Reject Kawailoa Wind Farm's application to kill 140 MORE endangered Hawaiian hoary bats
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Subject: Proposed Kawailoa Wind Farm application to kill 140 MORE endangered Hawaiian hoary bats (and other endangered animals, https://dlnr.hawaii.gov/wildlife/files/2018/10/Kawailoa-Wind-Power-Draft-HCP-Amendment.pdf and https://www.fws.gov/pacificislands/articles.cfm?id=149489649); written comments to State DLNR were due February 21, 2019, to Glenn.M.Metzler@hawaii.gov and written comments to US Fish and Wildlife Service due June 10, 2019 to HIwindPEIS@fws.gov.
Dear Endangered Species Recovery Committee and US Fish and Wildlife Service,
Approval of Kawailoa Wind Farm’s application to continue to operate at night and kill 55 (Tier 4) plus an additional 85 (Tier 5) nocturnal endangered bats (in addition to the 60 bats this wind farm has already killed without mitigation) would not be lawful (not to mention the additional 65 (Tier 6) the applicant requested). The wildlife agencies must require the wind farm to shut down at night when wind speeds are 8 meters/second or lower (when bats are flying near the turbines) until mitigation to offset the bat deaths at the wind farm is developed and included in the incidental take license application. The wind farm must shut down at night because it is practicable for them to do so (because they can afford to). Your staff must oversee an independent auditor's assessment of maximum extent practicable.
Kawailoa Wind Farm generates less than 2% of Oahu's energy - operation of this wind farm at night (less than 1% of Oahu's energy) is not worth risking the loss of Oahu’s endangered bat population.
During only six years of operation, Kawailoa Wind Farm’s take of more than 80 bats far exceeds the 60-bat limit anticipated when you authorized the wind farm’s construction in 2012. In your 2011 and 2012 incidental take licenses to Hawaii wind farms, we were led to believe the wind farms would offset their bat kills with mitigation projects that would increase bat populations. The wind farms said they would help bats by removing feral ungulates and restoring native forest and wetland areas. Unfortunately, bats did not increase when ungulates were removed and habitat was restored, and even worse, bat occurrence declined at some mitigation sites.
Kawailoa Wind Farm now requests a permit to kill an additional 55 bats "Tier 4" and they want the wildlife agencies to agree they are offsetting take of 55 bats by helping purchase 3,000 acres of agricultural and preservation above Whitmore Village and Halemano. The HCP does not meet the requirements of endangered species laws because it does not explain how the transfer of title for land that’s already zoned agricultural and preservation would benefit a bat, let alone offset the take of 55 bats at the wind farm. The best available science by HT Harvey, funded by Kahuku Wind Farm, indicates the core area territory size for each male bat is approximately 2,900 acres and the bats prefer feeding in grazing land, gulches, and low density developed areas. How would title transfer for 3,000 acres increase the endangered bat population by 55? And if it did increase bat numbers - the spinning blades of five of the wind turbines are visible just across the slope from the mitigation site - the bat's territory would span from the mitigation site to the wind farm where it would be killed at night by a spinning turbine blade.
Kawailoa proposes tiers “four”, “five” and “six” levels of endangered bat take. None of these “tiers” of take should be authorized until a proven mitigation method is developed. The wind farm must shut down at night to avoid bat take until the mitigation method is developed. The wind farm has the option to conduct research to inform development of a mitigation method - this research in itself is not mitigation. Once a mitigation method is confirmed, the wind farm can resubmit their application for the license to kill the bats. To avoid uncertainty, mitigation benefits should be required to accrue prior to the taking.
Even IF there were a large number of endangered bats on Oahu and take of 200 of them without effective mitigation would not jeopardize the continued existence of the species on the island, the proposal does not meet the minimize and mitigate take to the "maximum extent practicable" license requirement. If take of endangered species is not offset with mitigation, state endangered species law requires that the take be avoided “to the maximum extent practicable”. “Maximum extent practicable” determinations include a financial assessment of what’s affordable to the developer. You don’t have to be an accountant to see Kawailoa Wind Farm can afford to shut down at night and forego that 45% of their income. First, Kawailoa Wind Farm just “reorganized” their debt in Chapter 11 bankruptcy and essentially bought the wind farm from themselves for pennies on the dollar and shed their debt. Second, Kawailoa Wind Farm’s gross receipts from HECO ratepayers is over $34 million/year because Kawailoa has one of the outdated HECO power purchase agreements raking in $0.22/kwh (whereas today, wind farm power purchase agreements will be approximately $0.10/kwh). In addition, Kawailoa Wind Farm receives a feed in tariff from taxpayers for each kwh it feeds into the grid.
Please do not authorize Kawailoa Wind Farm to operate at night – production of less than 1% of Oahu’s energy is not worth risking extinction of Oahu’s endangered bats.
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