HomeMy WebLinkAboutWPO202200024 Correspondence 2023-01-12 (4)From: Wittig, Thomas W <thomas_wittig@fws.gov>
Sent: Monday, May 23, 2022 5:18 AM
To: Ian Susslin <isusslin@adapturerenewables.com>
Cc: Travis Schricker <tschricker@adapturerenewables.com>; Morgan Zinger
<mzinger@adapturerenewables.com>
Subject: Re: [EXTERNAL] Rivanna Solar Project- located Southeast of Charlottesville VA
Hello Ian,
Thank you for reaching out.
For eagles and Eagle Act compliance, I recommend using our bald eagle project screening
form: httos://www.fws.gov/northeast/ecologicalservices/pdf/eagle/NE_Bald-Eagle_Project-
Screening-Form rev20200416.12df. Depending on the project design, construction may fall into
both the Construction and Loud noises categories.
Regarding migratory birds, the U.S. Fish and Wildlife Service (Service) is the Federal agency
delegated with the primary responsibility for managing migratory birds. Our authority derives
from the Migratory Bird Treaty Act of 1918, as amended (MBTA; 16 U.S.C. 703 et seq.), which
implements treaties with Canada, Mexico, Japan, and the Russian Federation. Migratory bird in
50 CFR 10.12 means "any bird, whatever its origin and whether or not raised in captivity, which
belongs to a species listed in 50 CFR 10.13, or which is a mutation or a hybrid of any such
species, including any part, nest, or egg of any such bird, or any product, whether or not
manufactured, which consists, or is composed in whole or part, of any such bird or any part,
nest, or egg thereof." The list of protected birds is maintained in regulation at 50 CFR 10.13 and
includes over 1,000 species.
The Service interprets MBTA to prohibit incidental take of migratory birds and will enforce the
statute accordingly (see httpsi//www.fws.gov/policy/do225.pdf). Incidental take means the
taking or killing of migratory birds that results from, but is not the purpose of, an activity. The
Service recognizes that a wide range of activities may result in incidental take of migratory birds.
Pursuing enforcement for all these activities would not be an effective orjudicious use of our
law enforcement resources. For that reason, the Service will focus our enforcement efforts on
specific types of activities that both foreseeably cause incidental take and where the proponent
fails to implement known beneficial practices to avoid or minimize incidental take. Our intention
through this policy is to apply a transparent and consistent approach to managing and
prioritizing our enforcement of incidental take, taking into account the case law applicable in a
given jurisdiction and the facts and circumstances of each case.
1. The following types of conduct are not a priority for enforcement:
1. A member of the general public conducting otherwise legal activities that
incidentally take migratory birds;
2. A Federal agency conducting activities in accordance with a signed memorandum of
understanding with the Service developed under Executive Order 13186 for the
conservation of migratory birds; or
3. A public- or private -sector entity conducting activities in accordance with applicable
beneficial practices for avoiding and minimizing incidental take.
2. The Service prioritizes the following types of conduct for enforcement:
1. Incidental take that is the result of an otherwise illegal activity; or
2. Incidental take that:
1. results from activities by a public- or private -sector entity that are otherwise
legal;
2. is foreseeable; and
3. occurs where known general or activity -specific beneficial practices were not
implemented.
To better protect migratory bird populations and provide more certainty for the regulated
public, the Service seeks to address human -caused mortality by providing information on
beneficial practices to avoid and minimize the incidental injury and killing of migratory birds.
Beneficial practice means an action implemented to avoid or minimize the incidental take of
migratory birds. We also refer to beneficial practices as best management practices,
conservation measures, best practices, mitigation measures, etc.
We maintain a comprehensive website of beneficial practices, conservation measures, and
decisionsupporttools: httos://www.fws.gov/library/collections/avoiding-and-minimizing=
incidental -take -migratory -birds. We advise that you consult these resources and implement any
beneficial practices that are applicable to your proposed activities. You'll find that there is
guidance specific to solar, though there are only a limited number of recommendations, not all
of which may be applicable to your project.
If you have any further questions regarding BGEPA or MBTA compliance, please do not hesitate
to follow up.
Best,
Tom
Tom Wittig
Eagle Coordinator) North Atlantic -Appalachian Region
Division of Migratory Birds I U.S. Fish and Wildlife Service
300 Westgate Center Drive
Hadley, MA01035
Phone: 413-253-8577
Fax: 413-253-8424
From: Ian Susslin<isusslinCcDadanturerenewables.com>
Sent: Friday, May 20, 2022 5:17 PM
To: Wittig, Thomas W <thomas_wittig(@fws.gov>
Cc: Travis Schricker<tschricker(@adapturerenewables.com>; Morgan Zinger
<mzinger(@adapturerenewables.com>
Subject: [EXTERNAL] Rivanna Solar Project- located Southeast of Charlottesville VA
This email has been received from outside of DOI - Use caution before clicking on links,
opening attachments, or responding.
Thomas,
Good day.
I am reaching out to you about the Migratory Bird Treaty Act and the Bald & Golden Eagle Protection
Act.
Our company is in the process of permitting for a Utility -Scale Solar Project located just southeast of
Charlottesville, VA. Google Earth KMZ file is attached.
• Rlvanna.kmz
We received your contact info from the Army Corps Of Engineers as we just acquired a permit from
them. The letter connected to out permit states we should reach out to you. Please see below (the
letter is also attached)
"The USFWS has asked that we inform you of their authority under the Migratory Bird Treaty
Act (16 USC 703). You should contact Thomas Wittig concerning this matter at 413-253-8577
or Thomas wittig@fws.gov to determine if any restrictions apply to your project.
Please note that you should either obtain a U.S. Fish and Wildlife Service (FWS) bald eagle
take permit or a letter of concurrence from FWS indicating that a permit is not necessary prior
to initiating construction activities. You should contact Thomas Wittig concerning this matter
at 413-253-8577 or Thomas wittia@fws.gov."
I was wondering if you can help us determine if any restrictions that apply to our site under the
Migratory Bird Treaty Act, or if we will need a Bald Eagle Permit for the project?
Thank you for your time and we look forward to hearing from you,
Ian Susslin
Project Engineer
Adapture Renewables, Inc.
i s u ss l i n Ca)a d a ptu re re n ewa b l e s. c o m
Direct: 510.710.5666
1901 Harrison Street, Suite 1630, Oakland, CA 94612
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