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Comments Submitted to Enviromental Assessment Review of the Canso Spaceport
10:09am - 08/04/2018

Comments on Registration Document of the Canso Spaceport Facility Project

By John Kearney


These comments address the avifauna component of the registration document (Section 5.6). As an avian consultant who did three years of field work in the same location as the proposed Spaceport, I have an in-depth knowledge of the birds in the area. These three years of field research (2013 and 2015-2016) were part of the pre- and post-construction studies for the Sable Wind project which is immediately adjacent to the proposed Spaceport. This research is publicly available on my website at If requested, the raw data could also be provided to Strum Consulting which conducted the avian studies for the proposed Spaceport.

The studies I conducted in the project area were not only of longer duration but more intense on an annual basis than those conducted for this registration document. They included 2 years of breeding bird surveys, 2 years of stop-over transects, 2 years of diurnal passage surveys, 2 years of mortality studies, 3 years of nocturnal acoustic monitoring, and 1 year of morning acoustic monitoring. These studies provide a more comprehensive avian baseline for the Canso Spaceport than in the 2017 study conducted by Strum Consulting and fills many gaps that were left by their more abbreviated studies.

My comments will follow the sub-sections of the avifauna section in the registration document.

Section 5.6 Introduction

An introduction and overview of the significant avian species and habitats of the project area should include a discussion of the importance of fog in affecting the behaviour of birds. The Climate and Weather portion of the registration document (Section 5.1.1) provides no information on fog conditions. The project area has frequent fog events, and the combination of fog with other factors greatly increases the risk to birds from the Spaceport. The registration document should be modified to include fog data and an analysis of the risk factors posed by fog.

The report states that the project site is within survey square #20PR52 of the Maritimes Breeding Bird Atlas. In fact, much of the project site is within the survey square #20PR51. This section needs to be updated to account for this omission.

Section 5.6.1 Passerine Surveys

Passerine surveys in the Strum study during the spring and fall migrations were very sparse. They were conducted on three days in the spring and two days in the fall. In my Sable Wind studies, migration surveys were conducted at least twice a week for approximately 8 weeks in both the spring and fall. Transects or a combination of transects and point counts are a more appropriate survey technique for migration studies than point counts alone as was the case in the Strum study. It is also important, especially in an area of high migratory traffic such as Canso, to conduct stationary diurnal passage surveys from an elevated position.

Since the number of birds and species composition during the migratory periods often changes from one day to the next, a study of migration employing only 2-3 days of field observations is very incomplete and unreliable as a baseline database. The consultants did try to compensate for this deficiency in at least one migration season by employing acoustic technology, but their methods of deployment and analysis undermined this attempt (see Section 5.6.3 below).

The Strum breeding surveys compare well with the breeding surveys I conducted. At the time of my surveys there was a small Common Tern colony in Spinney Gully that is not noted in the registration document. In mentioning Spinney Gully, I should also note that there was a large Gray Seal herd that spent the summer and early fall in Spinney Gully and Sherewink Cove during my study years. Seals are not mentioned anywhere in the registration document.

Section 5.6.2 Shorebird Surveys

The comments in the passerine survey section also apply to the shorebird surveys. With only two surveys in the fall, the consultants missed the importance of the large numbers of Greater Yellowlegs, Semipalmated Plovers, and Whimbrels that migrate through the project area.

Section 5.6.3 Avian Acoustic Study

The purpose of the acoustic study, as noted by the authors, is to collect daily data about the birds in the study area. However, the consultants, instead of analyzing the daily data, only analyzed one ten-minute period at civil sunrise for 3 days per week. To make matters worse, they used no backup equipment, and when one unit failed for two weeks, they also decided to not analyze the data for a second location during the same two-week period. Unfortunately, this gap occurred during what is normally one of the busiest times of fall migration.

The chart below from my studies shows the total number of birds recorded in 4 10-minute acoustic  point counts at two locations in 2016. Peak counts occurred in only 4 to 7 out of 61 days at the two locations. This shows how it is easy to miss the true magnitude of migration without daily analysis.

There was no study of nocturnal migration in the Strum study. It is the high density nocturnal migratory traffic that poses one of the greatest risks to birds from the Spaceport (to be further discussed below).

In addition, civil sunrise is the worst time in the morning to survey birds during the fall migration. The cool, even cold, temperatures on a fall morning suppress bird activity until the sun warms the air. The table below, based on my own data in the study area over an entire migration period, shows that bird activity at civil sunrise is significantly lower at the 95% confidence level compared to activity at 1, 2, and 3 hours after civil sunrise.


Mean Estimated Birds












While acoustic analysis can be time-consuming, it can be manageable with a well-designed sampling plan and the use of detection software to “pull out” the bird sounds from long recordings. The use of appropriate software is also important for the identification of birds to the species level. It appears that many birds were unidentified in this study that could have been identified with the proper software and experience. For example, one of the most abundant migrants in the fall in the study area is the Blackpoll Warbler. Not one Blackpoll Warbler is identified in the registration document or its appendices. This species should have easily been detected in the acoustic study with the use of the proper software combined with the knowledge of the analyst. This lack of species identification has important implications for adequately assessing the species of conservation interest in the study area (to be discussed further below).

The original Sable Wind proposal would have had wind turbines on the coastal headlands, but they were eventually moved inland due to concerns about bird mortality. The launch site for the Canso Spaceport is proposed to be constructed on the headland 1.5 kilometers south of Glasgow Head. This high-risk area for birds was not acoustically surveyed during the preparation of the Canso Spaceport registration document and poses a highly significant concern for the reasons to be discussed further below.

5.6.4 Avian SOCI

The Sable Wind study identified a longer list of species of conservation interest that occurred in the study area between 2013 and 2015-2016. These additions are likely due to the more intensive field surveys, and more comprehensive analysis of the acoustic studies compared to the Spaceport study. The additional species are listed here:

American Golden-Plover: Primarily detected in nocturnal migration in all years with additional records on stop-over transects and morning flight

Wilson’s Snipe-One on spring transects in 2013

Black-billed Cuckoo-One on breeding point count in 2015

Yellow-bellied Flycatcher-One on breeding point count in 2013 and 2015. Two additional records on spring transects and autumn morning flight

Barn Swallow-One in morning flight in 2016

Tree Swallow-A few individuals seen in all years

Eastern Bluebird-A few recorded each year in nocturnal migration and 2 in morning flight in 2016

Gray Catbird-Three birds in morning flight in 2016

Tennessee Warbler-A few in nocturnal migration each year in the spring with somewhat larger numbers (up to 23 night flight calls in 2016) in the fall

Cape May Warbler-Recorded regularly in nocturnal migration and morning flight with peak count of 153 night flight calls in the fall of 2015

Bay-breasted Warbler-Recorded regularly in nocturnal migration and morning flight with peak count of 91 night flight calls in 2016.

Blackpoll Warbler-Recorded in large numbers in morning flight and nocturnal migration with lesser numbers on transects. The peak count was 2,334 night flight calls in 2015

Wilson’s Warbler-Recorded regularly in nocturnal migration and morning flight in small numbers

Canada Warbler-Recorded regularly both in the spring and fall in nocturnal migration and morning flight with peak count of 20 night flight calls in 2015

Vesper Sparrow-Two to four birds in nocturnal migration in 2013 and 2016

Rose-breasted Grosbeak-Recorded each year in nocturnal migration with peak of 22 night flight calls in 2015

Bobolink-Recorded each year in small numbers in nocturnal migration, with peak of 16 birds in morning flight in 2016

Rusty Blackbird-One on transects in spring of 2013 and 4 birds in morning fight in fall of 2016

Baltimore Oriole-1 in morning flight in 2016

It is also important to mention one other species of conservation interest that is not normally listed for Nova Scotia. This is the Newfoundland Gray-cheeked Thrush, a subspecies of the Gray-cheeked Thrush. This population has declined by 95% since 1975 (Whitaker et al. 2015) and is listed as “vulnerable” in the province of Newfoundland and Labrador. Gray-cheeked Thrush is a relatively rare bird in Nova Scotia during the fall migration but 47 night flight calls were recorded in the Sable Wind acoustic studies in 2013 with smaller numbers in 2015 and 2016. The spectrogram of the Gray-cheeked Thrush flight calls in the Canso area was often noticeably different from those of the western and more common population of the species. Thus, there is some evidence that the Canso area is an important first stop in the southbound migration of this subspecies from Newfoundland and Labrador.

5.6.5 Potential Interactions and Effects

Headlands in Nova Scotia are often concentration points for migrating birds (McLaren 2012). Glasgow Head at the easternmost point on the mainland of Nova Scotia is such a headland. My acoustic studies indicated that it is a point of departure in the spring and an arrival point in the autumn for birds migrating to and from Cape Breton Island and the island of Newfoundland. In the autumn it is also a concentration point for reorienting migrants that have been caught in crosswinds during the night. In morning flight one can see nocturnal migrants reorienting in a westward direction and birds in resumed migration heading to the southwest.

The nocturnal acoustic studies carried out in 2013 and 2015-2016 produced between 6,000 to 10,000 night flight calls during each of the three autumn seasons of monitoring at Glasgow Head. This roughly represents a minimum of 3,000 to 6,000 birds per autumn detected in the airspace up to a maximum of 150 meters. The microphone detects only a portion of the total birds flying over the headland at all altitudes and beyond the lateral boundaries of the microphone detection cone. Radar studies conducted at Glasgow Head (Lightfoot and Taylor 2013) indicated a strong correlation between acoustic and radar detections, especially below 150 meters altitude.

It has long been known that artificial lights attract night-migrating birds and alter their behaviour. A recent study quantified these behavioural responses through radar and acoustic sensors (Van Doren, et al. 2017). The study indicated that illumination resulted in aggregation in high densities, decreased flight speeds, circular flight paths, and frequent vocalization. Birds up to 4 kilometers above the ground were influenced by the light. The authors conclude that these behaviours may lead to significant energetic expenditures, increased predation, collision with human structures, and changes in stop-over ecology. If birds do not die from collision, predation, or exhaustion, their migratory flight may be delayed in order to rebuild their fat condition.

Dense fog can aggravate the effect of lights. Most large mortality events that I have witnessed at wind energy facilities in Nova Scotia have been a combination of fog and lights. Even a small light source, a single light bulb over the door at the base of a wind turbine tower on a foggy night caused dozens of mortalities.

The launch site of the proposed spaceport is located on the next peninsula from Glasgow Head, about 1.5 kilometers to the south southwest. Like Glasgow Head, it is currently a dark environment at night. The proposed launch site would bring lights to a coastal headland and near a large coastal island, Andrew Island. The study by Van Doren, et al. (2017) demonstrated that bird activity began to increase at distances 2 kilometers from a light and peaked within 500 meters.

These studies point to the potential of significant negative impacts on the survival and health of migratory birds at the proposed launch site due to the concentrating of birds circling lighted structures, leading to collision, exhaustion, increased predation, and loss of migratory fitness. This risk could be compounded by causing disorientation of the birds concentrated at Glasgow Head. Similarly, the lights of the Spaceport might result in disoriented birds flying through the six turbines at Sable Wind. One species that could be seriously affected by the presence of lights and structures at headlands is the Blackpoll Warbler, a species of conservation interest, that occurs in large numbers during the autumn migration at this location.

Another species that could be significantly affected by the Canso Spaceport is the Whimbrel. The rich berry crop on the barrens surrounding the proposed spaceport are an important source of food for Whimbrels (Numenius phaeopus hudsonicus) during their autumn migration. The barrens of eastern Cape Breton Island and eastern Nova Scotia are critical stopover habitat for Whimbrels building their body condition for a flight that many of them will take directly from Nova Scotia over the Atlantic to the Caribbean and South America (Morrison 1984).

(Whimbrel painting by Robert Verity Clem, published as a plate in the Shorebirds of North American (1967) by Peter Matthiessen, Gardner Stout, and Ralph S. Palmer)

The Atlantic Canada Conservation Data Centre (2017) lists the conservation status of the Whimbrel as S2S3M. This indicates that this migratory population in Nova Scotia has a status between “imperiled” and “vulnerable”. A recent paper (Pearce-Higgins et al. 2017) on the population status of the tribe Numeniini, of which the Whimbrel is a member, stresses how changes in stop-over habitat are the greatest threat to these species. The authors state: “Residential and commercial development, drilling, mining and quarrying, and the construction of transportation and service corridors were regarded as having widespread and severe impacts on populations, especially in coastal non-breeding areas where they can result in significant changes in land use.”

In 2013, an acoustic station was positioned on the shore of Spinney Gull, a body of water between Glasgow Head and the proposed launch site. Total Whimbrel calls from the two stations (Glasgow Head and Spinney Gully) in the autumn totaled 528, a number representing at least one hundred Whimbrels. During the day, Whimbrels were not seen feeding on the coastal mudflats which indicated that these nocturnal migrants were taking off from or landing in the stopover foraging areas in the barrens.

In 2016, acoustic point counts were carried out for 10-minute intervals every hour for 3 hours after civil sunrise. At Glasgow Head at least one Whimbrel was detected on 12 mornings between 2 September and 3 October for an estimate of 42 total birds. These birds were likely flying to stop-over habitat in the adjacent barrens. At a more inland monitoring station, Whimbrels were detected on 10 mornings between 28 August and 8 October for a total estimated number of 22 birds. These were likely foraging Whimbrels in the barrens immediately adjacent to the monitoring station.

The Whimbrels detected in the study area during the 4 daily, 10-minute acoustic samples are equal to 17.6% of all the Whimbrels in Nova Scotia reported to eBird during the same period in 2016 (eBird 2018). This statistic indicates the critical importance of the coastal barrens of this region as stop-over habitat for the Whimbrel.

The other shorebird that could be significantly impacted by the Spaceport is the Willet. According to the Atlantic Canada Conservation Data Centre (2017), the conservation status of the Willet in Nova Scotia is S2S3B; “imperiled” to “vulnerable” in the breeding season. The data from the breeding surveys in 2013 and 2015 showed that a small colony of Willets adjacent to the Sable Wind project was abandoned following construction. This case provides evidence that Willets are sensitive to and are displaced by construction activities and industrial noise, and thus there could be a permanent loss of breeding Willets closest to the Spaceport.

There is increasing evidence that industrial noise can affect the breeding behaviour and reproductive success of many bird species. One of the most recent papers demonstrated that birds exposed to excessive noise suffered from chronic stress and a decline in fitness (Kleist et al. 2018). These studies raise the question as to whether the peak noise from launches during the breeding season could have long-term effects on nesting birds and their nestlings.

Strum Consulting writes that it is “extremely unlikely” that birds would be exposed to unsymmetrical dimethylhydrazine (UDMH) since this rocket fuel isn’t released into the atmosphere until the launch vehicle is hundreds of kilometers away from Canso. However, the consultants do not consider the much greater possibility of an accidental spill of UDMH in transport to or within the Spaceport facilities. Similarly, a failed launch could result in the release of large amounts of UDMH locally. UDMH constitutes “a significant threat to both environmental and human health, the latter as a result of the carcinogenic, mutagenic, convulsant, teratogenic and embryotoxic characteristics of UDMH in addition to the general toxic characteristics of the compound”(Carlsen et al. 2007). It persists for long periods in soil and freshwater but its effects in the marine environment have not been studied (Byers and Byers 2017). However, the registration document contains no information on how UDMH will be transported, stored, and handled at the Spaceport and instead notes that these will be finalized later for approval by Transport Canada.

5.6.6 Specific Mitigative and Protective Measures

Strum Consulting proposed to eventually write a lighting plan that is “minimally intrusive to birds” and a lighting curtailment schedule during key migratory periods. These are sound proposals. However, a study of the abundance and patterns of behaviour of migratory birds at the launch site area as well as an analysis of annual fog conditions need to be completed in order to have sufficient data to create such a plan and schedule and to determine if they are capable of reducing the risk to birds.

Due to the critical nature of the Whimbrel and Willet habitat that will be lost as a result of constructing the Canso Spaceport, an equal amount of land, of equal value as Whimbrel and Willet habitat, should be permanently set aside in a nearby area as a shorebird sanctuary as compensation for this loss.

5.6.7 Potential Residual Effects

All residual effects as listed by Strum Consulting are categorized as none or minimal. Such an analysis is premature given the serious data gaps pointed out in these comments and the lack of information on the transport, handling, and storage of UDMH.

5.6.8 Recommended Monitoring and Follow-up

In my opinion, the environmental assessment of the Canso Spaceport should not be approved until:

1)       1) A radar, acoustic, and observational study of nocturnal and diurnal migration density and the behaviour of migratory birds at the location of the launch site of the Canso Spaceport is completed.

2)    2) A lighting management plan is developed that is based on the results of all radar, acoustic, and observational studies

3    3) The baseline avian data and final analysis includes all data sources and not just those reported in the registration document

4    4) Plans are put in place for the acquisition of lands for the creation of a shorebird sanctuary of the same quality and size of the habitat lost to the Canso Spaceport

5)    5) A draft plan for the transport, handling, and storage of dangerous substances is completed and public consultations held

6)    6) A plan for monitoring and post-construction studies is completed and subject to public consultation

The 7) The post-construction monitoring plan includes an avian mortality study at both the Canso Spaceport and Sable Wind. The latter is required since the validity of the previous 2-year mortality study conducted there, under dark conditions, can no longer be considered adequate due to the plans for the Canso Spaceport.

References Cited

Atlantic Canada Conservation Data Centre. 2018, Last updated on 30 July 2018. "Conservation Ranks." from


Byers, M. and C. Byers. 2017. "Toxic splash: Russian rocket stages dropped in Arctic waters raise health, environmental and legal concerns." Polar Record 1-12. doi:10.1017/S0032247417000547.


Carlsen, L., O. A. Kenesova and S. E. Batyrbekova. 2007. "A preliminary assessment of the potential environmental and human health impact of unsymmetrical dimethylhydrazine as a result of space activities." Chemosphere 6(6): 1108-1116.

eBird. 2018. "An Online Database of Bird Distribution and Abundance." from


Kleist, N. J., R. P. Guralnick, A. Cruza, C. A. Lowry and C. D. Francis. 2018. "Chronic anthropogenic noise disrupts glucocorticoid signaling and has multiple effects on fitness in an avian community." Proceedings of the National Academy of Science U S A 115(9): E2145.


Lightfoot, H. L. and P. D. Taylor. 2013. "Sable Wind - Fall Radar Study Report". Acadia University 25 p.


McLaren, I. A. 2012. All the Birds of Nova Scotia: Status and Critical Identification. Kentville, Nova Scotia, Gaspereau Press.


Morrison, R. I. G. 1984. Migration system of some New World shorebirds. Behavior of marine animals. Vol. 6. Shorebird: migration and foraging behavior. J. Burger and B. L. Olla. New York, Plenum Press: 125-202.


Pearce-Higgins, J. W., D. J. Brown, D. J. T. Douglas, J. A. Alves, M. Bellio, P. Bocher, G. M. Buchanan, R. P. Clay, J. Conklin, N. Crockford, P. Dann, J. Elts, C. Friis, R. A. Fuller, J. A. Gill, K. E. N. Gosbell, J. A. Johnson, R. Marquez-Ferrando, J. A. Masero, D. S. Melville, S. Millington, C. Minton, T. Mundkur, E. Nol, H. Pehlak, T. Piersma, F. Robin, D. I. Rogers, D. R. Ruthrauff, N. R. Senner, J. N. Shah, R. D. Sheldon, S. A. Soloviev, P. S. Tomkovich and Y. I. Verkuil. 2017. "A global threats overview for Numeniini populations: synthesising expert knowledge for a group of declining migratory birds." Bird Conservation International 27(01): 6-34.


Van Doren, B. M., K. G. Horton, A. M. Dokter, H. Klinck, S. B. Elbin and A. Farnsworth. 2017. "High-intensity urban light installation dramatically alters nocturnal bird migration." Proc Natl Acad Sci U S A 114(42): 11175-11180.


Whitaker, D. M., P. D. Taylor and I. G. Warkentin. 2015. "Gray-cheeked Thrush (Catharus minimus minimus) distribution and habitat use in a montane forest landscape of western Newfoundland, Canada." Avian Conservation and Ecology 10(2).




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