To the Editor:

This is a letter to Ken Kovalchik, Guilderland’s town planner:

Our citizen science group (The All Volunteer Ecology Study Team) has been visiting the proposed development sites 1, 2 and 3 regularly. We have gathered acoustic data on the variety of bat calls that are on these sites. Acoustic monitoring suggests the probable presence of five bat species: big brown bat, silver-haired bat, hoary bat, red bat, and a species of Myotis.

While our ongoing monitoring with Anabat recorders, yielding pictograms of the high-frequency calls the bats make, which allow their identification, found five species of bats, we couldn’t help but notice that the species inventory in the draft environmental impact statement submitted by Pyramid omitted all bats from their list of mammals onsite.

In Appendix G, pages 15 and 16, the list of mammals found on site 2 and 3 does not include Eptesicus fuscus (big brown bat), Lasiurus borealis (eastern red bat), Aeorestes cinereus (hoary bat), Lasionycteris noctivagans (silver-haired bat), nor any Myotis species (the “mouse-eared bat” genus.)

Yet, the DEIS does discuss one Myotis species it is certain is not there.

The DEIS states in Appendix G, page 21:

“Northern Long-eared bats are typically associated with cave habitats when hibernating in the winter and trees with crevasses and snags for roosting in the summer. Suitable potential summer roosting/maternity habitat is characterized by numerous trees (e.g. dead, dying, or alive) or snags, down to 3 inches diameter breast height (d.b.h.).

“The northern long-eared bat is currently presumed by USFWS [United States Fish and Wildlife Service] to have a biology and life history very similar to the Indiana bat (Myotis sodalis), with a difference being that the northern long-eared bat will also roost in old, loosely sealed, or abandoned structures.

“2.3.2 Potential On-site: The Site does not contain any cave habitats and is, therefore, not suitable habitat for winter hibernating northern long-eared bats. Vacant residential structures exist on site and a number PYRCRG15-01- veg/wildlife rpt – 09/2019 21 of large trees such as cottonwood and red maple, including some older, broken individuals have the potential to provide summer roosting habitat for this species.

“However, according to NYSDEC publications, this location is outside the 5-mile radius of the nearest recorded winter hibernaculum and is more than 7-miles away from known hibernacula. There are no confirmed summer occurrences of the NLEB in Albany County.”

It is difficult to understand why the DEIS is able to assess the absence of bats without noticing the presence of numerous bats on all three sites.

Bats in New York State face numerous challenges. The Myotis genus in particular has been decimated by the recent epizootic, White Nose Syndrome. They provide important ecosystem services and are under threat. An inventory of these sites is not complete if these species are ignored.

We also find it perplexing that no fireflies were found on sites 2 and 3 when our observations indicated there were numerous fireflies (Lampyridae species) at all the sites.

In Appendix F, we also find there are also no bat species listed under “Mammals” at Site 1 instead of the five species we found.

We observed these animals with machines that can capture their voices, close to the sites on the pavement where it is legal for us to stand. We could not access the interior of the sites, as Pyramid’s biologists are able to do, so that makes their omission of bat species even more mysterious.

Thank you for addressing these concerns. Clearly, if no bats were found on any of the three sites, and we observed Myotis calls on two of the sites, this raises serious questions about the completeness and the accuracy of the inventories in the DEIS.

The absence of fireflies in the lists for sites 2 and 3 is of concern as well, because we have to wonder how they would find nocturnal moths onsite if they weren’t able to find bats or fireflies.

Thank you for addressing these concerns.

Grace Nichols

AVES Team

Berne

Editor’s note: Grace Nichols says this letter was written in collaboration with Conrad Vispo, agroecologists, and other bat experts. She adds that Vispo, a wildlife ecologist, advised the project and analyzed the data.