ESI serves environmental needs of the wind industry from siting through post-construction requirements. We complete field surveys, agency negotiations, and permitting to ensure proper avoidance and minimization of impacts to structure a project that will obtain regulatory approvals. The quality and continuity we provide throughout the process helps our Clients bring their projects to fruition on time and on budget.
One of the most significant obstacles that developers of wind energy face is the lack of a consistent, clearly defined lead federal agency and associated guidelines. In 2007 the Wind Turbine Guidelines Advisory Committee was established to provide recommendations on avoiding and minimizing impacts to wildlife and their habitats from land-based wind energy developments. Despite multiple revisions since then, the Committee remains without a mechanism for enforcement and the guidelines still leave many aspects of the environmental process, ranging from siting to permitting, without clear directives. Consequently, regulation of wind facilities has fallen to the state, county and/or even the local level, producing a regulatory setting where requirements vary among facilities.
At ESI, we work with project developers and engineers to ensure timely identification of project obstacles and delivery of regulatory approvals to produce a profitable project. Our experience with projects across the Midwest and Northeast makes us adept at navigating the manifold layers of requirements associated with wind turbine developments. We complete initial siting analysis and permit preparation, and assist in compliance with a variety of federal requirements, including those associated with Section 401 & 404 of the Clean Water Act (CWA), the Endangered Species Act (ESA), Migratory Bird Treaty Act (MBTA), and Bald and Golden Eagle Protection Act (BGEPA).
The first stage of environmental compliance for project development is a series of prescreening studies designed to identify ecological resources that should be avoided (i.e. wetlands, rare and unique species, concentrations of wildlife, etc.). Typically this screening includes a cursory desktop review based upon publicly available data including but not limited to National Wetlands Inventory (NWI) maps and species occurrence information, and is augmented by windshield surveys or ground-truthing.
ESI generates wetland and waterway boundaries that are adequate for siting from prescreening efforts; costs of this effort are significantly less than conventional delineations. The pitfalls associated with lack of adequate wetland boundaries during siting includes costly re-design work later to avoid wetlands, renegotiations with landowners, and potential inability to locate a turbine as desired.
One challenge for the wind industry is that often the most significant impacts to wildlife from turbines are associated with project operation, especially in regard to bird and bat mortality. Impacts to these taxa are a critical issue because U.S. Fish and Wildlife Service (USFWS) may require that operations are curtailed, which can reduce energy production to a point that a project is financially unviable. Thorough and accurate avian pre-sighting screening is an important tool to minimize project timelines and limit the potential for curtailment.
Once basic landscape screening is complete and potential project study areas identified, ESI offers an additional, significant, value-added service. Because we have nationally-recognized bat experts on staff, we can use Collision Risk Models to predict likely mortality rates for endangered Indiana bats at proposed project sites. This analysis provides insight into possible curtailment restrictions; it provides tangible information for strategic decision making very early in the project-development process.
Once the decision to proceed to detailed field studies is made, ESI surveys for wetlands, birds, bats, plants, and other unique ecological resources to meet requirements of federal and state agencies. We identify opportunities for avoidance and minimization measures throughout the project; in the event impacts to resources exceed thresholds of significance we provide solutions to move projects through to fruition, including preparation of compensatory mitigation plans and Habitat Conservation Plans. Finally, we prepare permit applications consistent with state and federal criteria to bring projects online.
Once the facility is operational, ESI completes post-construction mitigation and monitoring studies to comply with requirements of the Tier 5 Wind Turbine Guidelines to determine the species, number, and rate of bat and bird deaths attributed to project operation. We use credentialed field biologists on-site during these efforts to assure the quality of our work, and, perhaps, more importantly, this expertise provides critical insight into such issues as identifying problem turbines and using best available science to negotiate potential curtailment regimes.