and Mark Dougherty on 2/11/2005). BEPC, a New York city-based developer, is proposing the development of an offshore hydrogen wind farm off the southern coast of Long Island. As envisioned by BEPC, the offshore wind farm would consist of 3.6 MW turbines producing approximately 560 MW (BEPC, 2005). 2.4. Advantages/benefits of offshore sites 2.4.1 Physical advantages

Offshore locations have several advantages over land-based locations for the siting of wind farms. Offshore sites offer stronger and more consistent wind strength than land-based sites. Santora, Hade, and Odell (2004) note that wind speeds in the

ocean may be as much as 20 percent higher than wind speeds on land. In addition, offshore sites provide large tracts of open, unimpeded space (a relatively scarce resource on land), and may be less physically intrusive on nearby communities in terms of noise and visual impacts (Santora, Hade, and Odell, 2004). 2.4.2 Economic advantages

Aside from its physical advantages, wind power has economic advantages as well. For example, wind-generated electricity is expected to have less fluctuation in price as compared to fossil fuel-generated electricity, due to low or non-existent resource extraction, processing, transportation, and/or combustion costs (NWCC, 2002). In addition, wind is a freely available natural resource; therefore, it is not subject to the widely fluctuating costs frequently associated with other fuels. Gipe (1995) compared the cost per kilowatt-hour (kWh) of a land-based wind power plant in California to other sources of electricity (including coal-, nuclear-, oil-, and gas-powered facilities), and found the average cost per kWh (including operation, maintenance, and fuel costs) of the wind plant to be one-half to one-third the cost of the other plants. From an employment perspective, wind facilities are considered to be laborintensive; that is, they require more labor per MW of electricity generated that any other electricity generator. According to the National Wind Coordinating Committee (NWCC), "wind energy produced more jobs per dollar invested or per kilowatt-hour generated than most conventional resources" (NWCC, 1997). Wind facilities also require regular inspections, maintenance, and repair, generating employment for the communities

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in which they are located (Greenpeace and European Wind Energy Association 2002, as qtd. in Kempton et al., 2005). 2.4.3 Environmental advantages

Fossil fuel burning power plants are believed to influence the earth's climate by increasing anthropogenic sources of carbon dioxide, a commonly recognized "greenhouse gas." Should offshore wind facilities assume a significant role in the energy consumption framework of the United States and reduce dependence on fossil fuel-burning power plants, the amount of anthropogenic carbon dioxide emitted into the atmosphere could be significantly lessened. Additionally, the reduction in other air pollutants will almost certainly have many positive environmental and health-related benefits, aside from their potential climate-related effects. Increased use of offshore wind energy may have positive impacts on more than just air quality. A 2003 study by Caldeira and Wickett indicates that anthropogenic carbon dioxide emitted into the atmosphere from fossil fuel combustion is eventually absorbed by the oceans. As oceans absorb greater quantities of carbon dioxide, pH levels drop, resulting in higher acidity of ocean waters. An increase in ocean acidity may result in uncertain -- but potentially adverse -- impacts on marine life (Caldeira and Wickett, 2003). The increased use of a clean-burning source of energy, such as offshore wind power, may slow ocean acidification by reducing the amount of anthropogenic carbon dioxide available for absorption by the oceans, thus improving the quality of marine habitats.

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Another advantage of offshore wind facilities is the potential for the turbines to serve as artificial habitat for marine species (the "artificial reef" effect). Artificial reefs, often in the form of old subway cars, concrete ballasted tires, or decommissioned military ships, have been deployed in coastal waters around the United States, including the east coast, the Gulf of Mexico, and California. Artificial reefs provide environmental benefits in the form of new habitat for fish, shellfish, crustaceans, and other invertebrates in areas where natural habitat is scarce (i.e., the mid-Atlantic region of the United States, where bottom substrate usually consists of mud and sand). Artificial reefs also provide economic benefits by creating new fishing grounds for anglers, providing new diving locations for recreational water-sports enthusiasts and marine photographers, and providing employment for workers tasked with decommissioning abandoned structures and creating artificial reef structures (DNREC, 2004 and NJ Department of Fish and Wildlife, 2004). Peer-reviewed literature on the artificial reef effect of offshore wind turbines is not available at this time; however, a fairly wide body of literature is available on artificial reef effects of oil and gas platforms. Love, Schroeder, and Nishimoto (2003) provide an excellent overview of fish populations at both oil and gas platforms and natural outcroppings off the California coast, and Rilov and Benayahu (2000) provide a thorough discussion on fish assemblage around oil jetties located in the northern Red Sea. Readers are referred to these sources for more detailed information regarding artificial reef effects of man-made structures in the ocean.

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2.5.

Disadvantages One of the more controversial issues surrounding offshore wind facilities is the

aesthetic effect of an offshore site on the horizon, as well as on the local communities and residents for whom the facilities will be visible. The Cape Wind project in Nantucket, Massachusetts has generated strong opposition from local residents due in large part to concern over aesthetic impacts. A 2005 study by Kempton et al. identifies the following as possible explanations for local opposition to the Cape Wind project: Nantucket Sound is a unique place where human structures do not belong; the wind project would be better suited for development on land; and the wind project will have a localized impact yet not allow for local control. Beurskens and de Noord (2003) note that offshore turbines are less physically accessible and face harsher conditions (i.e., corrosion from saltwater; increased physical stress from pounding waves and ice) than land-based wind farms, resulting in higher maintenance costs. The construction, operation, and decommissioning of offshore wind facilities may have adverse effects on the marine environment and marine wildlife species, including habitat fragmentation, increased sedimentation and turbidity around turbines, increased levels of underwater noise and vibrations, effects from electromagnetic fields around power cables, navigational hazards, and collisions between birds and turbine blades. Many of the areas proposed for offshore wind development provide habitat for various species of fish, marine mammals, marine turtles, invertebrates, and birds; however, a thorough review of the short-term, long-term, and cumulative impacts of offshore wind

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facilities on these species has yet to be conducted. Since the impacts of offshore wind development on wildlife species are a central theme of this thesis research, this topic is discussed in greater detail in the following section. 2.6. Wildlife impacts of offshore wind development Available literature on the impacts of offshore wind development on wildlife species is scarce, most likely due to the fact that offshore wind development is a relatively new and emerging field, and sufficient time has not passed for appropriate "before and after" evaluations of the effects of existing offshore wind development on wildlife species. Recent literature has instead focused more on the regulatory and social aspects of offshore wind development; for example, see Santora, Hade, and Odell (2004), Firestone et al. (2004), Hartland (2003), and Kempton et al. (2005). After a review of peer-reviewed literature, books, and dissertations, only three peer-reviewed journal articles were identified that specifically address offshore wind development and wildlife interactions. The mere fact that these studies, discussed in more detail below, are the only ones of their kind emphasize the great need for more research into the impacts of offshore wind development on wildlife species. Koschinski et al. (2003) find that porpoises and seals are capable of detecting low frequency sounds (defined by NRDC 1999 as sounds below 1000 Hertz) emitted by a simulated 2 MW offshore wind turbine. This finding is supported by the surfacing of both harbor seals and porpoises at a significantly greater distance from the simulated sound source while it was in operation than during control experiments. Porpoises were also found to have extended echolocation activity during the simulated operation of the

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wind turbine, indicating that they were aware of the noise and were exploring it with their bio-sonar. While the study does not specifically indicate an adverse effect on the seals and porpoises from the low frequency sound, it does indicate a reaction by the marine mammals. Koschinski et al. (2003) suggest that marine mammals may also suffer indirect effects of noise from a wind turbine, such as prey fish avoiding the sound source and the masking of marine mammals' mating and communication calls by noise emitted during operation of wind turbines. According to Exo, Hppop, and Garthe (2003), the risk of avian collisions with turbines is greater at offshore wind farms than land-based wind farms, as marine areas tend to be richer in biodiversity, are more ecologically sensitive, and impart a larger "footprint" on the marine environment than land-based facilities. Birds may be affected by offshore wind development through collisions with turbines, short-term habitat loss during construction activities, long-term habitat loss during maintenance activities, turbines acting as barriers to flight, and turbines acting as barriers to ecological sites such as roosting and feeding grounds. Habitat disturbance and barrier effects of turbines are identified as the impacts with the greatest potential for conflict with birds (Exo, Hppop, and Garthe, 2003). Garthe and Hppop (2004) developed a wind sensitivity index (WSI) to measure the effects of marine wind farms on seabirds in the North Sea. Based on nine vulnerability factors, black- and red-throated divers are identified as having the highest sensitivity index values, indicating that they may be particularly vulnerable to the effects of marine wind farms. Coastal waters of the southeastern North Sea have higher WSI

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values than offshore waters. A WSI may be useful in the preparation of environmental impact assessments, and may assist in the decision-making process for the siting of future offshore wind farms (Garthe and Hppop, 2004). In an unpublished undergraduate honors thesis, Tingley (2003) examines the potential impacts of offshore wind turbines on birds, including avian collisions with turbines and rotor blades, habitat disturbance (i.e., noise disturbance and the turbines themselves serving as barriers to flight), habitat alteration (i.e., turbines may serve as an artificial reef for aquatic habitat, thus altering the food resource available for birds), and impacts from federally-mandated lighting requirements for offshore turbines. Tingley (2003) specifically analyzes potential avian impacts from the proposed Cape Wind project, and finds that direct collisions with turbines and rotor blades pose the greatest threat to birds, particularly amongst local birds, migrating land birds, and migrating seabirds. Risks, however, vary with season, weather, and time of day. Suggested mitigation methods include the cessation of turbine operation during peak nocturnal fall migration; manipulation of turbine lights so as to avoid disorienting birds, particularly during inclement weather events; and site designs that allow migrating birds to see turbines and navigate around them (i.e., small clumps of turbines with maximum distance between clumps). Tingley (2003) emphasizes the need for improved data (especially baseline data) and intense monitoring efforts as offshore wind development moves closer to reality in the United States. Outside of peer-reviewed literature, a fairly extensive body of gray literature exists on the subject of wildlife interactions with offshore wind turbines. For example, a

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number of environmental reports and environmental impact assessments have been prepared for European offshore wind sites, including Horns Rev (Denmark), Nysted (Denmark), Middelgrunden (Denmark), Arklow Bank (Ireland), and Liverpool Bay (United Kingdom). The Marine Institute, Ireland's national agency for marine research and development, published a 2000 report titled "Assessment of Impact of Offshore Wind Energy Structures on the Marine Environment." COWRIE (Collaborative Offshore Wind Energy Research into the Environment) has commissioned reports on underwater noise generated by offshore wind farms, electromagnetic fields generated by cables connecting offshore wind turbines to one another, and the impacts of offshore wind farms on birds. The European Commission sponsored a 2001 report entitled "Concerted Action on Offshore Wind Energy in Europe," with Chapter 7 devoted in part to the environmental impacts of offshore wind development. The findings of some of these reports and publications will be analyzed in more detail in subsequent sections of this thesis. Two other reports found in the gray literature that directly address wildlife interactions with offshore wind facilities include Vella (2002) and Dolman, Simmonds, and Keith (2003). Vella (2002) examines the possible impacts of underwater noise and vibration from an offshore wind turbine on four groups of marine wildlife: squid and lobster; fish; seals; and whales and dolphins. Based on limited available data, Vella (2002) concludes that seals, dolphins, and porpoises may initially avoid offshore wind farms (most commonly during construction activities), then habituate to noise levels and possibly use offshore wind sites as feeding grounds. Fish may aggregate around offshore turbines in much the same way that oil platforms have provided habitat for mussels,

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barnacles, tubeworms, sponges, soft corals, and other invertebrate species (Vella, 2002). These conclusions, however, are based on limited data on the auditory sensitivity of marine species, and Vella (2002) stresses the need for additional monitoring studies on the impacts of offshore wind facilities on marine wildlife species. Dolman, Simmonds, and Keith (2003) examine both short- and long-term impacts of offshore wind farms on marine wildlife. Activities with short-term impacts on marine wildlife, such as those activities occurring during the construction and decommissioning phases of offshore wind development, include seismic exploration, drilling and dredging operations, increased vessel traffic, and cable-laying activities. Activities with long-term impacts on marine wildlife, such as those activities occurring during the operation of a wind farm, include the actual presence of the structures themselves, noise and vibrations from the continuous operation of the turbines, the generation of electromagnetic fields from cables, and increased vessel traffic (Dolman, Simmonds, and Keith, 2003). Although the Dolman, Simmonds, and Keith (2003) study stops short of providing quantitative data on the impacts of offshore wind development on marine species, the study calls for the following actions: 1) improved baseline data, particularly in regards to the abundance and distribution of cetacean species; 2) a sufficient environmental impact assessment process that considers impacts from the planning phase all the way to decommissioning phase; 3) a regional-scale assessment that considers the impacts from offshore wind development along with impacts from other local activities; 4) public consultation at every phase of offshore development; 5) cooperation among government agencies, researchers, and offshore developers; and 6) international

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cooperation to develop an international environmental assessment (Dolman, Simmonds, and Keith, 2003). Lastly, valuable information concerning the impacts of offshore wind development on wildlife species may be drawn through analysis of similar information available for land-based wind facilities. The NWCC provides a comprehensive review of existing studies on avian collisions with wind turbines (Erickson et al., 2001). According to the NWCC report, there is an average of 2.19 bird deaths per turbine per year in the United States for all species combined, with an annual range of approximately 10-40,000 bird deaths per year. De Lucas, Janss, and Ferrer (2004) studied the effects of a wind farm on local, breeding, and migratory bird populations in the Straits of Gibraltar, an important bird migration point between Europe and Africa. According to this study, soaring birds are able to detect and avoid wind turbines by changing their flight direction. Bird mortality due to collisions with turbines was 0.03 birds/turbine/year (De Lucas, Janss, and Ferrer, 2004). Barrios and Rodriguez (2004) also examined the effects of two wind farms on soaring birds in the Straits of Gibraltar. The total mortality rate for the two wind farms combined was 0.270 birds/turbine/year (Barrios and Rodriguez, 2004). Most recently, Smallwood and Thelander (2005) published the results of a three and a half year study on bird mortality in the Altamont Pass wind resource area of California. The purpose of this study was to quantify bird use, evaluate flying behaviors, and identify relationships between bird behavior and bird mortality. The study concluded that "birds are aware of operating wind turbines and take measures to avoid moving wind turbine blades, but raptor species flew within the areas 50 [meters] from wind turbines

19

several times more often than expected by chance" (Smallwood and Thelander, 2005). The authors of the study make a number of recommendations as a result of their research, including alteration of habitat within 50 meters of wind turbines, in order to reduce prey vulnerability to raptor predation and ultimately reducing raptor use of these 50 meter zones; a cessation in operation of the wind turbines during the winter months; the incorporation of new rotor blade painting schemes; and the purchase of conservation easements for the protection of raptor habitat outside the Altamont Pass wind resource area, as a means of offsetting raptor impacts that cannot be avoided (Smallwood and Thelander, 2005). 2.7. Current regulatory status of offshore wind development in United States Given the relatively recent emergence of the offshore wind industry in the United States, it is hardly surprising that a comprehensive management regime for the regulation of offshore wind development is currently lacking in the United States. As Firestone et al. (2004, 72) note, "any attempt to develop the promise of these new [ocean] uses requires government to spin together a hodgepodge of laws that were enacted prior to the development of these technologies and without the benefit of having them in mind." Traditionally, control over offshore development in the United States rests primarily with the USACE. The USACE is tasked with overseeing the permitting process for offshore development, deriving this authority from Section 10 of the U.S. Rivers and Harbors Act of 1899. Section 10 of the Rivers and Harbors Act prohibits the alteration or obstruction of any navigable water of the United States without prior approval and an appropriate permit from the USACE (33 U.S.C. 403). While reviewing applications for permits

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falling under Section 10, the USACE is required to coordinate and consult with appropriate federal agencies. These agencies vary according to the specific circumstances of the proposed project. For offshore wind development, the appropriate federal agencies may include the United States Fish and Wildlife Service (USFWS), the National Marine Fisheries Service (NMFS), the Minerals Management Service (MMS), the USEPA, the United States Coast Guard (USCG), and the Federal Aviation Administration (FAA) (U.S. Commission on Ocean Policy, 2004 and Firestone et al., 2004). In August 2005 the Energy Policy Act of 2005 was signed into law. This law effectively places regulatory control over offshore wind development with the MMS of the United States Department of the Interior2. In particular, Section 388 of the Act ("Alternate Energy-Related Uses on the Outer Continental Shelf") authorizes the MMS to grant leases, easements, or right-of-ways on the outer Continental Shelf for renewable energy activities. Under the Energy Policy Act of 2005, regulatory oversight of the Cape Wind project now rests with the MMS, rather than the USACE. There are a myriad of environmental regulations that must be considered during the development of an offshore wind facility within the United States. The following is a list of potentially applicable federal laws and regulations (adapted from Firestone et al., 2004): Clean Water Act (permits for dredging and filling activities);

Source: http://www.mms.gov/offshore/RenewableEnergy/RenewableEnergyMain.htm; accessed 29 October 2005.

2

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 2.8.

National Environmental Policy Act (environmental evaluations, including environmental assessments and environmental impact statements); Magnuson-Stevens Fishery Conservation and Management Act (essential fish habitat consultation); Endangered Species Act (critical habitat modification consultation); Marine Protected Resources and Sanctuary Act (marine sanctuary consultation); Marine Mammal Protection Act (takings of marine mammals); Migratory Bird Treaty Act (takings of migratory birds); National Historic Preservation Act (consultation for historic shipwrecks, archaeological sites, and views from historic districts); Coastal Zone Management Act (federal consistency); and Federal Aviation Act (notice and marking/lighting requirements). Pew Oceans Commission and the United States Commission on Ocean Policy In the past two years, two separate groups have conducted landmark studies on

the status of our nation's oceans. The Pew Oceans Commission, an independent group comprised of scientists, conservationists, elected officials, fishers, and business representatives, released its final report in May 2003. While the Pew report does not specifically address renewable energy resources or offshore wind energy, the report does make a connection between global climate change and the health of the marine environment: The Commission feels strongly that the U.S and its global neighbors must do the one thing that can directly limit the effects of climate change on the marine environment reduce our emissions of greenhouse gases that contribute to this problem (Pew Oceans Commission, 2003, 87).

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Thus, while the Pew report does not make specific recommendations relating to the development or management of offshore energy resources, it does stress the importance of reducing emissions of greenhouse gases, of which offshore wind energy may play a critical role. The United States Commission on Ocean Policy is a committee comprised of scientists, law-makers, and policy-makers, authorized by Congress and appointed by the President of the United States. The Commission is tasked with developing a coordinated and comprehensive national ocean policy. Chapter 24 of the Commission's final report, released in September 2004, is devoted exclusively to the management of offshore energy (including offshore wind energy) and other mineral resources. The Commission's recommendation concerning offshore renewable energy development is as follows: What is urgently needed is a comprehensive offshore management regime that considers all offshore uses within a larger planning context. A coherent and predictable federal management process for offshore renewable resources that weighs the benefits to the nation's energy future against the potential adverse effects on other ocean users, marine life, and the ocean's natural processes, should be fully integrated into the broader management regime (U.S. Commission on Ocean Policy, 2004, 368). The report also calls on Congress to "enact legislation providing for the comprehensive management of offshore renewable energy development as part of a coordinated offshore management regime" (U.S. Commission on Ocean Policy, 2004, 368). It further specifies that the legislation provide for a streamlined process for the licensing, leasing, and permitting of all renewable energy facilities sited in United States waters; consider the public nature of oceans and their resources; ensure that the general public share in the financial returns from the private use and development of a public resource; and provide

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for a transparent decision-making process that considers interests and concerns at the state and local level (U.S. Commission on Ocean Policy, 2004). The Commission's report also addresses marine mammals and endangered marine species in Chapter 20 of the final report. According to the report, "the potential impacts of new ocean technologies on marine mammals will need to be examined and the permit application process started early in the developmental stages" of emerging development projects (U.S. Commission on Ocean Policy, 2004, 314). Recommendation 20-8 of the final report calls for a program to "examine and mitigate the effects of human activities on marine mammals and endangered species" (U.S. Commission on Ocean Policy, 2004, 315). The Commission clearly envisions a more coordinated and comprehensive effort between agencies addressing marine wildlife species and emerging offshore uses of the continental shelf. 2.9. Impacts of Power Plants on Wildlife Species The operation of a power plant may impact wildlife species directly through impingement, entrainment, and thermal discharge, and indirectly by contributing to occurrences of acid rain, oil spills, and mercury contamination. Activities associated with the operation of a power plant, such as coal mining and oil extraction activities, also impact wildlife species. 2.10. Direct impacts 2.10.1 Impingement Veil et al. (2003) define impingement as the trapping of aquatic organisms on the cooling water intake screens of power plant generating stations. Impingement generally

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occurs as power plants draw water in for a cooling cycle, and the suction effect of the water traps or "impinges" - organisms against the intake screen. Some larger power plants may have systems in place to wash impinged organisms from the cooling water intake screens and return them to the water, thus reducing injury or mortality (Veil et al., 2003). Weak-swimming organisms that are too large to pass through the cooling water intake screens may be particularly susceptible to impingement (Committee on Entrainment, 1978). 2.10.2 Entrainment There are two types of entrainment: intake entrainment and plume entrainment. Intake entrainment occurs as aquatic organisms are carried throughout the entire cooling system of a power plant generating station, and plume entrainment occurs as organisms are caught up in the discharge plume from a plant, but do not actually pass through the plant. Organisms such as plankton, nekton, and larval and juvenile fish are particularly susceptible to intake entrainment if their cross-sectional dimensions are smaller than the mesh size of the cooling water intake screens. Larger organisms, such as adult fish, may be more susceptible to plume entrainment (Committee on Entrainment, 1978). The ecological effects of entrainment depend on several factors, including a particular organism's life cycle (i.e., how long the organism spends in the larval stage, when entrainment is more likely to occur, versus the juvenile and adult stages, when entrainment is less likely to occur), the regeneration ability of different species (i.e., phytoplankton regenerate in hours, while fish and shellfish may take several years to regenerate), and whether or not entrainment is occurring in an important nursery area

25

(Committee on Entrainment, 1978). Some organisms may not be susceptible to entrainment themselves, but may depend on other organisms that are susceptible to entrainment. The Committee on Entrainment (in Schubel and Marcy, 1978) note that adult striped bass are not susceptible to entrainment, yet are dependent on macroplankton that are susceptible to entrainment. Similarly, El-Hinnawi (1981) notes that "certain microinvertebrates serve as food for juvenile fish, and any adverse effects on the food chain involving these organisms can have an impact ultimately on the commercial and recreational fisheries" (El-Hinnawi, 1981, 33). Interestingly, Veil et al. (2003) note the following with regards to the impingement and entrainment of non-aquatic organisms: Cooling systems that rely on moving large volumes of air by fans may create their own form of impingement and entrainment. Insects and birds can be drawn into the intake plumes of large fans the authors are not aware of any published literature quantifying this impact, but the parallels to aquatic impingement and entrainment are obvious (Veil et al., 2003, 47).

2.10.3 Thermal discharge Thermal discharge, defined by Hill (1975) as waste heat that is released to the environment as a by-product of electricity generation, is another way by which power plants may directly impact wildlife species. In steam-electric power plants, water is heated to produce steam, which in turn drives the generators producing electricity. The steam is then condensed by cooling water, which circulates through a system of tubes and absorbs heat from the steam (Veil et al., 2003). In "once-through cooling" systems, the heated cooling water now approximately 5 to 20 C warmer is discharged back to its

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source, such as a river, lake, estuary, or ocean. In "closed-cycle cooling" systems, the heated cooling water is passed to a cooling pond or cooling tower, where it gives off heat through the process of evaporation, and is then returned to the condenser and re-used (ElHinnawi, 1981 and Schubel, Coutant, and Woodhead, 1978). Thermal discharges into the aquatic environment may have varying environmental impacts on aquatic organisms. Changes in temperature resulting from thermal discharge may affect various biological activities and processes, including growth rates, feeding, reproduction, and photosynthesis (El-Hinnawi, 1981 and Hillman and Morgan, 1980). Mortality of otherwise healthy adult organisms may occur if the change in temperature is high enough, and organisms that can withstand the change in temperature may become more susceptible to disease (Hill, 1975). Both Theodore and Buonicore (1980) and Schubel and Marcy (1978) provide thorough discussions on the biological impacts of thermal discharge from power plants. 2.11. Indirect impacts 2.11.1 Oil spills Spills from barges transporting oil to power plants impact a variety of wildlife species, including birds, marine mammals, fish, and commercially valuable types of shellfish such as oysters, clams, scallops, and mussels. Biologically rich coastal regions are particularly vulnerable to the effects of an oil spill, as these areas are home to the majority of the world's fisheries, and represent important spawning and nursery grounds for many species (El-Hinnawi, 1981). Oil spills may have immediate impacts, such as the mortality of oiled seabirds, and longer-term impacts, such as the persistence of oil in

27

bottom sediments and long-term closures of fisheries and shellfish beds (Blumer et al., 1975). Birds (particularly seabirds) are very sensitive to the effects of an oil spill, due to the large amount of time they spent on or near the water's surface (AMSA, 2002). External contamination of a bird's feathers with oil results in loss of water-repellency and insulation, subsequently leading to a loss of body heat and an increase in metabolic rate. Mortality may result from a combination of heat loss, starvation, and drowning. Oiled birds may transfer oil from their feathers to their eggs during incubation, leading to reduced hatchling success, developmental defects and/or embryo mortality. Ingestion of oil, either through a bird's attempts to clean oil from its feathers by preening or through consumption of contaminated food and water, may also be toxic to avian species (Leighton, 1995). Marine mammals are also vulnerable to the effects of an oil spill, due in part to the large amount of time they spend at the water's surface, engaging in activities such as swimming, breathing, feeding, and resting (Neff, 1990). Certain physical characteristics, such as rough skin, the presence of body hair or fur, and grooming habits also make marine mammals sensitive to oil contamination. Oiled marine mammals may suffer from hypothermia, congested lungs, damaged airways, eye and skin lesions, decreased body mass, behavioral changes, and interstitial emphysema resulting from the inhalation of oil droplets and vapors (AMSA, 2002). Vulnerability to an oil spill differs among marine mammal species. Since oil spills commonly occur in coastal areas, pelagic species (i.e., humpback whales) are less

28

likely to be exposed to an oil spill than species that spend time closer to the shoreline, such as manatees and dolphins (AMSA, 2002). Mammals with heavy pelage, such as fur seals, sea otters, and polar bears, are more susceptible to oil fouling than smooth-skinned mammals such as dolphins, whales, manatees, and most seal species. Ingestion of oil by marine mammals is also a concern, particularly for species whose pelage requires regular grooming, and for species that feed through filter feeding, such as baleen whales. Marine mammals that spend time on land (i.e., many species of pinnipeds, including sea lions, seals, and walruses) may also be exposed if their haul-out areas are contaminated with oil (AMSA, 2002 and Neff, 1990). Geraci and St. Aubin (1990) provide a more detailed account of the impacts of oil spills on seals, whales, dolphins, sea otters, polar bears, and manatees. Like marine mammals, sea turtles must surface to breathe, and exposure to oil may damage their eyes, lungs, and mucous membranes. Sea turtles lay their eggs on land, and oil contamination of sea turtle nesting beaches may contaminate eggs and affect hatchling success rates (AMSA, 2002). Although fish do not breathe air and therefore do not spend as much time at the surface as marine mammals and sea turtles, fish may still be adversely impacted by an oil spill. Oil can coat the gills of fish, inhibiting oxygen exchange with the surrounding environment. Oil spills that occur in nearshore feeding and nursery grounds may be particularly harmful to fish (USFWS, 1978). Fish, however, are unlikely to accumulate and retain concentrations of petroleum hydrocarbons in their tissue; therefore, indirect transfer of hydrocarbon residues from fish to their predators is minimal (Neff, 1990).

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Bottom-dwelling invertebrates may accumulate hydrocarbon residues from contaminated sediments, food, and water. Bivalve mollusks are limited in their ability to metabolize and excrete hydrocarbon compounds, and as a result may retain residues of hydrocarbons longer than other species of invertebrates. Crustaceans, on the other hand, can more readily eliminate hydrocarbon residues. Species that depend on bottomdwelling invertebrates for food may be indirectly impacted by an oil spill if their food source is significantly damaged or depleted (Neff, 1990). Oily sludge that sinks to the bottom of an estuary, lake, or ocean may smother bottom-dwelling organisms (USFWS, 1978). 2.11.2 Acid precipitation The combustion of fossil fuels at power plants results in emissions of various pollutants, including carbon dioxide, nitrogen oxides, sulfur dioxide, mercury compounds, and particulate matter. Sulfur and nitrogen are the two primary elements that cause acid precipitation: sulfur, in the form of sulfur dioxide; and nitrogen, in the form of nitrogen oxide and nitrogen dioxide (commonly expressed as "NOx"). Sulfur dioxide and NOx are released into the atmosphere and may travel great distances before falling to the ground through wet deposition (acid rain, acid snow, acid fog) or dry deposition (deposition on the earth's surface as small particles) (USEPA, 2003). According to Graveland (1998), acid precipitation may affect birds in the following ways: 1) through changes in food/prey abundance (i.e., declines in fish stocks); 2) through loss of suitable habitat for breeding, nesting, and foraging (i.e., forest dieback); and 3) through chemical changes in the water and soil on which birds depend

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(i.e., changes in calcium availability and toxic metal levels). The acidification of soil may result in the leaching of calcium from soil and an increase in the concentration of aluminum in soil, which in turn leads to reduced calcium intake by roots and lowered calcium content in leaves. The calcium content of leaves and soils determines the number of calcium-rich invertebrates available as prey items for birds. Without proper levels of calcium, eggshells are more likely to be thin, porous, and prone to breakage, and offspring are more likely to suffer from bone malformations and mortality. Acid precipitation may also result in a decreased abundance of insects such as mayflies, caddisflies, dragonflies, and damselflies, which serve as an important food resource for many species of birds (Graveland, 1998). Hames et al. (2002) find that acid rain is behind the decline of the Wood Thrush, a neotropical migrant that breeds in the eastern United States. According to Hames et al. (2002, 11238) there is an "extremely strong, highly significant, negative effect of acidic deposition on the predicted probability of breeding by the Wood Thrush" while controlling for covariates such as regional abundance, habitat fragmentation, elevation, soil pH, and vegetation. The effects of acid precipitation on the Wood Thrush are only strengthened by fragmented habitat, even though this species has not previously demonstrated a negative effect to habitat fragmentation (Hames et al., 2002). Aquatic species are affected by acid precipitation as well. Fish, for example, are believed to have greater variety and abundance of species in waters with a pH greater than five, although this is not always the case (i.e., the Amazon River and its tributaries have pH values as low as 3.5, yet exhibit a high diversity of fish with more than 1300

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species). Increasing acidity of waters that support fisheries may lead to an overall decrease in species richness, mortality of fish eggs and larvae, lower biomass and production, physiological distress, and poor growth (Howells, 1995 and USFWS, 1978). Changes in the acidity of aquatic habitats may also impact zooplankton, macroinvertebrates, and macrophytes, although the effects of increased acidity on these species are far less studied than the effects on fish (Howells, 1995). According to the USFWS (1978, 68), "reduced zooplankton diversity would reduce the size range of primary consumers and thus reduce the feeding efficiency of the secondary consumers, affecting community structure at that level." Other species affected by acid precipitation may include amphibians and waterfowl. Amphibians have more permeable skin than other species, and require water for reproduction; therefore, they may be more sensitive to the effects of acid precipitation (USFWS, 1978). Wildlife may also be impacted by acid precipitation if they consume aquatic prey; for example, North American otters, mink, and raccoons may be indirectly affected by acid rain if the fish they consume are depleted due to changes in the acidity of their aquatic habitats. In general, acidic waters exhibit a lower diversity of flora and fauna than more neutral waters (Howells, 1995). 2.11.3 Mercury contamination Approximately 48 tons of mercury are emitted each year from coal-fired power plants, with approximately 400 pounds of mercury emitted from New England sources (USEPA, 2005). Mercury, a heavy metal, bioaccumulates in the food chain and is found in a variety of species, including clams, mussels, fish, shellfish, and marine mammals (Wittnich et al., 2004).

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A recent study on the effects of mercury in marine animals examined mercury concentrations in the livers of seals, whales, dolphins, polar bears, walruses, and otters in various geographical locations throughout the world. The report finds that the amount of mercury in marine mammals has increased significantly in the past several decades. The mercury levels in seal livers, for example, have doubled from 1972 to 1994, and mercury levels in dolphin livers exhibit a six-fold increase from 1989 to 1998 (Wittnich et al., 2004). The primary target of mercury in the bodies of mammals is the central nervous system. Although effects of mercury in wild animals may be difficult to detect and observe, behavioral changes (i.e., loss of coordination, disorientation, visual or peripheral impairment, and auditory impairment) are likely to be the first visible effects of mercury poisoning. Mass strandings of marine mammals may also be a result of mercury poisoning, although other causes are frequently cited as causing marine mammal strandings, including bacteria, viruses, and underwater sonar activity (Wittnich et al., 2004). 2.12. Other The extraction of the resources needed to run a power plant, such as coal and oil, and the day-to-day activities at power plants also impact wildlife species and their habitats, although the impacts are indirect in nature and difficult to quantify. For example, a 1000 MW power station requires more than 12,000 acres of land for coal mining, coal processing, and waste storage, and an additional 3000 acres of land for associated structures and roads. A petroleum refinery requires land for storage of crude

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oil and processing facilities, including setting ponds, water treatment facilities, and disposal sites for oily sludge. The land area required is estimated to be 12.5 acres/1000 bbl (barrels)/day (Shen, 1980). Underground mining and strip mining are two methods used for extracting coal from the ground. One environmental consequence of underground coal mining is acid mine drainage, which occurs as un-neutralized sulfuric acid seeps from coal mines and drains into waterways, degrading water quality and the habitats of fish and other aquatic organisms. Strip mining, the process of removing large quantities of overlying earth to reveal coal seams, results in acid drainage, increased erosion, and sedimentation. Sedimentation smothers bottom-dwelling benthic organisms and impacts the ability of a waterway to carry storm water (Fortune, 1975). According to Fortune (1975), strip mining requires the removal of ten feet of overburden for every foot of thickness of the coal seam, with the average coal seam 5.1 feet thick. The on-site cleaning and storage requirements for coal contribute to acid drainage and erosion problems. Drainage from coal storage piles introduces high concentrations of sulfate and metals such as iron, zinc, and aluminum to surface and groundwater, while erosion from storage areas introduces large quantities of sediments to receiving waters. Both acid drainage and erosion impair water quality and ultimately impact the habitats of fish, benthos, and other wildlife species (Theodore and Buonicore, 1980 and USFWS, 1978).

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2.13.

Summary This chapter has provided some background information on the offshore wind

industry, both at the international level and within the United States. A review of pertinent literature on the wildlife impacts of offshore wind development, as well as the wildlife impacts of fossil fuel burning power plants, is provided. Wildlife impacts of both forms of energy generation will be explored in greater detail in Chapter 4 and 5, using the Cape Wind site, Brayton Point station, and to a lesser extent Canal Electric Station as case studies.

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Chapter 3 RESEARCH METHODOLOGY This chapter discusses the research design of this thesis, and identifies the methods of data collection and data analysis utilized in the research process. The goal of this thesis is to explore a relatively new field of research, and draw comparisons between this new field (wildlife impacts of offshore wind development) and an existing field (wildlife impacts of power plants). As defined by Mauch and Birch (1998, 119, 117), an exploratory methodology consists of "investigations into new or relatively unknown territory for the purpose of much more closely scrutinizing objects or phenomena, mostly to lead to a better understanding of them" and a comparative methodology examines "two or more existing situations in order to determine and explicate their likenesses and differences." Exploratory work is designed to 1) find out what is happening; 2) seek new insights; 3) ask questions; and 4) assess phenomena in a new light (Robson, 1993). According to Robson (1993), a case study is an appropriate research strategy for exploratory work. Case studies assist in the development of "detailed, intensive knowledge about a single 'case' or of a small number of related 'cases'" and involve information collection through observation, interview, or documentary analysis. Case studies are particularly useful when existing information or research on a particular

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subject is limited, as is the case with the wildlife impacts of offshore wind development (Robson, 1993). This thesis utilizes aspects of a case study research project by providing a comparative analysis of the wildlife impacts of two different power plants (an offshore wind facility and a fossil fuel burning power plant), using select parameters. These parameters include quantitative estimates of wildlife mortality and the area of disturbed and/or lost habitat, and qualitative estimates of wildlife impacts resulting from the construction, operation, maintenance, and decommissioning of these two power plants. The proposed Cape Wind facility in Nantucket Sound (Massachusetts) and the Brayton Point fossil-fuel burning power plant (Somerset, Massachusetts) will serve as case studies of the wildlife impacts of proposed and common means of energy production, respectively (see Figure A.1 in the Appendix). The Cape Wind site provides for a unique case study as it is currently at the center of a debate on offshore wind development in the United States, and a draft environmental impact statement on the Cape Wind site has recently been released by the U.S. Army Corps of Engineers. Brayton Point is the largest fossil-fuel burning power plant in New England, and numerous environmental studies and reports are readily available for review and analysis. Less data and information are available for the Canal Electric Power Plant, located in Sandwich, Massachusetts (on Cape Cod); however, data related to the wildlife impacts of the Canal Electric plant will be used in this analysis as available and appropriate. Research methods will consist primarily of the collection and analysis of existing sources of data (secondary data), rather than field measurements or the collection of

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primary data through techniques such as interviews, surveys, or questionnaires. Data sources for this research include the following: Federal environmental impact statements for the proposed Cape Wind facility and Brayton Point station, Environmental data and studies available from federal and state agencies, including the US Environmental Protection Agency, the US Fish and Wildlife Service, the Massachusetts Division of Marine Fisheries, and the Rhode Island Division of Fish and Wildlife, and Attendance at relevant conferences and workshops, including "Wind Energy and Wildlife: The Good, the Badthe Possible" (Princeton University, May 2005), and "Mini-Conference on the Impacts of Offshore Energy Development on Coastal Marine Wildlife" (Dowling College, March 2005).

Data analysis will be both qualitative and quantitative in nature. Quantitative comparisons of wildlife impacts will be adjusted to reflect the difference in power generating capacity between Cape Wind and Brayton Point.

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Chapter 4 WILDLIFE IMPACTS This chapter provides an analysis of the possible wildlife impacts of both an offshore wind facility and a fossil-fuel burning power plant, using the Cape Wind site and the Brayton Point power plant as case studies. These facilities are expected to produce (Cape Wind) or currently produce (Brayton Point) electric power for Cape Cod and southeastern Massachusetts, and impact wildlife species either directly or indirectly through plant construction, operation, maintenance, and decommissioning activities. The goal of this chapter is to analyze the potential impacts of the Cape Wind site and of Brayton Point station to fish and wildlife species. The analysis uses several sources of information: for the Cape Wind site, this analysis draws mainly on data presented in the United States Army Corps of Engineers (USACE) draft environmental impact statement (DEIS), as well as data from available European offshore wind studies. For Brayton Point, this analysis relies on the United States Department of Energy's final environmental impact statement (FEIS) for Brayton Point station; available environmental studies from the Rhode Island Division of Fish and Wildlife and the United States Environmental Protection Agency (USEPA); information from the Massachusetts Division of Marine Fisheries; and other available information from state and federal environmental agencies.

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4.1.

Case Study of an Offshore Wind Site Cape Wind Associates, LLC is proposing to build an offshore wind facility on

Horseshoe Shoal in Nantucket Sound, Massachusetts. As proposed, the Cape Wind site will cover 24 square miles of Nantucket Sound and will be located 4.7 miles from the mainland (Point Gammon, Cape Cod) at its closest point. Consisting of 130 3.6 megawatt (MW) wind turbines arranged in a grid pattern, the maximum generating capacity of the Cape Wind facility will be approximately 454 MW. Each of the 130 wind turbines will consist of a monopile foundation, penetrating 85 feet into the ocean floor; three rotor blades; and a tubular tower height of 246 feet. The overall turbine height (i.e., the height of the turbine when a blade is in the 12 o'clock position) is 417 feet. The distance between each turbine will be approximately 2000 feet by 3300 feet. A 33 kilovolt (kV) submarine cable will transmit the wind-generated electricity from each of the turbines to an electric service platform within the wind park; from this point a 12.2 mile submarine cable will transmit the electrical power to the Cape Cod mainland, making landfall in the town of Yarmouth for connection with the existing electrical grid (USACE, 2004). Electricity generated by the wind project is expected to provide approximately three-quarters of the electrical power needs of Cape Cod (Kempton et al., 2005). Nantucket Sound, the location of the proposed wind farm, is situated between the Cape Cod mainland, Martha's Vineyard, and Nantucket Island. Located where the cold waters of the Labrador Current meet the warm waters of the Gulf Stream, Nantucket Sound is a unique and highly diverse ecosystem that encompasses 163 square nautical

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miles (216 square miles). The 24 square mile proposed wind farm will occupy approximately 11 percent of the total area of Nantucket Sound. A rich diversity of local and migrating species of marine wildlife utilize Nantucket Sound for feeding, breeding, and nesting habitat, including various species of sea turtles, marine mammals, seabirds, waterfowl, finfish, and shellfish (CCS, 2003). It is the potential impact of the proposed wind farm on these wildlife species to which we now turn. 4.2. Wildlife impacts Impacts to wildlife species may occur during each phase of offshore wind development, including construction of the turbines and construction-related activities such as cable-laying and vessel traffic; turbine operation and maintenance; and decommissioning of the wind facility at the end of its lifespan. Wildlife impacts from the decommissioning of the wind farm are expected to be similar to or less than wildlife impacts from construction-related activities, as the decommissioning process will not require the pile-driving activities necessary to construction. Therefore, expected wildlife impacts from the decommissioning of the wind farm are not specifically addressed here but rather should be considered similar to or less than construction-related wildlife impacts (USACE, 2004). 4.2.1. Marine mammals and sea turtles The Cape Wind DEIS identifies thirteen species of marine mammals that may occur in Nantucket Sound: humpback, fin, Northern Atlantic right, long-finned pilot, and minke whales; gray, harbor, harp, and hooded seals; white-sided, striped, and common dolphins, and harbor porpoises. Of these species, the humpback, fin, and North Atlantic

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right whales are federally protected under the U.S. Endangered Species Act. The gray seal is considered a Massachusetts species of special concern3 (USACE, 2004). Marine mammals face unique challenges from offshore wind farms. Many marine mammal species, particularly cetaceans, are large in size and require large amounts of unimpeded ocean space in order to navigate the ocean freely. An offshore wind farm consisting of many turbines and covering a large area, such as the Cape Wind facility, may hinder the movements of migrating marine mammals, particularly those that emit echolocation signals for navigational purposes. Should marine mammals move away from the wind farm area in search of more open habitat, they may risk entering busy shipping lanes and thus be at an increased risk for ship strikes (Safewind, 2005). The USACE DEIS notes that vessel traffic associated with the Cape Wind site will not overlap areas with known concentrations of marine mammals, thereby reducing the potential for close encounters or collisions between marine mammals and wind projectrelated vessels. Additionally, operation and maintenance of the Cape Wind site is expected to result in two round-trip vessel trips per day for 252 days per year, for a total of 504 round-trip vessel trips per year. The USACE considers this to be a negligible increase in existing vessel traffic in Nantucket Sound, including traffic from United States Coast Guard vessels, research vessels, cruise ships, passenger ferries, barges, tour boats, and recreational and commercial fishing boats (USACE, 2004). This author's

The Massachusetts Division of Fisheries and Wildlife defines a species of special concern as any native species that "occur in such small numbers or with such restricted distribution or specialized habitat requirements that they could easily become threatened within Massachusetts." (Source: http://www.mass.gov/dfwele/dfw/nhesp/nhrare.htm; accessed 9 June 2005).
3

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calculation results in an increase in existing vessel traffic of approximately four percent per year, a value that while low should not be considered negligible.4 The DEIS, however, fails to address the possibility of vessel strikes that may result should marine mammals abandon their habitat in Nantucket Sound and enter busy shipping lanes. This type of impact is of special concern for species like the endangered North Atlantic right whale, for which ship strikes are a significant source of mortality (Richardson et al., 1995). The effects of underwater noise on marine mammals from activities such as shipping, seismic exploration, and military sonar have been extensively studied in peerreviewed literature (Richardson et al., 1995 and NRC, 2003). The effects of noise on marine mammals should also be considered when assessing the possible impacts of an offshore wind facility. Marine mammals use sound to locate prey, communicate with other members of their species, attract mates, and navigate through dark ocean waters. Anthropogenic sounds introduced into the marine environment such as the sounds that The following annual frequencies of vessel traffic in Nantucket Sound are assumed, based on author's best judgment: USCG/scientific research (2 round-trips/day x 275 days/year = 550 round-trips/year); cruise ships (1 round-trip/day x 90 days/year = 90 round-trips/year); passenger ferries (8 round-trips/day x 365 days/year = 2920 roundtrips/year); barge/commerce vessels (1,305 round-trips/year; estimate from DEIS); tour vessels (4 round-trips/day x 90 days/year = 360 round-trips/year); recreational fishing (20 round-trips/day x 90 days/year = 1800 round-trips/year); commercial fishing (20 roundtrips/day x 275 days/year = 5500 round-trips/year). This results in a total of 12,525 existing round-trips/year; vessel traffic resulting from the operation/maintenance of the Cape Wind site (2 round-trips/day x 252 days/year = 504 round-trips/year) results in an increase of approximately four percent over existing vessel traffic. Frequency estimates (in days/year) are based on the assumption that some activities take place mainly in the summer months of June, July, and August when tourism is at its peak (i.e., cruise ships, tour vessels, recreational fishing vessels), while other activities occur more regularly throughout the year (i.e.,USCG/scientific research, passenger ferries, commercial fishing).
4

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may occur during all phases of offshore wind development -- may displace marine mammals from their natural habitats, cause temporary or permanent hearing damage, or prevent marine mammals from hearing and interpreting sounds necessary to their survival (Richardson et al., 1995). The United States Navy identifies 180 decibels5 (dB) as the sound level above which 95 percent of marine mammals "could incur a significant change in a biologically important behavior" (US Department of the Navy, 2001, ES-18). This level is based on several factors, including estimates of the frequency range at which marine mammals are most sensitive; extrapolation from human exposure studies; and measurements of temporary threshold shifts in the hearing capabilities of marine mammals (US Department of the Navy, 2001). Pile driving, the process by which a wind turbine tower is driven into the sea floor, may result in intermittent sound levels ranging from 166 dB to more than 200 dB. The maximum sound level expected from pile driving operations at the Cape Wind site (as identified in the DEIS) ranges from 170 dB to 178 dB, with sound levels varying with distance from the turbine. The sound levels produced by pile driving, coupled with an increase in vessel traffic noise (sound levels ranging from 152 dB to 192 dB) expected during the construction phase, will likely result in a temporary avoidance of habitat by marine mammals (Nedwell and Howell, 2004; USACE, 2004). Acoustic impacts to marine mammals during construction, however, are expected to be short-term in duration, and marine mammals are likely to return to the area once construction

A decibel (dB) is a unit expressing the magnitude of the difference between two signals or sound levels as ten times the common logarithm of the ratio of their powers (Stephens, 1974).

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activities have terminated (USACE, 2004). Post-construction monitoring at the Horns Rev (Denmark) offshore wind site in 2002, for example, reveals that the acoustic activity of harbour porpoises returned to normal levels three to four hours after pile driving activities had ceased. The post-construction monitoring report from 2003 indicates that "echolocation activity in the impact area relative to the control area almost returned to baseline levels after the end of the construction period" (Elsam Engineering and ENERGI E2, 2004, 30). Appropriate mitigation measures may also help reduce the acoustical impacts resulting from construction activities; for example, the DEIS notes that a softstart technique will be implemented for pile driving activities. A soft-start technique involves a gradual increase in the sound source level, allowing marine mammals, sea turtles, and fish to detect and respond to the noise before it reaches levels that may be harmful to them. Additionally, an on-site, government-appointed observer will ensure that all construction activities cease should a marine mammal or sea turtle be spotted within the construction zone (USACE, 2004). While the construction of an offshore wind farm may result in short-term impacts to wildlife species in the form of temporary habitat disturbance or avoidance, the operation of a wind farm over its 20-plus year lifespan may have longer-term implications for wildlife species, such as hearing damage or permanent habitat abandonment. Turbine operation will generate noise both above the surface of the water, as the rotor blades sweep through the air, and below the surface of the water, as a result of structural vibrations (Nedwell and Howell, 2004). The low-frequency underwater sound generated by the operation of an offshore wind turbine is estimated to have a sound

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level range of 98 dB to 130 dB (Safewind, 2005; Koschinski et al., 2003; Sker et al., 2000). The Cape Wind DEIS estimates the underwater sound level generated by a single wind turbine to be 109.1 dB, measured at a distance of 20 meters from the monopile foundation. However, since turbines are expected to be placed approximately 600 to 1000 meters apart, the underwater noise and vibration produced by the turbines is not expected to be additive, as noise levels fall below baseline noise levels (107.2 dB) at a distance of 110 meters from the monopile foundation. According to the DEIS, noiserelated impacts to marine mammals from the operation of the wind turbines are expected to be minimal (USACE, 2004). One should also keep in mind that the decibel system is measured on a logarithmic scale; therefore, while the difference between the underwater sound level generated by an offshore wind turbine (109.1 dB) and the level at which marine mammals are believed to be adversely impacted (180 dB) is approximately 71 dB, this actually represents a difference in sound energy of 107. Another concern for marine mammals is the potential effect of electromagnetic fields. Electromagnetic fields are created by the generation and transmission of electricity through cables buried below the sea floor, and may interfere with some marine mammals' use of the earth's magnetic field for navigation and migration (Sker et al., 2000). The environmental impact assessment for Denmark's Rodsand offshore wind farm, however, suggests that the magnetic field from a cable buried one meter below the sea floor is likely to be less than the earth's magnetic field, and therefore is not expected to have any adverse effects on marine mammals (SEAS, 2000). According to the Cape Wind DEIS, all cables associated with the wind farm will be buried approximately 1.8

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meters (5.9 feet) below the sea floor; therefore, impacts from the electromagnetic fields surrounding the cables are expected to be minimal (USACE, 2004). Marine mammals may be indirectly affected by the construction, operation, and decommissioning of an offshore wind facility as a result of the possible displacement, change in distribution or abundance, and/or mortality of the prey species on which they depend. Fish and bottom-dwelling invertebrates, for example, may be temporarily displaced from their habitat during construction activities. The eggs and larvae of demersal fish may experience localized increases in mortality during construction-related activities. The monopile foundations of the turbines will likely serve as fish-aggregating devices, introducing new sources of prey in the form of finfish and invertebrates for marine mammals, and subsequently removing these sources of prey during the decommissioning process. Displacement or mortality of prey is not expected to adversely impact marine mammals, as marine mammals are expected to find suitable prey species in less-disturbed areas adjacent to the wind farm. Similarly, change in the abundance of prey as a result of the artificial reef effect will not have an adverse impact on marine mammals, as the surface area introduced into the marine environment by the monopile foundations is relatively small (112 square meters, or approximately 1200 square feet, per tower) and is not expected to significantly alter the feeding habits of marine mammals (USACE, 2004). In order to properly characterize the possible impacts to marine mammals from offshore wind development, the physical presence of marine mammals in Nantucket Sound, as well as their population status, must be considered. Humpback, fin, and North

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Atlantic right whales are the only federally protected species of marine mammals known to occur in Nantucket Sound and therefore deserve special consideration when assessing the impacts from offshore wind development. Humpbacks, however, are only occasional visitors in Nantucket Sound, and fin whales are common in much deeper waters (40 to 50 meters in depth) than the shallower waters of Nantucket Sound, which range from approximately four to 15 meters in depth. North Atlantic right whales favor waters 100 meters or more in depth and are also rarely sighted in Nantucket Sound. The primary feeding grounds for these three species of whales include Stellwagen Bank, Cape Cod Bay, and the Gulf of Maine not Nantucket Sound. According to the DEIS, Nantucket Sound does not support a large density of the food resources necessary for these whales (USACE, 2004). Therefore, while humpback, fin, and North Atlantic right whales may occur in Nantucket Sound, such occurrences are infrequent and impacts to these species can be considered low. Other species of marine mammals are more common in Nantucket Sound; for example, harbor seals, harp seals, hooded seals, white-sided dolphins, striped dolphins, common dolphins, harbor porpoises, long-finned pilot whales, and minke whales. Many of these species are likely to occur in Nantucket Sound in the warmer months of the late spring, summer, and early fall. According to the DEIS, installation of the wind turbines will occur in the third quarter of 2006 (author assumes this refers to the months of July, August, and September); therefore, species occurring in Nantucket Sound during this time frame may be susceptible to construction-related impacts (USACE, 2004). However, as these species are neither endangered nor threatened, one might infer that

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impacts to these species may not be a significant concern at the population level, despite their known presence in Nantucket Sound. Three species of federally protected sea turtles occur in Nantucket Sound, mostly during the summer and early fall when water temperatures are warm. The loggerhead, leatherback, and Kemp's ridley sea turtles may be impacted by the construction, operation and maintenance, and decommissioning of the Cape Wind site in ways similar to marine mammals; that is, through short-term habitat avoidance, acoustic harassment, increased risk of vessel strikes, electromagnetic fields, and indirect impacts as a result of prey displacement. The generation of electromagnetic fields by inter-connecting cables within the wind park is of particular concern for sea turtles. Sea turtles are believed to use the earth's magnetic field to aid them in their migratory patterns; in particular, female sea turtles use the earth's magnetic field to locate and return to their natal beaches for nesting purposes (Gulko and Eckert, 2004). The effects of electromagnetic fields on sea turtles, however, are expected to be minimal given the design of the cable system and the depth at which the inter-connecting cables are buried (USACE, 2004). The leatherback, loggerhead, and Kemp's ridley sea turtles are all likely to occur in Nantucket Sound in the warm months of summer and early fall. All three species of sea turtles, particularly the Kemp's ridley and loggerhead, favor shallow waters for feeding on bottom-dwelling organisms. Given that turbine installation is scheduled to coincide with the presence of these three federally protected sea turtle species in Nantucket Sound, particular care should be taken to ensure their protection during construction activities. The presence of a government-appointed observer during

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construction activities will help ensure that sea turtles are not adversely impacted by the construction of the wind farm. 4.2.2. Fish Nantucket Sound is home to numerous species of commercially and recreationally valuable fish and squid. National Marine Fisheries Service (NMFS) data from 1994 2001 indicate the top ten commonly landed species of fish in Nantucket Sound are squid, Atlantic mackerel, black sea bass, summer flounder, scup, menhaden, butterfish, tautog, winter flounder, and bluefish. Commonly caught recreational fish species in Nantucket Sound, as identified by NMFS, include bluefish, Atlantic mackerel, scup, striped bass, winter and summer flounder, menhaden, and tautog. In addition, research trawl data from the Massachusetts Division of Marine Fisheries (MDMF) indicate the following species are "very common" (as opposed to "variably common" and "less common") within the wind farm site itself (abundance varies seasonally): longfin squid, northern sea robin, summer flounder, winter flounder, windowpane, little skate, winter skate, black sea bass, butterfish, scup, and smooth dogfish (USACE, 2004). Impacts to fish, like those to marine mammals, may occur during construction, operation and maintenance, and decommissioning of the offshore wind facility. Fish may temporarily avoid the wind farm area during the construction phase, due to intermittent noise and vibrations associated with pile-driving activities. Although the Cape Wind DEIS (2004, 5-59) states that "underwater sound would be well below levels that would cause permanent damage to finfish," Vella et al. (2001) suggest that noise associated with the construction of a wind farm may result in alarm and startle responses in fish, leading

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to avoidance of habitat. Such impacts should be closely monitored, especially if a wind farm is located near areas of significant habitat, such as spawning or nursery grounds (USACE, 2004; Vella, 2001). According to NOAA's Northeast Regional Office, Nantucket Sound provides significant habitat, in the form of designated essential fish habitat, for numerous species of fish, including the summer and winter flounder, Atlantic mackerel, Atlantic butterfish, king mackerel, and Spanish mackerel. Limited mortality to fish may occur during construction activities, especially in winter months when cold waters may limit the ability of some demersal species to actively avoid anchors and cables. Localized increases in mortality to demersal larvae and eggs may occur from anchor positioning and anchor line sweep. The temporary displacement of fish, fish larvae, and/or fish eggs during construction activities may indirectly impact larger predatory fish species that depend on the displaced species for food (USACE, 2004). The construction of the wind park may result in temporarily increased levels of total suspended solids and increased turbidity in the water column. Localized increases in turbidity may limit the ability of fish to engage in activities essential to their survival, such as navigation, foraging, and finding shelter. However, based on the technologies selected for pile driving and cable laying, as well as the characteristics of the sediments found at the Cape Wind site, turbidity is expected to be minimal and confined to areas immediate surrounding the monopile foundations and the cables (USACE, 2004). The operation of the wind farm will have minimal impacts on fish. The DEIS suggests that fish may habituate to the noise and vibration emitted during operation, and

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underwater noise from operation reaches background noise levels within 100 meters of an individual wind turbine (USACE, 2004). The habituation of fish to operational noises is also noted in other studies; for example, Vella (2002, 5) finds that "when wind farms are operating normally, fish appear to readily habituate and utilize wind farm sites at higher than normal densities." The increase in vessel traffic that results from maintenance of the wind farm may temporarily displace fish from the immediate area around the maintenance vessels; however, the avoidance behavior resulting from vessel traffic will be no different than that resulting from fishing vessels, ferry boats, or recreational boat traffic (USACE, 2004). Fish, particularly cartilaginous fish such as sharks, skates, and rays, may also be impacted by the electromagnetic fields produced by the submarine cables; however, as with marine mammals, these impacts are expected to be minimal as the cables will be buried 1.8 meters (5.9 feet) beneath the sea floor (SeaScape, 2002; USACE, 2004). Perhaps the most commonly identified way by which an offshore wind facility may impact fish is habitat alteration, through the introduction of an artificial structure to the marine environment. Wind turbines, like other underwater artificial structures such as oil and gas platforms, have the potential to serve as fish aggregating devices. Artificial structures may benefit fish species by providing new sources of food and shelter; however, artificial structures also alter the composition of species normally found within the wind park area and affect predator-prey balances. Based on the wide spacing between turbines, however, "the overall environment and finfish species composition in

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the Project area is not predicted to substantially change from pre-Project conditions" (USACE, 2004, 5-62). 4.2.3. Benthic organisms Benthic organisms are bottom-dwelling creatures found on or beneath the seabed, including crustaceans, mollusks, worms, and other macro-invertebrates. Nantucket Sound supports a variety of commercially valuable benthic organisms, including mussels, quahogs, bay scallops, surf clams, soft shell clams, and conch species. MDMF trawl data indicate that within the wind farm site itself lady crab and spider crab are "very common;" and various whelk species are "very common" (with some seasonal variation). American lobster, bay scallops, Atlantic surf clams, blue mussels, and northern horse mussels are considered "rare" or "very rare" within the Cape Wind site (USACE, 2004). Benthic organisms are somewhat different from marine mammals, fish, and birds in that they are bottom-dwelling creatures by nature and thus cannot readily move away from the wind park area, should their habitat be disturbed by construction, operation, or decommissioning-related activities. Impacts to benthic organisms are most likely to occur during construction activities, in the form of direct seabed disturbance from piledriving, jet plowing of the cables, and anchoring of vessels necessary to construction activities. Some mortality to benthic organisms and temporary displacement from habitat may be expected during construction, although such impacts are expected to be limited due to the relatively small area of seabed disturbed. For example, the installation of 78 miles of connecting cables within the wind farm is estimated to disturb approximately 115 acres of seabed, which represents less than one percent of the total area (24 square

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miles) of the wind farm. The anchoring of construction-related vessels and anchor line sweep impacts during cable installation is expected to disturb approximately 570 acres of seabed, or less than four percent of the total wind farm area (USACE, 2004). Permanent disturbance of the sea floor will result once the wind turbines are erected and associated scour protection mats are in place, although this disturbance (and associated limited mortality to benthic organisms) will also be limited in area. The total area of seabed disturbed by 130 turbines is estimated to be less than one acre (approximately 0.004 square kilometers); the total area of seabed disturbed by scour protection is estimated to be approximately 2.4 acres (approximately 0.01 square kilometers). The combined seabed disturbance resulting from the wind turbines and scour protection mats is less than one percent of the total wind farm area (USACE, 2004). To put the area of seabed disturbed by wind turbines and associated scour protection into perspective, consider the area of seabed disturbed by trawling activities in Nantucket Sound, as evaluated by Kempton et al. (2005): six trawl vessels, harbored in the town of Barnstable, Massachusetts (on Cape Cod), are estimated to disturb 1,267 square kilometers of seabed as a result of groundfishing activities. If one considers that there are up to 12 transient groundfishing vessels harbored in Barnstable, as well as vessels engaging in fishing methods other than trawling, the area of seabed disturbed by fishing activities would be even greater (Kempton et al., 2005). The wind turbines will likely serve as a new source of hard substrate for a variety of organisms, including algae, barnacles, hydroids, sponges, tunicates, bryzoans, anemones, and mussels. The introduction of new substrate (1200 square feet per tower)

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is not likely to alter the overall benthic composition of Nantucket Sound, as the introduced area is relatively small and turbines are spaced far enough apart so as to avoid creating concentrated areas of hard substrate (USACE, 2004). 4.2.4. Birds The estuaries, shoals, salt marshes, tidal flats, dunes, and beaches that comprise the Nantucket Sound ecosystem provide important breeding, nesting, and foraging habitat for many species of resident and migratory birds. Nantucket Sound is located in the Atlantic flyway, and is recognized as an important migratory stopover area for millions of birds each year. Examples of some of the bird species that utilize Nantucket Sound include the federally endangered roseate tern and the federally threatened piping plover, several species of sea ducks, gulls, terns (including the common tern, a Massachusetts species of special concern), loons, grebes, gannets, cormorants, mergansers, auks, shearwaters, and various species of shorebirds and wading birds (CCS, 2003 and USACE, 2004). As part of the environmental impact statement process, Cape Wind Associates has conducted extensive research on avian use of Nantucket Sound. A preliminary avian risk assessment was conducted in 2001, utilizing published literature studies on avian distribution and migratory patterns, as well as available databases from relevant federal agencies. The preliminary risk assessment identified known impacts to birds from existing (land-based) wind facilities, and recommended additional field studies to help further characterize the risk that offshore wind facilities may pose to avian species. Between 2001 and 2004, Cape Wind conducted extensive aerial, boat, and radar surveys

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of avian use of Nantucket Sound. These surveys indicated that the majority of birds observed (approximately 95 percent) flew below rotor height; however, birds were also observed flying at rotor height, and therefore the potential for avian collisions with rotor blades can not be ruled out. Of the various species of birds observed flying at rotor height (including grebes, loons, northern gannets, cormorants, scoters, gulls, and terns), gulls and terns were the most numerous (USACE, 2004). Although attention has traditionally been focused on the risk of avian collisions with wind turbines, birds may be impacted during all phases of a wind farm's life cycle. Temporary habitat displacement and habitat disturbance are likely to occur during construction activities as a result of increased vessel traffic, the presence and operation of construction equipment, and associated noise. Birds may leave their usual habitat in search of undisturbed feeding and resting areas, although they are likely to return once construction activities have ceased. Some species of birds, including terns, gulls, and cormorants, have been shown to habituate to human activities and are likely to continue normal foraging activities in the construction zone (USACE, 2004). Avian species may be indirectly impacted by construction activities should the presence of benthic organisms on which birds feed be altered through sedimentation or turbidity. Sedimentation and turbidity typically occur during cable-laying activities. Changes to bottom fauna as a result of construction activities are expected to be temporary, and given the presence of suitable prey items in areas adjacent to the construction zone, birds are not likely to be significantly impacted by this indirect form of habitat disturbance (USACE, 2004).

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The operation of an offshore wind facility is likely to have a greater impact on birds than construction activities. The physical presence of turbines may serve as barriers to flight, interfering with the normal flight patterns of migratory birds. The presence of turbines may also prevent birds from entering their normal breeding, feeding, and roosting grounds, effectively excluding them from suitable habitats. Scoters, divers, geese, and waders are examples of bird species that are considered particularly sensitive to the presence of wind turbines (Exo, Hppop, and Garthe, 2003). Collisions between birds and wind turbines are a well-recognized and wellstudied impact of wind development, although to date most studies on avian collisions with wind turbines are from land-based facilities, rather than offshore facilities. The risk of collision depends on several factors, including the number of wind turbines, the distance between turbines, turbine height, tower design, and lighting (Kerlinger, 2001). According to Erickson et al. (2001), there is an average of 2.19 avian fatalities per landbased turbine per year in the United States for all avian species combined (32,850 total fatalities per year, assuming 15,000 operational wind turbines; see Erickson et al., 2001). This represents a small fraction (less than one percent) of annual avian collision mortalities in the United States from all man-made sources, including buildings and windows (98 million to 980 million), vehicles (60 million to 80 million), communication towers (four million to 50 million), power lines (tens of thousands to 174 million), etc. Even household cats are estimated to kill more birds per year (100 million) than wind turbines (Erickson et al., 2001).

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While a great deal of information exists on avian collisions with land-based wind turbines, information on avian collisions with offshore wind turbines is scarcer. This is due in part to the relatively recent development of the offshore wind industry and lack of sufficient before-and-after studies on avian collisions. Recovery of bird carcasses is also inherently more difficult in the marine environment than in the terrestrial environment. Studies conducted to date at European offshore wind facilities do provide some data on avian collisions with offshore wind turbines. For example, environmental monitoring at Denmark's Horns Rev offshore wind farm reveals that some species (divers and alcids) avoided the wind farm area during construction activities, while other species (herring gull) were attracted to the wind farm area during construction. Monitoring conducted during the first year of operation (2003) at Horns Rev revealed that divers, common scoters, and little gulls increased in number as compared to previous years, while divers, gannets, common scoters, and guillemots/razorbills demonstrated an increased avoidance of the wind farm area as compared to previous study years. Visual and radar observations were also conducted at the Horns Rev site in 2003, and revealed a general deflection of birds around the wind farm area. The report concludes that "avoidance of the wind farm was a frequent behavioural response shown by most of the bird species occurring at Horns Rev" (Elsam Engineering and ENERGI E2, 2004, 36). A number of factors influence the risk of collision between avian species and offshore wind turbines, including the various species known to frequent the wind farm area, the height at which a species flies, the number of turbines constructed, turbine height, turbine spacing, rotor speed, weather, and lighting. According to the Cape Wind

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DEIS, some avian species present at the Cape Wind site fly above the height of the turbine rotors; these species include many shorebirds (plovers, sandpipers, allies) and landbirds (songbirds, passerines). Gulls, terns, and northern gannets, however, are known to hunt for prey within the rotor-swept zone of the turbines and as a result may be at increased risk for collision-related mortalities. Nighttime fliers are also likely to be at increased risk for collisions as compared with daytime fliers (USACE, 2004). Several characteristics of the Cape Wind site may help reduce the risk of avian collisions with wind turbines. For example, the use of tubular towers rather than lattice towers may discourage perching and thus reduce potential for collisions. Wider spacing between individual turbines may also reduce the risk of avian collisions by providing more room for movement between turbines, although on the other hand turbines grouped more closely together may encourage birds to avoid the wind farm area altogether. The relatively low density of turbines in the Cape Wind site (approximately six wind turbines per square mile), especially as compared to other sites such as the Altamont Pass region where there are almost 70 turbines per square mile, may also help keep bird fatalities to a minimum (USACE, 2004). Avian use of Nantucket Sound is high, particularly during spring and fall migration. Despite high avian use of the area, approximately 95 percent of birds observed during field studies conducted by the applicant (Cape Wind) in Nantucket Sound fly below rotor height and, consequently, would be at low risk for collisions with the wind turbines. Based on quantitative collision data from twelve land-based wind turbines in the United States, the worst-case estimate for bird collisions with wind

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turbines is 2.19 fatalities per turbine per year. For the Cape Wind site (130 turbines), this results in approximately 285 collision-based fatalities per year (Erickson et al., 2001; USACE, 2004). [Note to reader: The DEIS states that the average number of fatalities per turbine per year is 2.8, based on data collected from 12 on-shore wind facilities and analyzed in Erickson et al., 2001. This value is assumed to be a typographical error within the DEIS, as the actual value noted in Erickson et al. 2001 is 2.19 fatalities per turbine per year, not 2.8 fatalities. Therefore, the DEIS estimate of 364 bird fatalities per year at the Cape Wind site is incorrect and should be considered to be 285 fatalities per year, as noted above.] The estimate of 2.19 fatalities per turbine per year, however, is based in part on fatality estimates from land-based wind facilities in California. California has the largest number of land-based wind turbines in the United States, thus increasing the risk of avian collisions. Studies at wind facilities in California have also focused largely on raptor fatalities, which are substantially higher in California than in any other state. If avian fatalities from California sites are excluded, the annual number of fatalities per turbine per year drops from 2.19 to 1.83. Applying this lower-end value to the Cape Wind site (130 turbines) yields approximately 238 fatalities per year. Therefore, the expected mortality from avian collisions with wind turbines in Nantucket Sound ranges from 238 to 285 collisions per year (Erickson et al., 2001). It should be noted that land-based wind turbines are smaller than the 3.6 MW turbines planned for the Cape Wind site; therefore, 238 to 285 avian collisions per year

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may actually underestimate actual avian mortality at the Cape Wind site, since it is assumed that the 3.6 MW machines would result in a higher number of fatalities than the smaller megawatt machines used at on-shore facilities. If one considers that the total installed wind generating capacity at land-based wind facilities in the United States is 6740 MW (AWEA, 2005), this translates into 0.45 MW (450 kW) per turbine (assuming 15,000 operational turbines, as cited in Erickson et al., 2001). By comparing the total blade area of a 450 kW turbine to the total blade area of a 3.6 MW turbine, it may be possible to provide a more accurate estimate of avian mortality at the Cape Wind site resulting from avian collisions with rotor blades. Based on data provided by the National Renewable Energy Laboratory (NREL) and the Danish Wind Industry Association6, a 450 kW turbine has a single blade area of approximately 40 square meters, for a total blade area of 120 square meters. A 3.6 MW turbine has a single blade area of approximately 245 square meters, for a total blade area of 735 square meters. Assuming that avian mortalities are directly proportional to total blade area, the Cape Wind DEIS may be underestimating the number of birds killed by a factor of approximately six, given that the total blade area of the 3.6 MW turbines is approximately six times larger than the total blade area of the smaller, land-based wind turbines. Therefore, the number of avian collisions per year at the Cape Wind site may be as high as 1710 collisions. Sources: http://www.nrel.gov/docs/fy01osti/29439.pdf and http://www.windpower.org/en/tour/wtrb/size.htm; accessed 29 October 2005. Blade areas are derived from the blade length and blade (chord) width provided for a 500 kW turbine and a 3.5MW turbine, rather than for a 450 kW / 3.6 MW turbine. Blade areas are likely to be an overestimate of actual blade area, as calculations are based on the assumption that rotor blades are perfectly rectangular in shape.
6

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Even if this figure is an overestimate, the DEIS' assumption that the number of collisions from smaller, land-based turbines is applicable to larger, offshore turbines is clearly an underestimate. 4.3. Summary of wind-related wildlife impacts The Cape Wind site will not be without some adverse impact on the marine environment. Marine mammals, fish, benthic organisms, and birds will all be impacted to some degree by the construction, operation and maintenance, and decommissioning activities necessary for offshore wind development. For marine mammals, the impact of greatest concern is the potential increase in underwater noise levels from the construction and operation of the wind turbines. Deleterious impacts to marine mammals from underwater noise generated by shipping vessels, military sonar, and scientific research have been extensively studied and are the subject of international concern; the noise and vibrations that will be generated by offshore wind turbines present similar concerns to marine mammals and should be given equal attention. The cumulative impacts of underwater noise on marine mammals should also be considered, particularly as multiple offshore wind sites, each comprised of hundreds of individual wind turbines, are proposed for the eastern coast of the United States. Concerns for marine mammals may be lessened by mitigation efforts such as the soft-start of pile-driving equipment, and the use of government-appointed marine mammal observers during construction activities. In addition, the low use of Nantucket Sound by federally protected species of marine mammals (humpback, fin, and North Atlantic right whales) may also lessen the potential for adverse impacts to these species from underwater noise, although other species of

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marine mammals more commonly found in Nantucket Sound may also be sensitive to acoustic impacts. Collisions with wind turbines pose the greatest risk to birds, particularly those species of birds known to fly in the rotor-swept zone (gulls, terns, and northern gannets). Of particular concern are impacts to endangered roseate terns, known to frequent Nantucket Sound, especially between the months of April and September. Although birds at European offshore wind sites demonstrate avoidance behavior of wind turbines, similar behavior around offshore wind turbines in the United States cannot be determined until the turbines are operational. The use of tubular towers, rather than lattice towers, the wide spacing of the wind turbines, and bird deterrent devices on turbine platforms may help discourage perching and thus reduce collision risks. Although the USACE estimates that approximately 364 birds may be killed as a result of collisions with wind turbines, this thesis finds 1) this number is incorrect, as it is based on an average of 2.8 collisions per turbine per year rather than 2.19 collisions per turbine per year; and 2) the USACE estimate may be underestimated by as much as a factor of six, since it is based on the smaller megawatt wind turbines typically used at onshore locations, rather than the 3.6 MW offshore turbines. Fish and benthic organisms are unlikely to be significantly impacted by the Cape Wind site. Habitat alteration will occur during construction activities; however, construction-related impacts will be short-term in duration and affect a limited area of seabed. The incorporation of jet-plowing technology will lessen impacts to fish and benthic organisms by allowing plowing and cable-laying to take place simultaneously,

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rather than in separate intervals. A soft start technique will also be employed during monopile installation, to allow fish to vacate the construction zone and avoid associated high-intensity noises. Lastly, the use of monopile foundations will minimize the area of disturbed seabed. As the first part of this chapter has indicated, the Cape Wind site will have some adverse impacts on marine life. These impacts, however, cannot be truly understood unless they are placed in the proper context that is, how the wildlife impacts from offshore wind development compare to the wildlife impacts associated with existing means of energy generation. The next section of this chapter provides an analysis of the impacts associated with a fossil-fuel burning power plant; the next chapter (Chapter 5) will provide a discussion of how the wildlife impacts of the two means of energy generation (wind versus fossil-fuel burning power plants) compare. 4.4. Case Study of a Fossil Fuel Burning Power Plant Brayton Point Station is a coal- and oil-burning power plant located approximately 55 miles south of Boston in Somerset, Massachusetts. Operational since the 1960s, Brayton Point is the largest fossil-fuel burning power plant in New England with a net generating capacity of approximately 1600 MW. The power plant consists of four generating units: Units 1, 2, and 3 are coal-burning units, while Unit 4 is an oilburning unit. Brayton Point is owned by USGen New England, Inc., an affiliate of Pacific Gas & Electric National Energy Group (USDOE, 1979). Brayton Point Station is situated on 250 acres of land at the confluence of the Lee and Taunton Rivers on the Mount Hope Bay. According to the USEPA (2002, 1-2),

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"Brayton Point Station is the largest industrial discharger impacting the habitat and fishery of Mount Hope Bay." The Mount Hope Bay, an extension of the Narragansett Bay, is a shallow estuary with an average depth of less than 19 feet, and a surface area of 13.6 square miles. A productive estuary, Mount Hope Bay provides habitat for more than 100 species of benthic invertebrates, numerous species of fish (including striped bass, bluefish, weakfish, white perch, tautog, winter flounder, American eel, and northern kingfish), and many bird and waterfowl species (including canvasback ducks, black ducks, herons, egrets, and sandpipers). In addition to a diversity of wildlife species, Mount Hope Bay contains extensive shellfish beds (quahogs and soft shell clams) and represents important spawning and nursery areas for menhaden and winter flounder (USDOE, 1979; USEPA, 2002). Brayton Point has been selected as the focus of this case study as it is the largest fossil-fuel burning power plant in New England and thus a number of relevant environmental studies exist that will serve as a basis for analysis. Less data are available on the environmental impacts of the Canal Electric Station, an oil and natural gas-fired power plant located in Sandwich, Massachusetts alongside the Cape Cod Canal. This plant, which opened in 1968, generates 1120 MW of power, the majority of which is through the burning of oil. Canal Electric Station provides electricity for most of Cape Cod, Martha's Vineyard, and Nantucket Island, and is owned by Mirant Canal LLC. The limited data on the wildlife impacts of the Canal Electric Station will be utilized, as appropriate, in order to further illustrate the wildlife impacts of a coastal power plant.

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4.5.

Wildlife impacts Power plants may also have adverse impacts on wildlife species. These impacts

may occur during the extraction of resources necessary to run power plants (i.e., coal or oil), the transportation of resources to the plant itself, and the operation of the power plant. Many of the wildlife impacts of a power plant are indirect, rather than direct, in nature; that is, many wildlife impacts are not due to the operation of the plant itself, but rather from the activities necessary to the operation of the plant (i.e., habitat displacement as a result of resource extraction, oil spills resulting from transportation of fuel resources to the power plant, etc.). This is somewhat different from an offshore wind facility, where most of the wildlife impacts are a direct result of the wind turbines themselves; for example, physical disturbance of habitat, underwater noise and vibration, and avian collisions with wind turbines. Therefore, rather than analyze the wildlife impacts of a power plant based on the type of species affected (marine mammals, fish, benthic organisms, birds) as was done for the previous case of wind power, this section will analyze wildlife impacts based on two categories: direct impacts and indirect impacts. The goal of this section is to address the wildlife impacts of the Brayton Point power plant and, as appropriate, the Canal Electric Station. The analysis will utilize the FEIS for the Brayton Point power plant, environmental studies from the Rhode Island Division of Fish and Wildlife and Massachusetts Division of Marine Fisheries, and other information as available from state and federal environmental agencies.

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4.5.1. Direct impacts The direct impact of entrainment, impingement, and thermal discharge on fish populations (including fish eggs and larvae) in Mount Hope Bay is perhaps the most well-studied wildlife impact of the Brayton Point power station. Mount Hope Bay is home to a diverse number of fish species; the bay also provides designated essential fish habitat for the various life stages of fourteen species of fish (NOAA, 2005). According to the USEPA (2002), the following are considered "Representative Important Species" of the Mount Hope Bay ecosystem: alewife, Atlantic menhaden, Atlantic silverside, bay anchovy, hogchoker, rainbow smelt, sand lance, seaboard goby, silver hake, tautog, threespine stickleback, weakfish, white perch, and winter flounder. A 1972 entrainment study from the USEPA provides quantitative estimates of the direct impacts of Brayton Point on fish populations. This study, as reviewed by Marcy et al. (1978), estimated that seven million to 165.5 million menhaden and river herring larvae between 5 and 50 millimeters in length were killed via entrainment in a single day at the power plant. While these estimates are several decades old and newer technology might reduce the level of mortality from entrainment, the estimates are nonetheless -dramatic, even if the lower-bound value is assumed (seven million larvae per day). According to Marcy et al., the effects of plant passage on entrained organisms, especially physical impacts, can cause changes in community structure through changes in diversity caused by elimination of less tolerant species and life stages, and size selectivity because of damage or mortality to various life stages of species (Marcy et al., 1978, 151).

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More recent studies on the impacts of entrainment and thermal discharge on fish in the Mount Hope Bay also provide insight into the environmental impacts of Brayton Point. Gibson (2002, Research Reference Document 02/1) analyzed the impacts of Brayton Point station on winter flounder abundance in Mount Hope Bay. The study utilized data from several trawl surveys (i.e., National Marine Fisheries Service, Rhode Island Division of Fish and Wildlife, University of Rhode Island Graduate School of Oceanography, and Marine Research Inc.), as well as impingement data from Brayton Point station, as a measure of winter flounder abundance. Results of the study revealed that "a large reduction in winter flounder abundance occurred near [Brayton Point Station] that did not occur in other areas" (Gibson, 2002, Research Reference Document 02/1, 6). Gibson concluded that the winter flounder abundance in Mount Hope Bay significantly declined as a result of the operation of Brayton Point station. This decline accelerated in the mid-1980s to the point of a complete collapse in the winter flounder stock, as a result of the increased discharge of cooling water and waste heat into the bay after the conversion of generating unit four from closed-cycle to open-cycle cooling (Gibson, 2002, Research Reference Document 02/1). According to the USEPA (2003), the following are the current average annual losses of fish eggs and larvae, as a result of entrainment, at Brayton Point station: 251 million winter flounder; 11.8 billion bay anchovy; 375 million windowpane flounder; and 3.5 billion tautog. Additionally, a month-long impingement event at Brayton Point in 1999 resulted in the loss of 75,000 juvenile and adult Atlantic menhaden. The billions of organisms lost at Brayton Point each year as a result of entrainment and impingement

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include species of "commercial and recreational importance, and forage fish and other organisms integral to the food web" (USEPA, 2003, 2). The USEPA (2002) assessed the effects of thermal discharge from Brayton Point on phytoplankton, zooplankton, habitat formers (i.e., eelgrass), shellfish and macroinvertebrates, fish, and vertebrate wildlife, including marine mammals and sea turtles. The USEPA's assessment notes that "communities showing little or no impact from current operation were deemed to have low potential impact for thermal effects from future operation assuming other stressors stay constant;" however, only one of the aforementioned communities (vertebrate wildlife) were considered to have low potential impact from the thermal effects of Brayton Point station (USEPA, 2002, 6-15). More specifically, the USEPA's assessment finds that thermal discharge from Brayton Point will likely "alter normal phytoplankton population dynamics," resulting in potentially "significant impacts within the trophic dynamics of the food web" (USEPA, 2002, 6-23). Impacts to the phytoplankton communities of Mount Hope Bay are of particular concern as phytoplankton serve as primary producers within the bay. Changes in the zooplankton community of the bay as a result of thermal discharge may harm indigenous populations of fish and shellfish, which are dependent on zooplankton as a food source. Thermal discharge may also affect shellfish, macro-invertebrates, and fish. Mount Hope Bay serves as important spawning and nursery grounds for these organisms, many of which are recreationally and commercially valuable (USEPA, 2002). The assessment does note that thermal discharges from Brayton Point may actually attract some species of fish to warmer waters near the power plant, particularly

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striped bass and bluefish in the fall and winter months. This may be considered a positive impact for sports fishermen; however, the ecological effects are overwhelmingly negative. The crowding of thousands of fish into the area of the thermal discharge plume increases their susceptibility to disease and increases competition for limited food resources, resulting in fish in a compromised physical state. The thermal discharge plume may also attract species that are traditionally warmer-water species; thus shifting the overall balance of the once indigenously-balanced ecosystem. Lastly, the attraction of fish to the thermal plume brings them closer to the cooling water intake pipes of the power plant, thus putting them at greater risk for impingement (USEPA, 2002). The effects of entrainment and thermal discharge may have ecosystem-level impacts in the form of lost food resources from benthic and pelagic food webs, as well as economic impacts in the form of the lost value of fisheries resources that are missing as a result of the operation of Brayton Point. "Production foregone" is a term describing the production that would have been realized by fish during their entire lifespan, had they not been killed by impacts related to power generation. Production foregone accounts for both denied catch opportunities, as well as biomass contributing to higher trophic levels (Gibson, 2002, Research Reference Document 02/2). The difference between the realized fishery production of winter flounder caught in the Mount Hope Bay, and the production of winter flounder that would be caught in the absence of Brayton Point station, is 70 to 140 metric tons per year. For tautog and windowpane, production deficits are 20-40 tons per year and 10-40 tons per year, respectively. Between 1986 and

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2002, the monetary value of this forgone fishery production is approximately 12.7 million dollars, or $800,000 dollars per year (Gibson, 2002, Research Reference Document 02/2). 4.5.2. Indirect impacts Brayton Point power plant has one oil-burning unit, and Canal Electric Station is a predominantly oil-burning facility. Barges and tanker ships transport the oil from petroleum refineries to the power plants, traveling through the Narragansett and Mount Hope Bays to reach the Brayton Point station, and through Buzzards Bay and the Cape Cod Canal to reach the Canal Electric Station. According to the USEPA (2003), approximately 1.8 billion gallons of oil (destined for many sources, not just for Brayton Point station and Canal Electric Station) transit the Cape Cod Canal on an annual basis. The transportation of such large quantities of oil through sensitive coastal ecosystems puts many wildlife species at risk, should a ship transporting oil leak or rupture. Oil spills, although rare in occurrence, may have devastating consequences for affected wildlife species. In April 2003, a fuel barge carrying four million gallons of oil that was destined for the Canal Electric Station grounded in Buzzards Bay, rupturing its hull and spilling 98 thousand gallons of oil. The spill affected approximately 90 miles of shoreline with light to heavy degrees of oiling, and within three days of the spill the entire bay was closed to shell-fishing activities. A month after the spill, just under 50 percent of the bay remained closed to shell-fishing; six months after the spill, 20 percent of the bay was still closed to shell-fishing. Fifteen months after the oil spill (June 2004) less than one percent of the bay remained closed to shell-fishing as a direct result of the oil spill (Buzzards Bay, 2005). The types of shellfish believed to be present in Buzzards

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Bay at the time of the spill include the American lobster, horseshoe crab, American oyster, and hard- and soft-shelled clams (USFWS, 2005). With an oil spill, the concern is not as much for mortality of shellfish themselves as it is for contamination of their meat and potential human health impacts resulting from the consumption of contaminated shellfish. Given that the Buzzards Bay shell-fishing industry is valued at four million dollars annually, significant economic concerns exist for the impacts of an oil spill on shellfish, although such a discussion is beyond the scope of this thesis (Buzzards Bay, 2005). The 2003 oil spill in Buzzards Bay had a serious impact on bird species as well. According to calculations by the Buzzards Bay Project National Estuary Program, 479 birds were killed as a result of the oil spill, representing 38 different species. Among the species oiled were scoters, loons, egrets, grebes, terns, eiders, cormorants, and various species of ducks. Of special concern were the deaths of three federally endangered roseate terns and one federally threatened piping plover. One of the reasons for the high number of bird mortalities is the type of fuel spilled; number six fuel oil is a thick and viscous oil that is more harmful to birds than most other types of fuel oil (Buzzards Bay, 2005). The gray seal, harbor seal, northern diamondback terrapin, and ridley sea turtle were also identified by the USFWS as likely to be present in Buzzards Bay around the time of the oil spill; however, no mortalities attributed to the oil spill were reported for these species (USFWS, 2005). The Natural Resources Damage Assessment (NRDA) for the oil spill is currently being prepared by NOAA with the cooperation of various state

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and federal agencies. The goal of the NRDA is to restore coastal and marine resources fouled by the spill, and obtain compensation for the public's loss-of-use and loss of enjoyment of Buzzards Bay as a result of the spill (Buzzards Bay, 2005). The largest recorded oil spill in Buzzards Bay occurred in September 1969 when an oil barge, also bound for the Canal Electric Station, grounded near West Falmouth, Massachusetts. Approximately 189,000 gallons of fuel oil spilled into Buzzards Bay, with significant adverse consequences for fish and marine invertebrates. According to Sanders (1978, 719), there was "nearly total decimation of the benthic fauna in the area of maximum oil pollution immediately following the oil spill." In the months following the spill, severely oiled inter-tidal and sub-tidal areas were dominated by a single species of an opportunistic worm (Capitella capitata), and species numbers and species density in intermediately oiled subtidal areas were "markedly depressed" (Sanders, 1978, 729). Although quantitative estimates of the number of species affected by the spill are not available, Blumer et al. (1975) note that the ecological effects of the oil spill included widespread loss of fish, shellfish, worms, crabs, other crustaceans, and invertebrates. Commercial shell-fishing was prohibited for more than two years following the spill (Blumer et al., 1975). The release of harmful emissions into the air and, ultimately, into waterways is another indirect way in which a fossil-fuel burning power plant may impact wildlife species and their habitats. Mercury, for example, is released into the atmosphere as a byproduct of coal combustion, and may travel great distances from its source before being deposited on land or in water, where it may be transformed into a more toxic form of

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mercury, known as methylmercury. Mercury contaminates aquatic habitats and bioaccumulates in the food chain, particularly in species that maintain a high trophic position in the food chain such as mammals, predatory fish (i.e., sharks, tuna, and swordfish), and fish-eating birds (MA DEP, 1996). According to the USEPA (1999), Brayton Point is the second largest contributor of hazardous mercury compounds in Massachusetts, emitting 244 pounds of mercury per year. In contrast, the Canal Electric Station, a predominantly oil- and natural-gas fired power plant, emits only 1.31 pounds of mercury compounds per year (USEPA, 1999). Specific quantitative estimates of wildlife mortality from mercury contamination are not available, due in some degree to the fact that mercury released by Brayton Point or Canal Electric Station may travel thousands of miles before being deposited on the earth's surface, ultimately impacting wildlife species and wildlife habitats in locations far removed from Cape Cod. Mercury contamination does not necessarily result in the death of marine species, but rather may result in loss of coordination; mental deterioration; loss of sight; loss of hearing; neurological, developmental, and reproductive impairments; renal failure; and decreased viability. Mercury contamination has even been implicated as the underlying cause of mass strandings of marine mammals on beaches around the world (Wittnich et al., 2004). The Massachusetts Department of Public Health (DPH) has issued fish consumption advisories for 37 state water bodies as a result of mercury contamination (MA DEP, 1996). In addition, the DPH advises pregnant women, women of childbearing age who may become pregnant, nursing mothers, and all children less than 12 years of

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age to avoid eating all freshwater fish, as well as the following types of marine fish, as a result of mercury contamination: shark, swordfish, king mackerel, tuna steak, and tilefish (MA DPH, 2001). While fish consumption advisories are more of a human health impact than a wildlife impact, this impact is an indicator of high levels of mercury in fish tissue, which may also affect predators other than humans, such as larger fish or fish-eating birds. Other toxins emitted by Brayton Point (commonly from coal pile runoff) include iron, copper, zinc, nickel, and lead, all of which may negatively impact the water quality of Mount Hope Bay and degrade aquatic habitats of wildlife species. Iron leachate from coal pile runoff may threaten winter flounder and shellfish in Mount Hope Bay, and manganese and zinc runoff may bioaccumulate in shellfish, ultimately threatening species that feed on shellfish, such as ducks and gulls (USDOE, 1979). Power plants contribute to the formation of acid precipitation through the emission of sulfur dioxides and nitrous oxides; acid precipitation impacts wildlife species through habitat alteration and habitat loss. The FEIS for Brayton Point notes that acid precipitation is "deleterious to both plants and animals" while the USFWS (1978) identifies acid precipitation as the "most important secondary pollutant associated with the emission of a coal-fired power plant" (USDOE, 1979, 3-69; USFWS, 1978, 66). Brayton Point emitted almost 36,000 tons of sulfur dioxide and 11,000 tons of nitrous oxides in 2003, making it the number one source of these pollutants in New England and a significant contributor to acid precipitation. Canal Electric Station emitted approximately 23,500 tons and 5,000 tons of sulfur dioxide and nitrous oxides

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(respectively) in 2003, making it the third largest source of sulfur dioxide and second largest source of nitrous oxides in New England (USEPA, 2003). Acid precipitation in New England has contributed to the acidification of lakes and streams, resulting in a loss of fish species that are intolerant to acidic waters. Sprucefir forests in the eastern United States have also declined as a result of acid precipitation (USEPA, 2003?). Terrestrial species are unlikely to be directly impacted by acid precipitation, as they are protected by scales, feathers, and/or body hair. Impacts to terrestrial species are more indirect in nature, through habitat alteration or habitat loss. Aquatic species, including zooplankton, macro-invertebrates, and fish, are likely to be directly affected by acid precipitation. Impacts may include reduced productivity, disruption of natural cycles, and simplification of food webs (USFWS, 1978). Specific quantitative estimates of wildlife mortality as a result of acid precipitation resulting from the operation of Brayton Point and/or Canal Electric station are difficult to estimate, given the trans-boundary nature of the air pollutants that cause acid precipitation. Similar to mercury emitted by fossil-fuel burning power plants, sulfur dioxide and nitrous oxides may travel hundreds or even thousands of miles before falling to the earth as acid precipitation, ultimately impacting wildlife species and habitat far removed from the power plants that originally emitted the pollutants. Lastly, the physical footprint of a power plant and its associated roads, buildings, and other infrastructure also represent an indirect impact to wildlife species in the form of habitat alteration and habitat displacement. According to the 1979 FEIS for Brayton Point, the power plant occupies approximately 250 acres of land, the majority of which is

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"highly developed and contains little natural vegetation" that may provide habitat for wildlife species (USDOE, 1979, 3-67). The site consists of a nine-acre coal storage pile, a coal-crusher house, a station building containing temporary coal storage silos, five fuel oil storage tanks, a sluice system and wastewater treatment facility for coal bottom ash, ash settling basins, cooling water canals, transmission lines, roadways, and parking facilities. The transportation of coal ash via truck from Brayton Point to a nearby landfill site requires approximately forty round trips per day, increasing local noise levels along truck routes and contributing to air pollution (USDOE, 1979). 4.6. Summary of fossil-fuel related wildlife impacts Brayton Point station has a number of adverse impacts on fish and wildlife species. Direct impacts of Brayton Point on wildlife species include the documented entrainment of millions of fish larvae and fish eggs every day, as well as the collapse of the winter flounder population of Mount Hope Bay as a result of thermal pollution. Indirectly, the many activities necessary to the operation of a power plant including fuel extraction, transportation, and combustion also impact fish and wildlife species through oil spills, heavy metal contamination of aquatic environments, and acid precipitation. While mitigation efforts may reduce the risk of oil spills, or lower the amount of harmful pollutants emitted into the environment by a power plant, these threats can never be completely eliminated due to the continual need for the fuel resource itself. Power plants differ from offshore wind facilities in that they tend to impact species that occupy a lower position in the food chain; for example, plankton, fish larvae, and fish eggs. While these species lack the charisma of larger, more visible species, such

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as marine mammals and birds, they are, nonetheless, an essential component of ecosystems and food webs. The next chapter, Chapter 5, provides a comparative analysis of the impacts from the Cape Wind site as compared to the impacts from Brayton Point.

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Chapter 5 COMPARATIVE ANALYSIS As discussed in the previous chapter, neither an offshore wind facility nor a fossilfuel burning power plant is without some adverse impact on wildlife species. The previous chapter identified the impacts of both an offshore wind facility and a fossil-fuel burning power plant on wildlife species, and in so doing, addressed the first two research questions outlined in the introduction chapter. That is, What are the possible impacts (positive and negative) of offshore wind development on wildlife species; and How do fossil-fuel burning power plants impact wildlife species?

This chapter aims to address the final research question stated in the introduction chapter; specifically, What comparisons can be made between offshore wind facilities and fossilfuel burning power plants in terms of their impacts on wildlife?

5.1.

Scaling Factors Used for Size Comparison The Cape Wind facility and Brayton Point station provide different amounts of

power, with the Cape Wind facility providing less power and being available at a lower percentage of the time due to the inherently intermittent nature of wind. Thus, an accurate comparison of the wildlife impacts of the two facilities must take into account these differences in power output. Table 5.1 identifies the scaling factors used in this chapter. These scaling factors allow for comparisons of impacts from Cape Wind and

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Brayton Point on a per gigawatt basis; for example, acres of land disturbed per gigawatt, avian mortalities per gigawatt, etc.

Table 5.1: Scaling factors used for coal, oil, and wind

Brayton Point (coal; Units 1,2,&3) Brayton Point (oil; Unit 4) Brayton Point (total) Cape Wind
a

Maximum power output (MW) 1157 443 1600 454

Capacity factora (percentage) 80b 20b 63 26c

Actual power outputd (MW) 926 89 1015 118

Scaling factore (impact per gigawatt) 1.1 11.2 1.0 8.5

Capacity factor is defined as the average plant output divided by the maximum possible output over a period of time, generally one year (Denholm et al. 2005). b Source: USEPA (2002) c Source: Pacala and Socolow (2004) d Actual power output is calculated by multiplying the maximum power output by the capacity factor. e Scaling factors are calculated as follows: actual power output in MW is converted into gigawatts (GW), then divided into 1.0 GW in order to provide a scaling factor on a per gigawatt basis. For example, 926 MW = 0.926 GW; 1.0/0.926 = 1.1. The scaling factor for Brayton Point (total) is 0.985, here rounded to 1.0.

5.2.

Wildlife Impacts of Fuel Resource The analysis begins with a need for the resource itself: coal and oil to fire power

plants, and wind to turn the rotors of the turbines that comprise an offshore wind facility. Wind is a naturally occurring phenomenon; its presence and strength off the coast of Massachusetts is one of the primary reasons Nantucket Sound was selected for offshore wind development. Wind does not need to be harvested from the ground like coal or oil, nor does it require transportation to reach its destination, so creating and transporting the

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energy source to the generator is not considered to have any anthropogenic environmental impact. Coal and oil, on the other hand, must be extracted from the earth; doing so requires processes such as mountaintop removal, strip mining, underground mining, and oil exploration, drilling, and pumping activities at offshore locations. Once the resources are extracted from the earth, they must be transported to their destination via truck, rail, barge, or tanker. None of these activities may be considered environmentally benign; impacts affecting wildlife species as a result of these activities (as identified in previous chapters) include habitat displacement, habitat loss, erosion, sedimentation, aquatic habitat contamination, and oil spills. Oil spills that occur during the transportation of fuel to power plant sites are one of the more quantifiable impacts to wildlife species from fossil-fuel burning power plants. Available data from the Buzzards Bay Project National Estuary Program indicate that 479 birds were killed as a result of a 2003 spill of 98,000 gallons of oil (see Chapter 4 for a discussion on the 2003 Buzzards Bay oil spill). By adjusting this mortality figure based on the volume of oil spilled and applying it to other documented oil spills in Buzzards Bay, it is possible to provide an estimate of the number of birds that may have been killed as a result of oil spills in Buzzards Bay in the past several decades. Table 5.2 summarizes documented past oil spills in Buzzards Bay, and provides an estimated number of bird mortalities that might have resulted from these spills, based on the mortality figure (479 bird fatalities) from the 2003 spill.

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Table 5.2: Calculated bird mortality in Buzzards Bay as a result of oil spills, 19692003 Date September 1969 October 1974 January 1977 April 2003 TOTAL
a b

Location West Falmouth Entrance to Cape Cod Canal Entrance to Cape Cod Canal Fairhaven

Source Florida fuel barge Bouchard No. 65 fuel barge Bouchard No. 65 fuel barge Bouchard No. 120 fuel barge

Estimated amount of oil spilled (gallons) 189,000 11,000 37,000 81,144 98,000

Calculated bird mortalitya 924 54 181 397 479b 1854 1981

Mortality numbers are rounded to the nearest whole number. This value represents the documented (rather than calculated) mortality figure for this spill.

Based on the values provided in Table 5.2 above, approximately 1854 to 1981 birds have been killed in Buzzards Bay in the past 34 years, as a result of documented oil spills totaling roughly 400,000 gallons. This translates into approximately 55 to 58 bird fatalities per year for the past 34 years. This comparison, however, is only a rough approximation, and several factors must be addressed when considering this value. First, bird mortalities may vary based on the type of fuel oil spilled. Number six fuel oil the type of oil spilled in April 2003 and the type of oil burned by Brayton Point station -- is a thick, viscous oil that may result in a higher number of bird fatalities, while number two fuel oil (the type of oil spilled in September 1969, October 1974, and January 1977) is a lighter oil that may be less toxic to birds and other wildlife species. Secondly, the number of bird fatalities is dependent on the time of year during which the oil spill

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occurs; for example, the April 2003 spill occurred at the beginning of the mating and nesting season for the endangered roseate tern and the threatened piping plover; therefore, these species were especially vulnerable to an oil spill. The April 2003 spill also occurred during the spring migratory period; therefore, using the number of bird fatalities from the April 2003 spill as the baseline value for estimating bird fatalities from other spills may result in somewhat elevated estimates. Lastly, the estimate of 55 to 58 bird fatalities per year for the past 34 years is extrapolated from only four documented oil spill incidents; other undocumented oil spills in Buzzards Bay may have also contributed to bird mortalities. The estimates provided in Table 5.2 should be considered a rough approximation. Despite the limitations of these data, the estimate provided above illustrates the quantitative impact that activities related to the operation of a fossil-fuel burning power plant (i.e., transportation of fuel oil to a power plant site) may have on wildlife species. One must also consider that wildlife impacts resulting from resource extraction and resource transportation-related activities occur during phases that are not even applicable to offshore wind development. While it is difficult to quantify the number of species displaced or even killed from resource extraction activities such as mountaintop removal, strip mining, and oil exploration, drilling, and pumping activities, the number of species killed is certain to be greater than the impacts from these phases of offshore wind development, for the simple reason that the entire fuel cycle is eliminated from offshore wind energy production.

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5.3.

Wildlife Impacts of Site Footprint The next wildlife impacts analyzed are the footprints of the sites themselves, and

resulting habitat disturbance. A cursory comparison reveals that Cape Wind, a 454 MW facility, will occupy 24 square miles, while Brayton Point station, a 1600 MW facility, occupies less than one square mile of land (approximately 250 acres). However, this is a misleading comparison because the area between the wind towers is a productive and essentially undisturbed ecosystem7, whereas there is no such area within a fossil-fuel burning power plant. A more comparable area is the physical footprint of the 130 wind turbine pilings, the six pilings supporting the electric service platform, and associated scour protection8, rather than the footprint of the entire wind farm area. Comparing in this way, the difference in amount of land disturbed at the two sites is striking. The area occupied by the 136 pilings and scour mats is summarized in Table 5.3, based on the dimensions outlined in the Cape Wind DEIS:

Note that for some species (i.e., birds) the entire footprint of the Cape Wind site may be considered lost habitat, should birds avoid the entire area during turbine operation. 8 Scour protection mats consists of synthetic polypropylene fronds that are similar in appearance to the vegetation commonly found on the seafloor. Six scour protection mats are in place for each piling. Each mat measures 16.5 feet by 8.2 feet (5 meters by 2.5 meters).
7

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Table 5.3: Land area requirements of the Cape Wind facility

Piling radius (feet)

Purpose

Area of sea floor occupied per piling (square feet) 222

Number of pilings

Area of sea floor occupied by pilings (square feet) 22,644

8.4

1.8

Support wind turbines in 0 to 40 foot depth Support wind turbines in 40 to 50 foot depth Support electric service platform

102

Area of sea floor occupied by scour matsa (square feet) 105,300

254

28

7,112

10

60

4860

TOTAL
a

29,816

110,160

Total area of sea floor occupied by scour mats calculated as follows: (135 square feet per mat*6 mats per turbine*130 turbines) + (135 square feet per mat*6 mats per ESP piling*6 pilings).

The total area occupied by the 136 pilings plus scour protection yields a total area of disturbed seabed of slightly less than 140,000 square feet (approximately 3.2 acres or 0.005 square miles). [If the area of seabed occupied by the connecting cables is also considered, the total area of disturbed seabed increases from approximately 140,000 square feet to approximately 29,800,000 square feet (approximately 688 acres). The connecting cables,

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however, are buried six feet beneath the surface of the sea floor, and do not represent a permanent disturbance to the seabed in the same way as the pilings and scour mats]. Although the entire 250-acre parcel of land occupied by Brayton Point station is unlikely to be permanently disturbed (just as the entire 24 square mile Cape Wind site is not permanently disturbed), an examination of a map of the facility, as provided in the Brayton Point final environmental impact statement (FEIS), reveals that approximately 80 percent of the 250 acre site (200 acres) has been permanently disturbed by buildings, coal and oil storage facilities, cooling water canals, transmission lines, roadways, parking facilities, etc. Of these 200 acres of disturbed land, approximately 75 percent (150 acres) appear to be dedicated to coal use (based on visual estimation from site map), while approximately 50 acres appear to be dedicated to oil use (USDOE, 1979). The area of land occupied by Brayton Point station does not include the land necessary for coal mining, coal processing, and waste storage. According to Shen (1980), a 1000 MW coal-fired power station requires more than 12,000 acres of land for coal mining, coal processing, and waste storage, and an additional 3000 acres of land for associated roads and structures. Brayton Point's 1600 MW facility (of which 1157 MW are produced by the burning of coal) would thus require approximately 13,900 acres of land for coal mining, coal processing, and waste storage; and approximately 3500 acres of land for associated structures and roads. These area calculations indicate that coalburning power plants permanently disturb thousands of acres of land, while the area of seabed permanently disturbed by wind turbines is three orders of magnitude less due in

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large degree to the lack of resource extraction and resource transportation needed for wind power. Table 5.4 compares the land requirements for the Cape Wind site to the coal burning portions of Brayton Point. The values provided are adjusted by the scaling factors presented in Table 5.1, to allow for a comparison on a per gigawatt basis:

Table 5.4: Land area requirements for Cape Wind and Brayton Point

Cape Wind Brayton Point (coal)

a

Land area required for coal extraction, processing, transportation (acres) 0 17,400

Area of land disturbed by facility (acres)

Scaling factor (per gigawatt)

Total disturbed area (acres) per gigawatt 27a 5,850 19,305b

3.2 688 150

8.5 1.1

Land area occupied by Cape Wind is calculated as follows: 3.2 acres (area occupied by 136 pilings and associated scour protection mats) * 8.5 (scaling factor, accounting for difference in size between Cape Wind and Brayton Point, see Table 5.1) = 27.2; or 688 acres (area occupied by 136 piling, associated scour protection mats, and connecting cables) * 8.5 = 5,850. b Land area occupied by coal-burning area of Brayton Point is calculated as follows: (17,400 acres + 150 acres (area of land estimated to be dedicated to coal use)) * 1.1 (scaling factor, see Table 5.1) = 19,305.

As illustrated in Table 5.4, the coal-burning portion of Brayton Point station disturbs 19,305 acres of land per gigawatt; the comparable area of land that will be disturbed by Cape Wind is 27 acres per gigawatt (or 5,850 acres per gigawatt if connecting cables are considered to be a permanent disturbance of the seabed). The land area required for coal extraction, processing, and transportation, rather than the land

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required for the power plant itself, is the driving factor behind the large land requirement for Brayton Point. 5.4. Wildlife Impacts of Site Operation The only quantitative estimate available for wildlife impacts from the operation of the Cape Wind facility is an estimate of avian mortality. The Cape Wind DEIS estimates that 364 birds are likely to be killed every year as a result of collisions with the turbines (this estimate should be 285; see Chapter 4 for derivation of this number). Applying the scaling factor of 8.5 from Table 5.1 results in a mortality estimate of approximately 2400 birds per gigawatt. While this number may seem insignificant compared to the millions of birds estimated to be killed each year as a result of collisions with cars, buildings, communication towers, windows, etc., bird kills resulting from the construction and operation of a new facility are still an adverse environmental impact that must be considered as an environmental cost of the project. An estimation of the number of birds killed at the Cape Wind site is particularly important, given the presence of several federally protected species of birds in the immediate vicinity of the Cape Wind site, the high avian use of the area, and the importance of Nantucket Sound as a stopover point for thousands of migratory birds each year. The only quantitative estimates of wildlife mortality resulting from the operation of Brayton Point are the estimates of entrainment and impingement of fish larvae and fish eggs in the cooling water intake screens of Brayton Point. A 1972 study estimates that seven million to 165.5 million larvae were entrained in a single day at Brayton Point. Over the course of one year, this translates into a minimum of 2.6 billion larvae killed as

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a result of entrainment. The USEPA (2003) estimates a much higher annual mortality for fish eggs and larvae as a result of entrainment: 251 million winter flounder, 11.8 billion bay anchovy, 375 million windowpane flounder, and 3.5 billion tautog (total estimate: 15.9 billion eggs and larvae per year). Since it is difficult to clearly distinguish whether entrainment and impingement impacts are the result of the coal burning portion of Brayton Point, the combined (coal + oil) plant scaling factor of 1.0 (see Table 5.1) is used. Given the importance of these organisms as a source of food for larger species, as well as the important niche they occupy in the food web, this level of mortality is significant. Thermal discharge, another impact resulting from the operation of Brayton Point, is blamed for the collapse of the winter flounder population in Mount Hope Bay in the mid-1980s. Comparing the impacts to birds from the operation of Cape Wind and the impacts to fish from the operation of Brayton Point is difficult; after all, how does one compare a fish to a bird, or 285 bird mortalities to the loss of billions of fish eggs and fish larvae? An economic analysis may provide some perspective; for example, Gibson (2002, Research Reference Document 02/2) calculates the value of production foregone as a result of Brayton Point station. Production foregone is a term describing the production that would have been realized by fish during their entire lifespan, had they not been killed by impacts related to power generation. Production foregone accounts for both denied catch opportunities, as well as biomass contributing to higher trophic levels. The difference between the realized fishery production of winter flounder caught in the Mount Hope Bay, and the production of winter flounder that would be caught in the absence of

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Brayton Point station, is 70 to 140 metric tons of fish per year (Gibson, 2002, Research Reference Document 02/2). The economic value of this foregone fishery production over a 15 year period (1986 to 2002) is more than 12 million dollars. A similar economic analysis of avian mortality at the Cape Wind site may provide for a comparison with fish mortality from Brayton Point; for example, an estimate of lost tourism revenue from bird watching activities as a result of Cape Wind-related avian mortality could be compared to production foregone as a result of thermal discharge from Brayton Point. When considering the wildlife impacts resulting from the operation of Cape Wind versus the operation of Brayton Point, an ecological analysis might be a useful means for comparing wildlife impacts that is, an evaluation of the different species affected and the role they play in their surrounding ecosystems. Cape Wind, for example, will impact birds and may impact marine mammals large, visible, charismatic species for which humans have a fair amount of interest and concern. Brayton Point, on the other hand, impacts (among other species) juvenile and adult fish, fish larvae, and fish eggs. These creatures do not have the intrigue or beauty of birds or marine mammals, yet they occupy an essential position in the food chain and serve as prey items for larger species (including birds and marine mammals, as well as other predators). Impacts to these species may have larger implications on an ecosystem-wide basis than direct impacts to birds or marine mammals. Therefore, while a species such as the winter flounder may fail to generate the public attention and concern that birds and marine mammals receive, impacts from energy generation to these species are no less significant and deserve no less attention.

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From a strictly quantitative perspective, Brayton Point station has a larger impact on fish and wildlife species than Cape Wind, if one considers the hundreds of birds killed by oil spills, the thousands of acres of land disturbed, and the billions of fish, fish larvae, and fish eggs killed via impingement, entrainment, and/or thermal discharge. Other wildlife impacts, while not easily quantified, must also be considered when comparing the wildlife impacts of Brayton Point to Cape Wind. Pollutants emitted from a fossil fuel burning power plant, such as sulfur dioxide, nitrous oxides, carbon dioxide, and heavy metals, impact wildlife species either directly or indirectly. The effects of these pollutants on wildlife species may have long-lasting effects, such as exclusion from important habitats, physical impairment, and in some cases, reduced breeding potential. For example, populations of the Wood Thrush, a neotropical migrant bird that breeds along the east coast of the United States, have demonstrated significant, long-term, negative trends range-wide in the past thirty years. According to Hames et al. (2002), acid deposition has a strong, highly significant, negative effect on the predicted probability of breeding for the Wood Thrush. Acidic deposition may also lead to a decrease in fish abundance, decreased abundance of insects, invertebrates, and tree seeds, a decrease of calcium-rich materials necessary for eggshell formation and skeletal growth, and an increase in the biological availability of metals such as aluminum, cadmium, and lead, all of which may adversely affect bird populations (Graveland, 1998). Since no such pollutants will be emitted from the Cape Wind facility, the associated impacts of these pollutants on wildlife species can be considered to be "zero."

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This is not to say that Cape Wind will have no adverse impact on wildlife species; aside from avian fatalities, other impacts will include increased levels of underwater noise and vibration, increased sedimentation and turbidity from construction activities, displacement and/or mortality of prey species, and habitat alteration. Many of these impacts, however, are expected to be short-term in duration, with no significant longterm, population-level impacts to wildlife. The possible exception to this is the increase in underwater noise and vibration, which will impact wildlife species as long as the wind farm is in operation. Moreover, underwater noise from other sources, such as shipping, sonar, and scientific research activities, has been shown to adversely impact marine species, and is an issue of growing international concern. Therefore, the potential for underwater noise from an offshore wind facility to cause harm to fish and wildlife species must be carefully evaluated and comprehensively addressed before, during, and after construction and operation activities. Habitat alteration as a result of the Cape Wind facility will also have longer-term effects on wildlife species, although as demonstrated in the previous table, the physical area of seabed disturbed by the Cape Wind facility is much less significant than the similar impact from Brayton Point. Lastly, an analysis of the wildlife impacts of the Cape Wind site would not be complete without considering the environmental impacts of the construction, installation, and operation of the wind turbines themselves. Not only does the physical construction of a wind turbine, installation, and operation require the consumption of natural resources, but these activities also result in the production of pollutants (greenhouse gases, sulfur dioxide, and nitrogen oxides). Denholm et al. (2005) provide an analysis of

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the environmental impacts of wind energy over the entire lifespan of a project, including manufacturing, operation, and disposal of the wind turbines. Denholm et al. (2005, 1908) note that "while wind turbines produce no GHG emissions during normal operation, current reliance on fossil fuels for manufacturing and transportation result in emissions from turbine construction, installation, and maintenance." Nevertheless, criteria pollutants as well as greenhouse gas emissions from wind power are less than the emissions from a fossil fuel fired power plant. For example, a wind system operating at a 25 to 50 percent capacity factor would result in a SO2 emission rate of less than 0.02 grams per kilowatt-hour (g/kWh) and a NOX emission rate of less than 0.1 g/kWh. A typical coal-fired power plant in the United States has a SO2 emission rate of two to 10 g/kWh and a NOX emission rate of two to four g/kWh (Denholm et al., 2005; note that Denholm et al. calculate emissions on a per KWh basis; thus, the scaling factor from Table 5.1 is not additionally applied to these values). Emissions of sulfur dioxide, nitrous oxides, and carbon dioxide from a wind plant and a coal power plant are summarized in Table 5.5.

Table 5.5: Life cycle emissions of wind compared to coal power plants, including manufacturing, operations, and fuela.

SO2 NOX CO2

a b c

Wind powerb <0.02 g/kWh <0.1 g/kWh 5-25 g CO2 eq/kWhc

Coal power 2-10 g/kWh 2-4 g/kWh 900-1100 g CO2 eq/kWh

Source: Denholm et al. 2005. Assumptions: no compressed air energy storage, capacity factor range ~25-50 percent. CO2 eq = CO2 mass equivalents

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Based on all the above wildlife impact comparisons (excluding the emissions comparison), Table 5.6 summarizes the quantitative impacts of Cape Wind and Brayton Point on marine mammals, fish, benthic organisms, and birds.

Table 5.6: Impacts of Cape Wind and Brayton Point on four different types of wildlife species

Cape Wind Marine mammals/sea turtles No mortality expected Fish Limited mortality to larvae and eggs expected from construction activities Benthic organisms Limited mortality expected from construction activities and associated seabed disturbance Moderate to high mortality possible; 238-285 birds estimated to be killed annually, although figure may be as high as 1710. [Applying scaling factor of 8.5 results in range of 20232423, and a high-end value of 14535].

Birds

Brayton Point No mortality expected Extremely high mortality; 15.9 billion fish eggs and larvae killed annually from impingement and entrainment Moderate mortality expected from effects of thermal discharge, heavy metal contamination, and oil contamination Moderate to high mortality possible to birds from effects of acid rain

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5.5.

Summary The goal of this chapter was to provide an understanding of how the fish and

wildlife impacts from the Cape Wind site compare to those from Brayton Point. As discussed above, from a quantitative perspective, Brayton Point has a much more significant impact than would the Cape Wind project (in terms of the number of species impacted, the number of individuals of each species killed or otherwise affected, and the acres of habitat altered). This is due to Brayton Point's use of coal and oil, resources that require extraction, transportation, storage, and combustion in order to produce electricity phases that are not part of the life cycle of an offshore wind facility. Many of the impacts resulting from the operation of Brayton Point, such as thermal discharge, acid deposition, and heavy metal contamination, are likely to have long-term effects, not only at the local level but on a larger, ecosystem-level scale as well. The comparison presented in this chapter is not intended to downplay the wildlife impacts of the Cape Wind facility. To the contrary, the effects of habitat alteration, increased levels of underwater noise and vibration, and avian collisions with wind turbines are serious impacts in their own right and require ongoing study and analysis. Rather, the purpose of this chapter is to provide the reader a context within which to consider the wildlife impacts of offshore wind development, in order to make more informed decisions concerning the role of wind power in the United States. Without considering the impacts of wind power in this greater context, the analyst could slip into the error of evaluating wind power in isolation, as if electricity would otherwise come from sources with no wildlife impacts at all.

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The following concluding table provides a summary of the types of impacts that may occur as a result of the construction, operation, maintenance, and decommissioning of Cape Wind and Brayton Point. Table 5.7: Summary of types of impacts from Cape Wind and Brayton Point

Type of Impact Resource extraction

Cape Wind No impact

Brayton Point Habitat alteration/loss; acid mine drainage; increased erosion and sedimentation; impaired water quality Oil spills; increased tanker/barge/rail/truck traffic; closure of fishing grounds/shellfish beds from oil contamination; wildlife mortality resulting from oil spills Heavy metal leachate from coal storage piles; leaking oil from oil storage containers; impaired water quality from contaminated run-off Emissions of sulfur dioxide, nitrous oxides, mercury, and other toxins; habitat alteration/loss from acid precipitation; heavy metal contamination of aquatic habitats; bioaccumulation of toxins in food chain

Resource transportation

No impact

Resource storage

No impact

Fuel combustion

No impact

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Type of Impact Site Construction

Cape Wind Habitat alteration/loss; displacement from habitat leading to use of other high-risk habitats (i.e., shipping lanes); underwater noise and vibration; prey displacement/mortality

Brayton Point Habitat alteration/loss; displacement from habitat

Site Operation and maintenance

Habitat alteration/loss; displacement from habitat; underwater noise and vibration; increased vessel traffic; collisions with turbines Same as construction

Entrainment; impingement; thermal discharge; changes in ecosystem dynamics; see also impacts under "Fuel combustion"

Site decommissioning

Same as construction

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Chapter 6 CONCLUSION Offshore wind energy is gaining greater attention throughout the world as a viable means of renewable energy production. The push for renewable sources of energy is strengthened by the recent rise in oil and gas prices, as well as by concern for the potential impacts of global warming. The incorporation of offshore wind energy, however, is slowed by aesthetic objections and the "not in my backyard" attitudes of many coastal landowners, as well as by concerns for fish and wildlife impacts. As this thesis has shown, concerns for wildlife impacts are not without merit: such impacts may occur during all phases of offshore wind development, and include habitat alteration, habitat displacement, increased levels of underwater noise and vibration, and in some cases, wildlife mortality. Many people indicate concern for impacts to fish and wildlife species as a reason for not supporting the Cape Wind site, yet they do not appear to consider how nearby power stations like Brayton Point and Canal Electric impact fish and wildlife species. This type of comparison has, to date, been absent from the debate over offshore wind energy. This thesis has attempted to better understand the wildlife impacts of offshore wind energy and inform the offshore wind debate by considering wildlife impacts in light of the wildlife impacts from fossil fuel power production, rather than in isolation. When the wildlife impacts of the Cape Wind project are considered in this way, it becomes

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evident that while still a concern the wildlife impacts from Cape Wind are not nearly as great as the wildlife impacts from Brayton Point station. This thesis research concludes that, from a quantitative perspective, Brayton Point has a larger impact on wildlife species than Cape Wind. Impacts from the former include the hundreds of birds killed by oil spills, thousands of acres of land disturbed, and billions of fish, fish larvae, and fish eggs killed annually by entrainment, impingement, and thermal discharge. The effects of acid precipitation and heavy metal contamination, although not quantified in the literature, are known to have long-lasting effects on wildlife species, including habitat exclusion, physical impairment, and reduced breeding potential. Additionally, fossil fuel burning power plants such as Brayton Point contribute to global climate change by releasing large quantities of greenhouse gases. Global climate change is likely to have an even greater impact on wildlife species and wildlife habitat than any of the impacts discussed in this thesis, although such an analysis is beyond the scope of this thesis9. Incorporating a discussion on the wildlife impacts of global climate change into the debate over offshore wind energy may, however, provide for a more regional or global perspective on offshore wind development, which thus far has received more attention at the local level. Identifying the impacts of global climate change on wildlife species may even lead to increased support for offshore wind development, particularly if those who object to offshore energy development because of wildlife DEFRA (2005) has recently released a report addressing wildlife impacts of climate change, with a particular emphasis on migratory species. The full report is available at http://www.defra.gov.uk/wildlife-countryside/resprog/findings/climatechangemigratory/index.htm.
9

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concerns consider the greater (and potentially more severe) implications of climate change on wildlife species. In contrast to fossil fuel burning power plants, offshore wind facilities (such as the proposed Cape Wind facility) require neither resource extraction nor resource transportation activities, occupy far less land on an acres per gigawatt basis than power plants, and produce fewer harmful emissions throughout their lifespan than a power plant. Additionally, and perhaps even more significantly, offshore wind development may play an important role in efforts to mitigate global climate change, which (as discussed in the previous paragraphs) will likely have significant impacts on wildlife species and wildlife habitat. This research is merely a first step towards a more comprehensive evaluation of the wildlife impacts of offshore wind development. While this thesis indicates that the wildlife impacts of fossil fuel power production are significantly greater than similar impacts from offshore wind development, the role this information may play in the debate over offshore wind development has not been explored. Perhaps a greater understanding of the wildlife impacts of offshore wind development, relative to the wildlife impacts of fossil fuel power production, will provide for a more balanced and informed discussion amongst the general public, regulatory officials, and wind developers. Public meetings and information sessions on offshore wind development may benefit from the incorporation of the conclusions presented in this research, and allow participants to engage more meaningfully in discussion and debate.

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This thesis also highlights gaps in our existing knowledge concerning the wildlife impacts of offshore wind development, and identifies topics for future study. For example, limited data are available on the impacts from underwater noise and vibration, specifically as a result of offshore wind turbine construction, operation, and decommissioning activities. Given the extent of our present knowledge on the adverse impacts of shipping noise, seismic exploration, and military sonar on marine species, this issue should be studied in much greater detail. Other wildlife impacts, including habitat displacement, avoidance, and/or habitat abandonment, cannot be fully evaluated until the post-construction phase of offshore wind development; therefore, the need for comprehensive post-construction monitoring and evaluation studies cannot be overemphasized. In addition, attention should be devoted to the impacts of wind turbines on an ecosystem as a whole, rather than on a species-specific basis (i.e., the impacts of collisions on bird species, or underwater noise and vibration on marine mammal species), as well as to the potential cumulative impacts of multiple offshore wind facilities along the eastern coast of the United States. This type of ecosystem-level analysis may allow for improved site selection in the future. Lastly, economic analyses, such as a costbenefit analysis or a contingent valuation study, may enrich existing knowledge by providing a means to weigh the public's desire for healthy and diverse ecosystems against their practical need for energy. There are several limitations to this research that should be emphasized. One significant limitation is the hypothetical basis of this research: Cape Wind has yet to be built, and there is no guarantee that it will be constructed in the future. Even if it does

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become a reality, the wildlife impacts of Cape Wind, or any offshore wind facility, cannot accurately be evaluated until after construction and operation commence. However, even if offshore wind development is not realized in the United States, the underlying message of this thesis research still holds true: an analysis of the environmental impacts of a new development scenario must also consider the impacts of the alternative (existing) scenario, rather than merely considering the impacts of the new scenario in isolation. Another limitation to this research is the assumption that wildlife impacts do, indeed, play a deciding role in determining one's support or opposition to offshore wind development. While surveys conducted on Cape Cod indicate that wildlife impacts play an important role in the public's decision making process, it is possible that objections to Cape Wind are actually rooted in less socially acceptable reasons such as spoiled ocean vistas or decreased property values. For those Cape Cod residents who truly do object to the development of Cape Wind over concerns for wildlife impacts, this research will hopefully provide a greater perspective on the wildlife impacts of energy generation. Data used in the analysis of the wildlife impacts from Brayton Point station are old and possibly outdated. Newer technologies may mitigate some of the risks presented in this thesis; however, more recent studies on the wildlife impacts of fossil fuel power plants are not available. This research highlights the need for updated information on the wildlife impacts of fossil fuel burning power stations, particularly impacts resulting from entrainment, impingement, and thermal discharge.

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Lastly, the comparative analysis presented in this thesis research uses Brayton Point station, the largest and most polluting fossil fuel power plant in New England, as a case study subject. Wildlife impacts of Brayton Point station (particularly the impacts that are a direct result of the operation of Brayton Point, such as entrainment, impingement, and thermal discharge) are likely to be more severe than those from a smaller fossil fuel power plant that emits fewer pollutants and/or requires a smaller intake of water for cooling purposes. Therefore, the comparative analysis presented in this research most likely represents the "worst case scenario" in terms of the wildlife impacts of a fossil fuel power plant. A smaller, less-polluting power plant, however, still requires resource extraction, transportation, and processing activities that are not applicable to an offshore wind facility; thus, while the wildlife impacts of a different fossil fuel power plant may be less than those presented within this research, the impacts would still be greater than those from a facility such as Cape Wind. Offshore wind energy is only beginning to gain a tentative foothold in the United States. As with the introduction of other new technologies, resistance is high and progress is slow; and long-term benefits are frequently overshadowed by the short-term costs. The key to acceptance of offshore wind development lies in our ability to appreciate its long-term benefits; that is, to view offshore wind development not from the perspective of the hundreds of birds that may be killed by collisions with turbines each year, but rather from the perspective of the hundreds or perhaps thousands of birds that may not be killed each year as a result of acid precipitation, mercury contamination, or oil spills.

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Offshore wind energy is not without environmental and aesthetic consequences, yet it offers so much in return: cleaner air, clearer skies, improved human health, and healthier ecosystems. Too often, we lose sight of these less tangible benefits, focusing instead on the more obvious costs of offshore wind development, such as avian mortality or obstructed horizons. As the United States seeks to establish an offshore wind energy regime, it is imperative that we properly address the social and environmental consequences of offshore wind development, but not lose sight of the long-term local, regional, and global benefits it has to offer.

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APPENDIX

Figure A.1: Map of southeastern Massachusetts showing Brayton Point Station and the proposed Cape Wind site10.

10

Source: http://www.maps.google.com

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