The costs of wind energy permitting compliance actions for regulated bats in the US

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 (USD), with a 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.