I am working on developing the required monitoring plan, but in conversations with the American Bird Conservation manager, drafting a plan for a new building cannot be drafted in the way the requirement is written. The issue is that there is no baseline to make a comparison and there are more factors that go into evaluating when an action plan would need to be implemented. Also, the corrective actions are more diverse and elaborate and will depend on the species of bird, location, time of the year, frequency, weather patterns, etc. Listing remediation strategies is really not advisable.

Our approach to meet the requirement will be to indicate a monitoring period of 2 years to develop a baseline and then a yearly review to evaluate significant changes. The corrective action plan will be based on recommendations after reviews from Virginia Department of Game & Inland Fisheries (State agency in charge of managing bird impacts and injured rehabilitation) and the owner following American Bird Conservancy acceptable remediation strategies.

Will this approach meet the intent of the credit?