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Figure 1. A walkway connecting two buildings at <br />Washington State University where one of the <br />earliest studies of bird collision mortality found 85 <br />bird fatalities per year prior to marking windows <br />(254 annual deaths adjusted for the proportion not <br />found). Given that the window markers have long <br />since disappeared, this walkway has likely killed at <br />least 12,7o5 birds since 1968, and continues to kill <br />birds. Notice that the transparent glass on both <br />sides of the walkway gives the impression of <br />unimpeded airspace that can be navigated safely by <br />birds familiar with flying between tree branches. <br />Also note the reflected images of trees, which can <br />mislead birds into seeing safe perch sites. Further <br />note the distances of ornamental trees, which allow <br />birds taking off from those trees to reach full speed <br />upon arrival at the windows. <br />Window collisions are often characterized as either the second or third largest source or <br />human -caused bird mortality. Loss et al. (2014) estimated that window collisions cause <br />365-988 million bird fatalities in the USA. Homes with birdfeeders are associated with <br />higher rates of window collisions than are homes without birdfeeders (Kummer and <br />Bayne 2015, Kummer et al. 2o16a), so the developed area might pose even greater <br />hazard to birds if it includes numerous birdfeeders. (The Staff Report is silent on this <br />possibility.) Another factor potentially biasing the national estimates low was revealed <br />by Bracey et al.'s (2o16) finding that trained fatality searchers found 2.6x the number of <br />fatalities found by homeowners on the days when both trained searchers and <br />homeowners searched around homes. The difference in carcass detection was 30.4-fold <br />when involving carcasses volitionally placed by Bracey et al. (2016) in blind detection <br />trials. This much larger difference in trial carcass detection rates likely resulted because <br />their placements did not include the sounds that typically alert homeowners to actual <br />window collisions, but this explanation also raises the question of how often homeowner <br />participants with such studies miss detecting window -caused fatalities because they did <br />not hear the collisions. <br />By the time Loss et al. (2014) performed their effort to estimate annual USA bird - <br />window fatalities, a minimially sufficient number of fatality monitoring studies had been <br />reported or were underway. Loss et al. (2014) were able to incorporate estimates of <br />fatality rates based on scientific monitoring. However, they included estimates based on <br />fatality monitoring by homeowners, which in one study were found to detect only 38 <br />of the available window fatalities (Bracey et al. 2o16). Loss et al. (2014) excluded all <br />fatality records lacking a dead bird in hand, such as injured birds or feather or blood <br />spots on windows. Loss et al.'s (2014) fatality metric was the number of fatalities per <br />building (where in this context a building can include a house, low-rise, or high-rise <br />structure), but they assumed that this metric was based on window collisions. Because <br />0 <br />