Based on our review of the Environmental Assessment (EA) related to the two proposed Wind Energy Areas (WEAs) in the Gulf of Mexico, insufficient data and analysis were provided to make sound scientific-based comments or decisions regarding the proposed sites. The current EA does not adequately address the potential impacts to trans-Gulf and circum-Gulf migrant birds that depend on safe passage through the region. Notable factors to be considered as part of the decision-making process regarding WEAs include the average altitude that birds fly over the proposed area, and how that may vary with weather condition. The influence of time of year on migratory bird flight patterns over these areas should also be assessed. Results of such analyses will better inform site selection and potential operational procedures that could be employed to limit impacts. With this in mind, we request a more detailed analysis of bird migration patterns addressing these factors be completed as well as assessments of alternative strategies that could be employed. Examples of design and operational adjustments that could be considered include changing the height of the turbines or turning the turbines off during peak migration periods in the spring and fall.
PDF of Our Full Letter to the Bureau of Ocean Energy Management