A coalition of conservation groups says it plans to sue the state Department of Transportation for failing to prevent the bright lights of its airports and harbors on Kauai, Maui and Lanai from killing federally protected native seabirds.

The groups — Hui Ho‘omalu i Ka ‘Aina, the Conservation Council for Hawai‘i, and the Center for Biological Diversity — accused the state agency of violating the federal Endangered Species Act in its failure to protect the Newell’s shearwater, a threatened species, and the Hawaiian petrel and band-rumped storm petrel, which are endangered species.

David Henkin, an Earthjustice attorney, said Thursday the groups have documentation showing the harm being inflicted on the birds distracted by the lights found at the state harbors and airports on Kauai, Maui and Lanai.

The seabirds are notorious for being attracted to artificial lights, often circling them until they fall to the ground from exhaustion or crash into nearby buildings.

Henkin said he received a report of a Newell’s shearwater that crashed to the ground at Kahului Airport on Wednesday.

“This is just the tip of the iceberg,” Henkin said.

A scientific study published this month indicated that Kauai populations of the Newell’s shearwater declined by 94 percent over two decades, while those of the Hawaiian petrel on Kauai dropped by 78 percent during the same time period. Kauai is home to 90 percent of the known population of the Newell’s shearwater.

Department spokesman Tim Sakahara declined to comment, saying the department hasn’t received the formal notice of intent to sue.

In October the Transportation Department backed out of an effort led by federal and state wildlife agencies to establish an islandwide habitat conservation plan aimed at minimizing harm to the rare seabirds on Kauai.

“By withdrawing from talks on Kauai, the department left the County of Kauai and private entities holding the bag to address harm from the airports and harbors, even though the department’s facilities are among the largest sources of illegal death and injury on the island,” Marjorie Ziegler of Conservation Council for Hawai‘i said in a news release.

“The department needs to fulfill its duty under Hawaii’s Constitution to conserve and protect our natural heritage, not stick its head in the sand and do nothing,” she said.

As a result of a federal lawsuit filed by Hui Ho‘omalu i Ka ‘Aina, the county, Kauai Island Utility Cooperative and the Princeville Resort in 2011 were ordered to create and carry out actions described in a habitat conservation plan. The utility created its own plan for the shearwaters, while the other two entities decided to create an islandwide plan that included the DOT in the partnership.

In its letter sent Thursday, the conservation groups said they aim to compel the department to comply with its obligations under the Endangered Species Act by securing incidental take permits covering its lighting practices on all three islands.

The permits, Henkin said, will ensure the department is doing what it can to minimize harm to the seabirds without jeopardizing airport and harbor safety. They might also require additional measures to ensure a net conservation benefit to the seabird species, he said.

Under the Endangered Species Act, agencies must be given 60 days’ advance notice before filing a lawsuit regarding illegal activities.