![\"\"](\"https:\/\/environment-hawaii.org\/wp-content\/uploads\/2019\/07\/Screenshot-2019-07-28-11.14.12.png\")
Committee member Michelle Bogardus, representing the FWS, said her agency supported the land purchase as mitigation for the take of 55 bats. However, member Kawika Winter, as well as Mililani Browning of Kamehameha Schools, questioned the approach. They noted that some of the lands purchased were already protected by their Conservation District status and that DOFAW would be the agency managing the lands for bats, not Kawailoa. <\/p>\n\n\n\n
Spain expressed concern that treating the Helemano acquisition and management as two separate mitigation measures seemed like double-counting. <\/p>\n\n\n\n
Fretz later added in written comments that the assumption that the Helemano acquisition would offset the take of any bats, let alone 55, was uncertain, as was the assumption that the proposed habitat improvements or protections proposed for Tiers 5 and 6 would produce 150 bats. <\/p>\n\n\n\n
\u201cThe conservation biology and recovery needs of HHB [Hawaiian hoary bats] are poorly known. The factors and threats that limit populations are not known, it is not known whether suitable habitat is a limiting factor, and there are no published studies or data on HHB that have demonstrated that restoration of habitat resulted in an increase in HHB populations,\u201d he wrote. <\/p>\n\n\n\n
He also complained that the plan did not require the use of deterrents, even though technologies were available that had \u201ca reasonable likelihood of success in reducing take and yielding essential information needed to improve the effectiveness of available methods.\u201d <\/p>\n\n\n\n
Fretz recommended a total take of less than 265 bats and that the proposed reversion trigger be deleted. <\/p>\n\n\n\n
In response to the ESRC\u2019s comments, Kawailoa submitted a revised draft plan in June, which reduced the proposed total take from 265 bats to 220, removed the reversion trigger, clarified its adaptive management strategy and added sections on the bat population, cumulative impacts, and monitoring. <\/p>\n\n\n\n
The company also installed acoustic deterrents on each of its 30 turbines. <\/p>\n\n\n\n
Brita Woeck, Kawailoa\u2019s environmental compliance manager, informed the committee at its July meeting that the facility is now the first in the nation to install acoustic deterrents commercially. Each turbine has been fitted with several speakers that emit a sound that interferes with the bats\u2019 ability to navigate. The sound extends only as far as the length of each blade, theoretically allowing bats to still forage below and above the hazardous zone. <\/p>\n\n\n\n
The installation was completed on June 7. Woeck reported that no bat fatalities had been discovered since then, but could not yet say how the bats were reacting to the deterrents. <\/p>\n\n\n\n
\u201cWe\u2019re really hopeful this is a trend we\u2019re going to start seeing,\u201d she said. <\/p>\n\n\n\n
Kawailoa expects the deterrents to reduce bat fatalities by 25 percent, hence the reduction in the requested take. <\/p>\n\n\n\n
\u201cWe want to be realistic. We don\u2019t want to come with a fake number. We feel this is the most realistic number,\u201d she said. <\/p>\n\n\n\n The final plan did not identify specific mitigation projects for Tiers 5 and 6, but did propose riparian restoration in parcels managed by the Ko\u2018olau Mountain Watershed Partnership. <\/p>\n\n\n\n \u201cTo mitigate for 85 bats in Tier 5, Kawailoa Wind would target a 1,725-acre area to fund management activities, a 406- acre area would be targeted for Tier 6,\u201d the plan stated. Those numbers are based on using a minimum of 20.3 acres to offset one Hawaiian hoary bat. The 20.3 acres reflects the median core use area of about two dozen bats on Hawai\u2018i island tagged in a 2015 foraging and range study by U.S. Geological Survey bat expert Frank Bonaccorso. <\/p>\n\n\n\n Woeck acknowledged that Kawailoa needs to start implementing a new mitigation measure soon because it has already reached its trigger for Tier 5. <\/p>\n\n\n\n While all of the commission members seemed to acknowledge the fact that no one knows how many acres of enhanced or protected habitat it takes to produce a bat \u2014 or even if mitigation should be tied to a particular acreage \u2014 some of them expressed concerns over Kawailoa\u2019s use of 20.3 acres\/bat rather than the 40 acres\/bat recommended in the committee\u2019s 2015 bat guidance document, which was based on the same Bonaccorso data. (The 40 acre number was arrived at by simply rounding down and doubling the 20.3-acre median core use area.) <\/p>\n\n\n\n The guidance document actually points out that Bonaccorso himself \u201cnoted that the mean core use area was approximately 65 acres and suggested that agencies should use this value\u201d \u2014 rather than the median \u2014 \u201cas the acreage for bat mitigation.\u201d <\/p>\n\n\n\n A recent study by a team of researchers with H.T. Harvey & Associates of about a dozen Maui bats suggests that the guidance document is in dire need of revision. The team found that the bats\u2019 core use area \u2014 where it spends 50 percent of its time (also known as the 50% kernel) \u2014 could be as small as seven acres to as many as 16,000. The average 50% kernel size was nearly 3,000 acres, they found. <\/p>\n\n\n\n At the Hawai\u2018i Conservation Conference in July, principal investigator Dave Johnston stressed in his presentation on this research that the species should be managed on an island-by-island basis, since the animals are doing different things on different islands. <\/p>\n\n\n\n In light of the Maui study, some committee members were particularly concerned about Kawailoa\u2019s decision to stick with 20.3 acres per bat for mitigation. <\/p>\n\n\n\n \u201cJust like the last time we met, I still disagree with that,\u201d committee member Loyal Mehrhoff said. He said he wasn\u2019t so concerned with that rate being applied to the Tier 4 mitigation, since the Helemano lands would more than accommodate mitigation for 55 bats at 40 acres per bat. He worried about Tiers 5 and 6, however. <\/p>\n\n\n\n Woeck called the 40 acres\/bat standard arbitrary and said there was no scientific justification for it. She also explained that habitat restoration benefits will extend beyond the acres managed. <\/p>\n\n\n\n In rebuttal, committee member and USGS biologist Jim Jacobi pointed out that with regard to using the median core use area identified in Bonaccorso\u2019s study, the USGS has \u201ccommented several times that is not the appropriate use of that information for calculating that.\u201d <\/p>\n\n\n\n Jacobi then questioned whether a lack of forest cover was actually a limiting factor for bats. \u201cBy having more forest, does it give you more bats?\u201d he asked. Bats have been tracked foraging over pasture lands and along gulches and roads. <\/p>\n\n\n\n Woeck said habitat complexity and improving foraging habitat is more important. <\/p>\n\n\n\n The existing information on core use area is challenging given the wide variation among individual bats, Bogardus said. \u201cIt\u2019s not an easy data set to make big broad assumptions about habitat. My read is acreage is not the thing we should necessarily use to determine the adequacy of mitigation. \u2026 I don\u2019t have a quick and easy metric of what that looks like, which is challenging for all of us. I can\u2019t say 40 acres equals a bat or 20 acres equals a bat \u2026 or 100,\u201d she said. <\/p>\n\n\n\n Her agency, at least, has determined that 20 acres is the baseline. From there, facilities have to justify how the mitigation package as a whole will be successful, she said. <\/p>\n\n\n\n Later in the meeting, Mehrhoff made a final pitch against the 20.3-acre standard. <\/p>\n\n\n\n \u201cOne of the leading bat biologists says you should be looking at 60 acres-plus. I don\u2019t see anything that leads me to cut that expert\u2019s opinion down to 20 acres,\u201d he said. <\/p>\n\n\n\n In addition to disagreeing with the method being used to determine suitable mitigation areas, Mehrhoff, at least, thought Kawailoa\u2019s estimate that there were at least 2,000 bats on O\u2018ahu \u2014 and could, therefore, support the cumulative level of take by wind farms on the island \u2014 was way off base. <\/p>\n\n\n\n Kawailoa\u2019s HCP suggests that even if all of the wind farms on O\u2018ahu killed a total of 15 bats\/year, that would impact less than one percent of the population. Using two separate approaches, the plan estimates that O\u2018ahu may support between 2,000 and 9,200 bats and that the population is stable to slightly increasing. <\/p>\n\n\n\n Method 1: The plan assumed that 30 percent of the island \u2014 115,000 acres \u2014 is occupied by bats. Based on Bonaccorso\u2019s core use area data from Hawai\u2018i island, the plan estimated bat density. \u201cO\u2018ahu could conservatively support 2,000 (115,000 acres\/58 acres) to 7,200 (115,000 acres\/16 acres) individuals,\u201d the plan states. <\/p>\n\n\n\n Method 2: Studies show that bats occupy more than 50 percent of the is- land. Excluding developed lands to be conservative, Kawailoa determined that bats occupied 147,500 acres (half of all undeveloped lands). Applying the same range of densities, the company came up with a minimum population ranging from 2,500 bats (147,500 acres\/58 acres) to 9,200 bats (147,500 acres\/16 acres) on O\u2018ahu, the plan states. <\/p>\n\n\n\n The plan also states that bats have a high reproductive capacity (twinning is common), that more than 90 percent of females are expected to breed in any given year, and that they have high juvenile survivorship. <\/p>\n\n\n\n Even so, Mehrhoff said at the July meeting, \u201cI don\u2019t think there\u2019s 2,000 bats on the island, personally, when I look at the data. \u2026 I don\u2019t think you\u2019ve got much more than 1,000.\u201d Mehrhoff is a former field supervisor of the FWS\u2019s Pacific Islands Office. <\/p>\n\n\n\n Noting that acoustic data shows there has been no decline in bat activity, Woeck said there is no indication the island\u2019s population is declining. <\/p>\n\n\n\n To which Jacobi pointed out that bat detectors are now more sensitive than they used to be, hinting that the level of bat activity may actually have decreased even as detections remain steady. He also asked what Kawailoa\u2019s estimate was of the probability that the population is not declining. <\/p>\n\n\n\n Woeck said a study will determine that. <\/p>\n\n\n\n Given that there\u2019s no evidence the population is stable or declining, to say definitively that it\u2019s not declining is \u201ca very strong statement,\u201d Jacobi said. <\/p>\n\n\n\n \u201cThis is our best attempt to respond to your request,\u201d Woeck said. <\/p>\n\n\n\n In any case, mitigation is intended to increase carrying capacity on the island, she said. <\/p>\n\n\n\n Under state law, HCPs must be designed to result in \u201can overall net gain in the recovery of Hawai\u2019i\u2019s threatened and endangered species.\u201d Committee member Winter complained that there are so many unknowns in the proposed Tier 5 mitigation that it was impossible to determine whether it would provide a cumulative net benefit. <\/p>\n\n\n\n To this, Woeck replied that the law does not require Kawailoa to produce a specific number of bats, but merely requires the plan to result in a net environmental benefit. \u201cThe fact that we\u2019re a renewable energy project needs to be taken into account. \u2026 It\u2019s not about creating one bat. We don\u2019t know how to do that,\u201d she said. <\/p>\n\n\n\n Deputy attorney general Linda Chow clarified that the law requires HCPs to provide a net environmental benefit, as well as an overall net gain of threatened and endangered species. <\/p>\n\n\n\n \u201cTo put it simply, endangered species should be better off with this in place,\u201d Winter said, adding that the committee should have some confidence that the plan actually does that before approving it. <\/p>\n\n\n\n Smith countered that the committee also needed to consider \u201cintangibles,\u201d such as the benefits renewable energy brings. <\/p>\n\n\n\n Mehrhoff agreed, but questioned how that is supposed to be done. \u201cThis is uncertainty central,\u201d he said. <\/p>\n\n\n\n Regarding net benefits, he said he believed Kawailoa\u2019s estimates of adult mortality were low, and in his analyses, the island\u2019s bat population could not support a take of 220-300 individuals by the various wind farms (total authorized take for the farms on the island would be 307, if the Kawailoa plan is approved). If the population is stable, the population will decline without compensatory measures with that level of take, he said. Even if the population is slightly increasing at a rate of one percent per year, the level of take can only increase if compensatory actions work, and \u201cwe have no indication of that,\u201d he said. <\/p>\n\n\n\n Take needs to be down in the realm of 10 bats a year, Mehrhoff said. The average total take of O\u2018ahu wind farms is anticipated to be 15 per year. \u201cThat\u2019s why I\u2019m uncomfortable with Tiers 5 and 6,\u201d he added. <\/p>\n\n\n\n Smith, however, sided with Kawailoa. \u201cWe\u2019re actually implementing more deterrents. Our expectation is our take rate is going to go down. \u2026 We don\u2019t have evidence the population is declining,\u201d he said. <\/p>\n\n\n\n Mehrhoff replied that there\u2019s a big difference between saying there\u2019s no evidence of decline and saying the project is okay. <\/p>\n\n\n\n An exasperated Woeck asked the committee how they could find some middle ground. \u201cWe\u2019re looking at the same information. \u2026 How do we get to acknowledging the uncertainty \u2026 No one is right and no one is wrong?\u201d she asked. <\/p>\n\n\n\n \u201cThat\u2019s what everyone is going to have to decide,\u201d Mehrhoff replied. <\/p>\n\n\n\n Jacobi added that more wind farms have been proposed for the island, which \u201cbrings another challenge in terms of how to proceed.\u201d <\/p>\n\n\n\n After even more discussion on bats as well as seabirds (see sidebar<\/a>), Smith asked the committee if it wanted to entertain a motion. <\/p>\n\n\n\n The committee responded with a long silence. Smith then called for a short break. In the minutes before the committee reconvened, Tetra Tech, Kawailoa\u2019s consultant, and Kawailoa staff conferred on possible changes they could make to help close the deal. <\/p>\n\n\n\n When the meeting resumed, Woeck said Kawailoa was willing to 1) commit to a specific management action for Tier 5, 2) clarify language in the plan\u2019s section on petrels to reflect the opinions of bird experts who believe the birds \u2014 perhaps genetically distinct from those on Kaua\u2018i \u2014 are breeding somewhere on the island, and 3) prepare a brief addendum to Tier 5 that specifies success criteria. <\/p>\n\n\n\n After Winter got some clarification on how Kawailoa arrived at its bat population estimate, Smith asked again for a motion and was again met with silence. The committee members sat looking at each other for a while. After several beats, Spain moved to approve the plan with the three amendments Woeck proposed. Bogardus seconded the motion. <\/p>\n\n\n\n Mehrhoff let it be known he wouldn\u2019t be voting in favor. \u201cThe take is too high,\u201d he said. <\/p>\n\n\n\n \u201cI\u2019m also uncomfortable with the take level in the higher tiers,\u201d Jacobi added. <\/p>\n\n\n\n While he said he thought Kawailoa\u2019s proposed changes were reasonable, he still didn\u2019t buy the plan\u2019s population estimate. \u201cThere are no foundations for those [numbers]. A number of acres gives you a bat? Doesn\u2019t make any sense to me,\u201d he said. <\/p>\n\n\n\n Even so, he voted with Bogardus and Smith in support of the motion, so long as it was understood that there would be a clear effort to involve the committee in adaptive management planning and actions. <\/p>\n\n\n\n Spain did not join them, at first. <\/p>\n\n\n\n \u201cI\u2019m stewing,\u201d she said before finally voting to support her motion. <\/p>\n\n\n\n Mehrhoff voted against the motion; member Winter abstained. <\/p>\n\n\n\n Afterward, Spain explained her reticence. \u201cI think all of us are extremely challenged by the number of bats [to be taken]. \u2026 We\u2019re very much hopeful the deterrents will be successful,\u201d she said. <\/p>\n\n\n\n She then urged the committee to update its bat guidance document. \u201cIt says 40 acres and we\u2019re being drawn into 20 acres. We need something feasible for us to be pointing back to,\u201d she said. <\/p>\n\n\n\n Bogardus then thanked Kawailoa\u2019s representatives at the meeting for being responsive to the committee\u2019s concerns. <\/p>\n\n\n\n The plan now goes to the Board of Land and Natural Resources, which will ultimately decide to approve it or not. <\/p>\n\n\n\n \u2014 Teresa Dawson<\/p>\n","protected":false},"excerpt":{"rendered":" “We’re not happy,” Lisa Spain told the room after casting the deciding vote to approve an amended Habitat Conservation Plan (HCP) that would allow the state’s largest wind farm to kill 160 more endangered bats than the 60 it was … Continued<\/a><\/p>\n","protected":false},"author":1,"featured_media":11641,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[457],"tags":[3],"class_list":["post-11635","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-august-2019","tag-teresa-dawson"],"_links":{"self":[{"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=\/wp\/v2\/posts\/11635","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=%2Fwp%2Fv2%2Fcomments&post=11635"}],"version-history":[{"count":0,"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=\/wp\/v2\/posts\/11635\/revisions"}],"wp:featuredmedia":[{"embeddable":true,"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=\/wp\/v2\/media\/11641"}],"wp:attachment":[{"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=%2Fwp%2Fv2%2Fmedia&parent=11635"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=%2Fwp%2Fv2%2Fcategories&post=11635"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/environment-hawaii.org\/index.php?rest_route=%2Fwp%2Fv2%2Ftags&post=11635"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}![\"\"](\"https:\/\/environment-hawaii.org\/wp-content\/uploads\/2019\/07\/Screenshot-2019-07-28-11.15.23.png\")
20 vs. 40<\/h4>\n\n\n\n
Net Benefit<\/h4>\n\n\n\n
Anyone?<\/h4>\n\n\n\n