The Mass Audubon Challenge
Recently, you may have read or heard about the Mass Audubon Challenge regarding the proposed Cape Wind project. In March of this year, following extensive staff and board review of the project, Mass Audubon challenged Cape Wind and its permitting agencies to accept comprehensive and rigorous monitoring and mitigation conditions that will reduce the risk to birds and other wildlife. If these conditions are adopted, and remaining significant data gaps are filled with a finding of no significant threat to living resources, Mass Audubon will support this Cape Wind project, the largest, clean, renewable-energy project in the Northeast.

Mass Audubon's Challenge comes from five years of project review, including three years of ornithological fieldwork; our assessment and comments on the federal draft environmental impact statement (DEIS) and literature review; talks with ornithologists, scientists, and engineers; and a visit to Denmark's offshore wind farms during the 2005 spring bird migration.

A revised DEIS is expected from the US Department of the Interior this spring, and with this challenge we hope to bring focus on several important issues that remain unaddressed.

Our technical review and assessment of the Cape Wind DEIS is focused primarily on the project's impacts on birds and their habitat. The basis for our position is that the project must pose no significant threat to living resources. This does not mean zero impact on those resources because the production of energy always entails some level of environmental impact.

While our primary expertise is birdlife, there are other important potential environmental impacts. Our position relies on the evaluation of our own scientists and the expertise of other organizations in assessing any potential threats from this project to the seafloor, fisheries, marine mammals, and other sea life.

More Research and Ongoing Monitoring
Mass Audubon identified data gaps in the first DEIS and has worked to fill many of them through our own research. Some significant gaps remain including the following:

• nighttime distribution and behavior of hundreds of thousands of long-tailed ducks in and around Horseshoe Shoal;
• movement of endangered terns and threatened plovers during the late summer to early fall migration; and
• abundance and distribution of migrating songbirds.

The Mass Audubon Challenge requires that these gaps are addressed with a finding of "no significant threat." Additionally the Challenge includes:

• adoption of an Adaptive Management Plan, which includes a rigorous three-year monitoring program beginning at the construction phase;
• mitigation measures in the event that the project results in significant adverse environmental impacts;
• compensation for the use of public lands and waters;
• enforceable procedures for decommissioning any abandoned turbines;
• a comprehensive postconstruction monitoring program modeled on programs for similar offshore wind farms in Denmark;
• creation of an independent panel responsible for collecting and analyzing data collected during monitoring and preparing reports for peer review and dissemination to relevant agencies, Cape Wind, and the public; and
• establishment of a mitigation fund administered by an independent third party, for conservation of bird habitat around Nantucket Sound, which would be funded by Cape Wind with contributions from independent institutions and government agencies as appropriate.

Conservation—a driving principle
We review Cape Wind in the context of a planet experiencing rapid climate warming, oil spills, strip mining, air pollution, and the push for nuclear power as a clean energy source. We know that the combustion of fossil fuels releases greenhouse gases including carbon dioxide and methane that accumulate in the lower atmosphere and heat the earth. Combustion of fossil fuels also results in the release of mercury, which bioaccumulates in the environment, causing health problems for humans, especially pregnant women and children.

Rising sea levels caused by warming will flood low-lying barrier beaches and islands that we all enjoy and that serve as critical habitat for coastal birds, including the endangered roseate tern and threatened piping plover. In addition, our safety may be threatened by increasing storm intensity and storm surge related to sea-level rise and a warmer planet.

The consequences of climate warming compel us to increase energy conservation as a first priority. And, to continue to supply our energy needs, wind should be tapped as the most successful and readily available of all renewable energy technologies. The benefits and detriments of Cape Wind must be balanced against the significant threats to Nantucket Sound posed by fossil-fuel use and rapid climate change.

For 110 years, the support of members like you has enabled Mass Audubon to be engaged in important environmental issues, and we continue to take our role in developing solutions for the future very seriously. We hope you support our position and this important challenge.

Sincerely,

Laura A. Johnson
President