on Registration Document of the Canso Spaceport Facility Project
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 johnfkearney.com. 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.
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.
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
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.
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.
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.
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
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
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.
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.
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)
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
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.
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.
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.
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.
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.
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
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.
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
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
my opinion, the environmental assessment of the Canso Spaceport should not be
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
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.
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