The project area report on…

The project area report on Birds and Bats, contains a critical flaw/omission. Specifically it takes no account of annual variation in migration patterns and species density. For example in the spring of this year (2018), a major cold front and low to the north, combined with a series of warmer fronts in the United States and Mexico, caused a significant pattern change. As a known rest and gather point on the Eastern North American migratory flyway, this weather pattern caused Arctic resident migratory birds, Northern resident migratory birds, and Local resident summer migratory birds, to be compressed into the project area. This presented unusually high densities of birds. Without a plan to allow for this sort of event risk to birds will be unusually high, in the vent of of a similar re-occurance. The report is deficient.