Wildlife and Wind Turbines in Prince Edward County

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1 Wildlife and Wind Turbines in Prince Edward County Prepared for The Alliance to Protect Prince Edward County Draft March 3, 2008

2 Page 2 Executive Summary Planning for wind turbines in Prince Edward County s South Marysburg must take into account the following facts: Environment Canada s environmental assessment guidelines stress that proper siting of wind turbines is the key to reducing bird collision fatalities and habitat disturbance. PEC s south shore has been variously designated as a Provincial Wildlife Area, National Wildlife Area, and Important Bird Area. Environment Canada assigns very high sensitivity (or risk) to wind turbines which would be adjacent to National Wildlife Areas and Important Bird Areas and for areas through which birds migrate, such as the PEC South Shore. Bird Studies Canada states that most of the specific risks associated with turbines require further research in Canada and eastern North America. However, the number of bird fatalities rises in proportion to the number of wind turbines. Consequently, proposals for wind turbine installations near PEC s south shore conflict with recognized land usage and environmental standards. Predictions about avian risk, whether high or low, cannot be made because of the inadequate research base. But one thing is clear: It is inadvisable to set up multiple hazards in a high traffic area for birds.

3 Page 3 CONTENTS Executive Summary Introduction Legal Status of PEC South Shore Species and Ecosystems affected by Wind Turbines Number and Variety of Birds in PEC South Shore Bird Species at Risk Bat Species at Risk Other Species at Risk Environmental Assessment of Avian Risks Causes of Adverse Effects by Wind Turbines Number of Turbines Tower Dimensions and Turbine Design Wires Limited Effects: Construction Disturbance Unknown Effects: Turbine Lighting, Blade Speed, and Facility Configuration Meteorological Conditions and Physical Features of the Landscape Limits of Knowledge Environmental Laws Environmental Assessment Standards Conclusion References

4 1.0 Introduction Page 4 Twice a year, March through May, and late August into November, Prince Edward County experiences one of Nature s wonders, the spring and fall bird migrations. Although birds migrate across Canada taking different routes (flyways), those flying over the Great Lakes concentrate in unique geographic areas so as to lessen the flight distance over open water. Prince Edward County serves the same purpose for Lake Ontario as Point Pelee does on Lake Erie. Both provide staging and recovery areas on shore and in the surroundings waters for birds as large as ducks and geese and as small as nuthatches and warblers. In season, large numbers of birds may be found feeding and resting as they prepare for or recuperate from their journey. Industrial wind turbines and the associated infrastructure (power lines, access roads, construction, substations) would have extensive negative ecological impacts on Prince Edward County s flora, wildlife and migratory species, as well as their food sources, resting and breeding habitats and community corridors. 2.0 Legal Status of PEC South Shore The Natural Heritage Information Centre (NHIC) has identified several natural heritage areas within southern Prince Edward County (southward and eastward of Wellington). These include (Table 1): seven provincially significant wetlands (e.g. Salmon Point and Soup Harbour), a National Wildlife Area, five provincially significant Areas of Natural and Scientific Interest (ANSI s), two regionally significant ANSI s ( McMahon Bluff Escarpment and Black Creek Valley Marsh and Forest). In the County migrating birds congregate along the south shore between Points Petre and Prince Edward. Municipal, provincial and federal governments have recognized the importance of the location through special environmental designations and reserves. The PEC official plan zones the shoreline as Environmental Protection. The Province of Ontario established the Point Petre Provincial Wildlife Area, bounded by Hwy. 24 and Army Reserve and Duetta roads. The Government of Canada purchased the southeast tip of Long Point peninsula and set up the Prince Edward Point National Wildlife Area, managed by the Canadian Wildlife Service and protected under the regulations of the Canada Wildlife Act of It is a concentration point for migrating songbirds and birds of prey, as well as for diving waterfowl, loons, and grebes which gather in huge numbers off the coast. The National Wildlife Area is home to the Prince Edward Point Bird Observatory (PEPBO), a non-profit organization which operates a banding station that collects vital scientific data on bird population densities, longevity, and migratory routes. A member of the Canadian Migration Monitoring Network, the observatory operates with a licensed bird bander assisted by local volunteers and university students gaining field and research experience, some having come from Europe and South America. Each May, in cooperation with local naturalist clubs, PEPBO hosts a birding festival that attracts birdwatchers from across North America. Most significantly, the 1998 designation of Important Bird Area (IBA) applies to all the land south of Army Reserve, Hilltop, and Babylon Roads and all of Long Point; and the IBA extends into Lake Ontario 5 kilometers offshore from Soup Harbor round to South Bay (Figure 1). It comprises approximately 26 square kilometres of land (about 45 percent publicly owned) and 65 square kilometres of nearshore waters.

5 Page 5 Table 1. Significant natural areas in southern Prince Edward County, as identified by NHIC. 1

6 Page 6 IBA s are part of the Natural Legacy 2000 program, a nation-wide initiative to conserve wildlife and habitats on private and public lands. The Vision statement for the Prince Edward County South Shore IBA is as follows. To conserve, manage and enhance the values of Prince Edward County South Shore Important Bird Area for all migratory and resident birds, contribute to bird habitat conservation, science, stewardship and education, and maintain, and restore the wild and natural character of the area for the citizens of Prince Edward County and beyond. 2 According to the standards for IBA s, PEC South Shore has been designated as globally significant under the congregatory species category and nationally significant under the threatened species category. 3 The IBA species and landbird migrants are protected under the Migratory Bird Convention Act of 1917; the birds of prey and turkey vulture are protected in Ontario under the Fish and Wildlife Conservation Act of Ontario, and bald eagle and peregrine falcon are also protected under the Endangered Species Act of Ontario. Figure 1. Boundaries of Prince Edward Important Bird Area. 4

7 3.0 Species and Ecosystems affected by Wind Turbines Page 7 The several proposed turbine sites include areas of: 1. species-at-risk 2. threatened species 3. rare plant species 4. rare and protected insects 5. rare reptiles 6. globally rare alvar habitat several marine archeology sites 3.1 Number and Variety of Birds in PEC South Shore. The total number and variety of birds inhabiting or migrating through the IBA can only be estimated, but the data available is impressive: In January 1996 and 1997, one-day peak numbers of Long-tailed Ducks totalled about 37,700, almost 2 percent of the global population (Canadian IBA Database 1998). On 17 April 2000, there were an estimated 150,000 Long-tailed Ducks in the waters of this IBA, 7.5 percent of the global population (Bain and Shanahan 2000). About 5,000 White-winged Scoters occur regularly in winter with recent one-day peak numbers of 12,800 in 1995 and 15,000 in 1996 (Canadian IBA Database 1998). This latter number represents 1.5 percent of the global population. The Greater Scaup overwinters regularly in numbers estimated at 10,000, 1.4 percent of the global population; however, a one-day peak of 39,000 in January 1995 represents more than 5 percent of this population (ibid.). Other waterfowl regularly occurring during winter in large numbers include Common Goldeneye, Common Merganser, and Red-breasted Merganser. As well, Common Loon and Horned Grebe occur regularly in large numbers in the waters of this IBA during winter. During the fall, large numbers of raptors move along the mainland shoreline of Lake Ontario. Winds from the west or northwest push these raptors into Prince Edward County, southward into the IBA, and eastward to Prince Edward Point (Sprague 1987). The western end of the IBA, Point Petre, is also a concentration point as some raptor species and Turkey Vultures hesitate and shift flight directions to avoid the open waters of Lake Ontario. As many as 2,000 hawks per day have been regularly recorded in the skies over Prince Edward County South Shore IBA, including large numbers of Sharp-shinned Hawks, Red-shouldered Hawks, and Red-tailed Hawks (Canadian IBA Database 1998). A total of 17 species of raptors have been observed, including Bald Eagle and Peregrine Falcon. Vagrants include Swainson s Hawk and Ferruginous Hawk. Daily maximum estimates for selected species during fall migration are described in Sprague and Weir (1984) and the Canadian IBA Database (1998): Red-tailed Hawk, 1,000; Broad-winged Hawk, 1,000; Turkey Vulture, 350; Sharp-shinned Hawk, 510; Red-shouldered Hawk, 100. Prince Edward Point National Wildlife Area is unequalled in North America for the numbers of Northern Saw-whet Owl migrating during fall (Levesque 1985). Between , for example, 2700 Northern Saw-whet Owl were banded (Harris 2000). A total of 162 species (excluding raptors) have been recorded, including 36 species of warblers, 20 species of sparrows and 12 species of flycatchers (Canadian IBA Database 1998). Hooded Warbler, a Threatened species in Canada, and Yellow-breasted Chat, a warbler of Special Concern

8 Page 8 nationally and Vulnerable provincially, are observed annually on migration. Daily censuses conducted during the migration period have recorded peak numbers of 200 to 500 individuals of common migrants in Ontario including Tree Swallow, Blue Jay, Black-capped Chickadee, Golden-crowned Kinglet, Ruby-crowned Kinglet, Yellow-rumped Warbler, White-throated Sparrow and Dark-eyed Junco. Migration events, here as elsewhere, are often weather dependent. When conditions cause particularly large fallouts of migrants, numbers in excess of 2,000 birds can occur. Numbers of Tree Swallow, Yellow-rumped Warbler and White-throated Sparrow may be as high as 10,000; 70,000 Dark-eyed Juncos have been recorded (ibid.). 5 These are phenomenal numbers for a relatively small area, 30 kilometers of shoreline separating the two points. Indeed, a well-known local naturalist, Terry Sprague, sums up PEC South Shore s importance: With 336 species of birds recorded in Prince Edward County and 92 percent of those observed within the IBA, this site has the highest concentration and abundance of any site on the Canadian side of Lake Ontario (Sprague 2000a) Bird Species at Risk. In 2002 NHIC, along with the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) and the Committee on the Status of Species-at-Risk in Ontario (COSSARO), identified nineteen species-at-risk in southern Prince Edward County. PEC South Shore also offers potential for their recovery. Table 2. Bird Species identified by the NHIC as species-at-risk 7

9 Page Bat Species at Risk. Bats play a crucial role in the ecosystem. They eat their body weight in insects daily: insects that threaten crops and those that spread disease, such as mosquitoes. Bats are not endangered, but they reproduce very slowly. Bats identified so far in Prince Edward County are Little Brown Bats, Big Brown Bats and Red Bats. High bat fatality rates at wind turbine sites have been documented worldwide. One turbine facility in Alberta alone kills close to 500 bats per year (Lapka 2005). 8 Understanding the reason for collision mortality at turbines is far less understood for bats than birds since bats, unlike birds, have no broad-based legal protection. However, the potential for devastating cumulative impacts is clear (Bat Conservation International 2004). Take the most conservative estimates of mortality and multiply them out by the number of turbines planned and you get very large, probably unsustainable kill rates. (Tuttle 2005). Over 90 percent of bat mortalities currently recorded at wind energy developments involve migratory species, especially during the fall (Johnson et al). 9 Also, more bats seem to die before and after storms and on warmer nights when wind speeds are lower (Blum 2005) Other Species at Risk. The southern shoreline from Pt. Petre to Prince Edward Pt. within the IBA is a vast plain of limestone bedrock (Ross 1999). The limestone plateau is covered with a shallow layer of loam topsoil or exposed bedrock creating globally RARE alvar-like conditions (ibid.). These surfaces have distinctive flowering plants, mosses, lichens and animal life as well as their own suite of birds (Reid 1996). RARE plants such as Ontario Aster, Downy Woodmint and Clammyweed, requiring largely undisturbed sites, thrive within the IBA (Sprague, pers. comm). Southern Prince Edward County is on the migration route of certain groups of migratory insects. The most significant butterfly of the area is the Juniper Hairstreak, a VERY RARE species in Ontario. In 1995 Prince Edward Point was declared an International Monarch Butterfly Reserve because of the large numbers of PROVINCIALLY PROTECTED Monarchs migrating through the area. Rare reptiles and amphibians are found within the IBA, including the Blandings Turtle, which is considered RARE in Ontario. The forest habitat of the Point Petre area is known to host two species of RARE terrestrial snail: Vallonia parvula and Triodopsis tridentate. Besides bats, many other mammals have been observed within the IBA (Table 3).

10 Table 3. Mammals recorded in Prince Edward County 11 Page Environmental Assessment of Avian Risks Mortality has generally been the main focus of avian research at wind turbine installations, but just as important is the disturbance these machines cause to birds, bats and other wildlife breeding, staging or over-wintering in the area. This disturbance could be in the form of habitat loss (as a result of tower and road construction), obstruction of regular flight paths, or human activity around breeding sites. Although waterfowl and shorebirds may show avoidance behavior to turbines, significant numbers have been known to collide with associated power lines causing fatal injuries due to both electrocution and collision. Raptors are especially affected. In 2007 Bird Studies Canada (BSC) updated a 2005 review, prepared for Environment Canada and the Canadian Wildlife Service, of worldwide research on wind turbines and bird populations. The report outlines the complexity of predicting the effects of wind farms because of differences in turbine design and layout and in local topography and flight patterns. Many studies record low numbers of collision fatalities except for raptors in California, where contributing factors may be unusually high raptor densities, topography, and possibly older turbine technology. In North America, songbirds are most at risk from factors such as topography, turbine lighting, turbine height, the presence of guy wires, weather, and numbers of birds moving through an area on migration. BSC stresses: Appropriate site selection appears to be the key factor in preventing negative impacts on birds. 12 BSC s report acknowledges: critics contend that mortality has been underestimated due to the inherent difficulties in locating carcasses, especially those of small birds, in the vicinity of turbines. In addition, even a relatively small number of deaths per turbine can have significant population impacts if the number of turbines at a wind energy installation is large. 13 Moreover, as The number of wind energy facilities, and the overall number of turbines, is expected to rise sharply in the next few years,... the potential for cumulative effects on birds increases. 14

11 Among the areas for further research, BSC asks these questions relevant to County wind farms: Page What is the height threshold of towers or turbines that cause mass collision events? How does this threshold relate to other factors such as lighting, weather and siting? 2. Are there specific, identifiable migration pathways in Canada that should be avoided when siting wind energy installations? 15 The greatest adverse effect that wind energy facilities may have on birds is disturbance to breeding and wintering birds, although this has received little attention. Disturbance is an especially important concern in offshore areas that are important feeding areas or movement corridors. 5.0 Causes of Adverse Effects by Wind Turbines BSC s report indicates the difficulty of precisely determining effects because of differences in the design, construction, size and siting of wind turbine installations. 5.1 Number of Turbines. The effect of turbines must be related to their number within a site and cumulatively within an area, but in general, more turbines, more fatalities: The scale of the facility can impact the amount of bird mortality and disturbance. Simply put, under comparable conditions, a large facility has the potential to affect more birds than a small one.... more dead birds will be found at a site as the number of turbines (or number sampled) increases.... A small properly sited wind energy installation is not likely to kill a large number of birds. If one takes the estimated average number of birds killed per turbine per year in the United States, as reported by the National Wind Coordinating Committee (NWCC 2004), a ten-turbine facility may be expected to kill approximately 23 birds per year if the average is extrapolated.... Considered in isolation, it is unlikely that small numbers of fatalities per year at a wind energy installation each year would be considered significant, unless some of those fatalities were of species at risk. However, a larger facility with more than 100 turbines may kill many more birds, approaching or exceeding levels that could affect the broader population (especially when vulnerable species are impacted). The number and siting opportunities of existing and future wind energy installations in an area is a factor that will affect the overall risk to birds. It would, for example, be better to have one very large wind energy installation in one wellsited location instead of many small poorly-sited installations. As such, it is important to consider both the average effect of each turbine and the cumulative effect of the total number of turbines in the area. The total should include existing and proposed turbines associated with other projects within the same area. As the size of the facility increases, the potential for adverse effects other than fatalities also increases. Larger facilities may cause more bird habitat to be lost or disturbed, and foraging and breeding birds may more readily avoid the area Tower Dimensions and Turbine Design. According to BSC s study, the height of turbine towers is critical because objects less than 150m in height appear to pose less of a threat to nocturnal migrants (see Section 3.6), but taller objects can cause mass bird kills, as found at communication towers and skyscrapers. 17

12 Page Wires. However, BSC states it is well known that Even if the wiring required for wind turbines is minimal, an increase in the number of power lines will cause higher mortality.... Several groups of birds appear to be the most susceptible to collision with wires, most notably waterfowl, shorebirds and raptors.... Powerline strikes are the cause of up to 64% of collision fatalities for certain waterfowl species Since wind farms usually require construction of more power lines to relay electrical production, these may be a greater cause of bird mortality than the turbines. 5.4 Limited Effects: Construction Disturbance. BSC states that disturbance due to construction on land, though high, is temporary and therefore less significant than offshore construction, which may upset local birds and disturb prey fish populations when pilings are being drilled/driven and if hazardous materials such as oil are spilled Unknown Effects: Turbine Lighting, Blade Speed, and Facility Configuration. BSC reports that there is little information about lighting as a cause of collision fatalities. Blade speed, causing motion smear (the degradation of visibility of rapidly moving objects), is also an uncertain factor. Nor has any research examined how overall wind energy installation configuration may affect birds Meteorological Conditions and Physical Features of the Landscape. According to BSC, Even in poor weather conditions, however, it is worth noting that there have been very few multiple-bird kills reported at wind energy sites. Prince Edward County s landform, however, may have the most significance in determining risk because diurnal migrants tend to follow shorelines of lakes, rivers, ridges and other linear features. During the day, peninsulas and islands can host concentrations of nocturnal migrants that had been migrating over large bodies of water Limits of Knowledge As the BSC report make clear, many questions about the interaction of birds and wind turbines have yet to be answered in Canada and eastern North America with respect to flight patterns, weather conditions, turbine lighting and nocturnal migrants, and turbine height. For offshore installations, further uncertainties involve turbine layout and spacing, buffer distance from migration pathways, turbine size, and even collision rates. But this is the key question: Are there specific, identifiable migration pathways in Canada that should be avoided when siting wind energy installations? 22 It would be unfortunate if the answer reveals the misplacement of turbines in Prince Edward County. There are no comparable studies of avian mortality that have been done on wind turbine facilities in bird migration pathways, as they are generally not located in these areas. 7.0 Environmental Laws The installation of wind turbines in southern PEC may violate Canada s and Ontario s responsibilities under numerous international treaties and provincial laws. In 1992 Canada signed the United Nations Convention on Biological Diversity at the Rio Earth Summit, but it took until 2002 for Canada to pass Bill C-5, the Species-at-Risk-Act (SARA).Legally protecting biodiversity through the protection of Canada s species-at-risk and their critical habitat is Canada s obligation under this Act. This legislation prohibits the killing, harming, harassment or capturing of any species in Canada officially listed as threatened, endangered or extinct. The Accord for the Protection of Species-at-Risk implies the partnership of federal, provincial and territorial governments.

13 Page 13 The regulations of the international Migratory Birds Convention Act (1994) protect migratory birds, their eggs and nests. This is the most important legal protection of birds in Canada and the United States. Under this Act, the federal government can designate an area of importance to migratory birds as a Migratory Bird Refuge to limit hunting and physical disturbance. The Act calls for cooperative and responsible stewardship to ensure that cumulative incidental effects on migratory birds from all activities can be managed to avoid significant impacts and maintain sustainable populations. Ontario s Ministry of Natural Resources (MNR), in reviewing wind farm applications, also must take into account several pieces of legislation. Specifically, the Public Lands Act, which regulates the management, sale and disposition of Crown land, requires MNR to ensure that significant environmental concerns have been addressed before approving a disposition. The Fish and Wildlife Act includes specific provisions for the protection of nests and eggs of all bird species not covered by the Migratory Birds Convention Act. Under the Lakes and Rivers Improvements Act, wind developments in lakes and rivers must provide for the management, perpetuation and use of the fish, wildlife, and other natural resources dependent on the lake or river. Finally, the Endangered Species Act makes it illegal to willfully attempt to kill, injure, interfere with, or take any species of flora or fauna threatened with extinction under ESA regulations. 8.0 Environmental Assessment Standards In light of the knowledge gap and the irreversible results of misjudgment, Environment Canada is cautious in determining the risk of wind farms, but its 2007 environmental assessment guidelines place PEC s south shore in the HIGH and VERY HIGH Sensitivity classifications for risk (Table 4). Table 4. Site sensitivity 23 Potential Sensitivity Very high Determining factor The presence of a bird species listed as at risk by the SARA, COSEWIC or provincial/territorial threat ranking, or the presence of the residence(s) of individuals of that species if listed under the SARA, or of its critical habitat. To be of concern, either the bird or its residence or critical habitat must be considered to be potentially affected by the project. Site contains, or is adjacent to, a large or important bird colony, such as herons, gulls, terns and seabirds. Site contains significant staging or wintering area for waterfowl or shorebirds, or significant areas of bird concentrations. Site is in, or is adjacent to, an area recognised as nationally important for birds (e.g., by being located in or adjacent to a National Wildlife Area, Migratory Bird Sanctuary, Important Bird Area, National Park, Western Hemisphere Shorebird Reserve Network (WHSRN) site, or similar area specifically designated to protect birds).

14 Page 14 Site contains large concentrations of raptors. Site is on a known migration corridor. High Site contains one or more landform factors that concentrate birds (e.g., islands, shoreline, ridge, peninsula or other landform that may funnel bird movement) or significantly increase the relative height of the turbines. Site is located between habitats where large local bird movements occur, or is close to significant migration staging or wintering area for waterfowl or shorebirds. Site contains, or is adjacent to, a small colony of colonial birds, such as herons, gulls, terns, or seabirds. Site is subject to increased bird activity from the presence of a large heron, gull, tern or seabird colony located in the vicinity of the site. Site is subject to increased bird activity from the presence of an area recognised as nationally important for birds (e.g., a National Wildlife Area, Migratory Bird Sanctuary, Important Bird Area, National Park, or similar area protected provincially or territorially because of its importance to birds). Site contains species of high conservation concern (e.g., birds known to have aerial flight displays, PIF/CWS priority species, etc.). For projects of Very High Sensitivity, Environment Canada s guidelines are clear:... proponents whose projects fall into this category may be encouraged or even required to seek alternative locations if significant adverse effects on birds are anticipated. 24 In a report prepared for the Union of Nova Scotia Municipalities, consulting firm Jacques Whitford describes two proposed Texas wind farm projects, which violate the U.S. Fish and Wildlife Service s Interim Guidance for siting wind energy facilities by their siting in one of the most significant migratory bird corridors which connects Canada and the United States to Mexico and South America. 25 The projects have been disallowed. How, then, can any wind turbine installation meet environmental guidelines and pass an environmental assessment if it is located on or near Prince Edward County s south shore? 9.0 Conclusion Industrial wind turbine installations, as well as the associated power lines, access roads, construction, substations, are inappropriate for PEC s south shore because they conflict with a protected area for birds and they have the potential for high collision fatalities and habitat disturbance. They may also have a negative

15 Page 15 ecological impact on bats, protected butterflies, and flora. Environment Canada s Guidance Document for Environmental Assessment recognizes the incompatibility of wind turbines with designated natural areas. It is illogical to set aside nature preserves and establish environmental standards, and then to discount their significance. Wind farm development should not be determined simply by favorable wind conditions. It must be restricted or prohibited when other land usages have already been given priority and when environmental risks are either high or incalculable References 1 Jacques Whitford, Proposed Wind Turbine Site, Royal Road Site, Prince Edward County. Final Report for Vision Quest Windelectric Inc.. July 15, p Prince Edward County South Shore Important Bird Area Conservation Plan (PEC SS IBA CP) by William G. Wilson and Edward D. Cheskey. July p PEC SS IBA CP, p PEC SS IBA CP, p PEC SS IBA CP, pp PEC SS IBA CP, p Jacques Whitford, Proposed Wind Turbine Site, Royal Road Site, Prince Edward County, p Stephanie Lapka, Bat Mortality by Wind Turbine Collisions: A Literature Review of North American Research. University of Calgary, Johnson, G.D., Perlik, Erickson & Strickland Bat activity, composition and collision mortality at a large windplant in Minnesota. Wildlife Society Bulletin 32: Blum, J Researchers Alarmed by Bat Deaths from Wind Turbines. 11 Jacques Whitford, Proposed Wind Turbine Site, Royal Road Site, Prince Edward County, p Bird Studies Canada. Andrea Kingsley and Becky Whittam. Wind Turbines and Birds: A Background Review for Environmental Assessment. Draft report for Environment Canada/Canadian Wildlife Service. April 2, p Bird Studies Canada, p Bird Studies Canada, p Bird Studies Canada, p Bird Studies Canada, pp

16 Page Bird Studies Canada, p Bird Studies Canada, p Bird Studies Canada, p Bird Studies Canada, pp Bird Studies Canada, pp Bird Studies Canada, pp Environment Canada/ Canadian Wildlife Service. Wind Turbines and Birds: A Guidance Document for Environmental Assessment. FINAL. February pp Environment Canada/ Canadian Wildlife Service, pp Jacques Whitford. Model Wind Turbine By-laws and Best Practices for Nova Scotia Municipalities. Final Report for Union of Nova Scotia Municipalities. January 28, p. 13. <

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