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most of the bird -window collision studies were limited to migration seasons, Loss et al. <br />(2014) developed an admittedly assumption -laden correction factor for making annual <br />estimates. Also, only 2 of the studies included adjustments for carcass persistence and <br />searcher detection error, and it was unclear how and to what degree fatality rates were <br />adjusted for these factors. Although Loss et al. (2014) attempted to account for some <br />biases as well as for large sources of uncertainty mostly resulting from an opportunistic <br />rather than systematic sampling data source, their estimated annual fatality rate across <br />the USA was highly uncertain and vulnerable to multiple biases, most of which would <br />have resulted in fatality estimates biased low. <br />In my review of bird -window collision monitoring, I found that the search radius <br />around homes and buildings was very narrow, usually 2 meters. Based on my <br />experience with bird collisions in other contexts, I would expect that a large portion of <br />bird -window collision victims would end up farther than 2 m from the windows, <br />especially when the windows are higher up on tall buildings. In my experience, searcher <br />detection rates tend to be low for small birds deposited on ground with vegetation cover <br />or woodchips or other types of organic matter. Also, vertebrate scavengers entrain on <br />anthropogenic sources of mortality and quickly remove many of the carcasses, thereby <br />preventing the fatality searcher from detecting these fatalities. Adjusting fatality rates <br />for these factors — search radius bias, searcher detection error, and carcass persistence <br />rates — would greatly increase nationwide estimates of bird -window collision fatalities. <br />Buildings can intercept many nocturnal migrants as well as birds flying in daylight. As <br />mentioned above, Johnson and Hudson (1976) found 266 bird fatalities of 41 species <br />within 73 months of monitoring of a four-story glass walkway at Washington State <br />University (no adjustments attempted). Somerlot (2003) found 21 bird fatalities among <br />13 buildings on a university campus within only 61 days. Monitoring twice per week, <br />Hager at al. (20o8) found 215 bird fatalities of 48 species, or 55 birds/building/year, <br />and at another site they found 142 bird fatalities of 37 species for 24 <br />birds/building/year. Gelb and Delacretaz (2oo9) recorded 540o bird fatalities under <br />buildings in New York City, based on a decade of monitoring only during migration <br />periods, and some of the high-rises were associated with hundreds of fatalities each. <br />Klem et al. (2009) monitored 73 building fagades in New York City during 114 days of <br />two migratory periods, tallying 549 collision victims, nearly 5 birds per day. Borden et <br />al. (2010) surveyed a 1.8 km route 3 times per week during 12-month period and found <br />271 bird fatalities of 50 species. Parkins et al. (2015) found 35 bird fatalities of 16 <br />species within only 45 days of monitoring under 4 building facades. From 24 days of <br />survey over a 48 day span, Porter and Huang (2015) found 47 fatalities under 8 <br />buildings on a university campus. Sabo et al. (2016) found 27 bird fatalities over 61 days <br />of searches under 31 windows. In San Francisco, Kahle et al. (2016) found 355 collision <br />victims within 1,762 days under a 5-story building. Ocampo-Penuela et al. (2016) <br />searched the perimeters of 6 buildings on a university campus, finding 86 fatalities after <br />63 days of surveys. One of these buildings produced 61 of the 86 fatalities, and another <br />building with collision -deterrent glass caused only 2 of the fatalities, thereby indicating <br />a wide range in impacts likely influenced by various factors. There is ample evidence <br />available to support my prediction that the proposed project would result in many <br />collision fatalities of birds. <br />7 <br />