Wind-bat habitat conservation plans (up through 2022) and cost analysis

The wind industry’s expansion in North America due to the need to provide
clean energy is leading to increased regulatory concern for bats,
particularly those that are endangered due to white-nose syndrome. The
projected growth of installed wind capacity overlaps extensively with the
ranges of several endangered and potentially regulated bat species. Wind
energy operators in the US can comply with the Endangered Species Act
(ESA) by submitting a Habitat Conservation Plan (HCP) and Incidental Take
Permit (ITP) to the U.S. Fish and Wildlife Service. HCP documents include
wind project overviews, estimates for incidental take (e.g., unavoidable
fatalities), outline minimization and compensatory mitigation measures to
avoid take, and often include estimated cost information for actions to
implement the HCP/ITP. However, the lack of insight into specific
cost data, combined with the lengthy ITP application process, has
potentially led to the perception that ESA compliance imposes a
costly regulatory burden on the private sector, deterring motivation for
voluntary compliance. Resulting from the absence of routine
reporting practices, it is not known how much it costs for companies to
comply with ESA listings, nor is there a standardized database of
compliance costs or a method for estimating
them. This analysis of 25 publicly available
project-specific HCPs published through 2022 establishes one approach to
conceptualizing these costs and determined the median total cost for an
HCP to be approximately $4.68 million, with notable discrepancy between
the median costs for compensatory mitigation cost ($1.64 million) and
fatality monitoring ($3.15 million). This analysis also created a general
linear model that can be used to estimate potential project-specific
costs, and overall provides better insight into the costs of complying
with the ESA by identifying variables that might affect compliance costs,
and estimating future costs for the wind industry.