The US Fish and Wildlife Service recently solicited comments regarding guidelines designed to protect wildlife from the vast expansion of industrial wind and insure that any intrusion into their fragile habitat meets the requirements under the various laws and treaties currently in place.

Ms. Ajax Eastman of Baltimore was kind enough to share the excellent letter she submitted to the USFWS.  We thank Ms. Eastman for allowing us to post it here for you.

Ms. Eastman’s letter begins:

To:  U.S. Fish and Wildlife Service

• Division of Fisheries and Habitat Conservation
• Division of Migratory Bird Management

Re: Comments on Wind Energy Guidelines for Onshore Wind and Eagle Conservation Plan Guidelines.

Dear Sir/Madam,

I am writing to first and foremost protest the issuance of the draft guidelines without making them mandatory.

Even properly sited wind energy facilities will most likely have a negative impact on the environment directly and indirectly when roads, grid connections, cumulative impacts, etc. are considered.

Further, the wind industry is unlikely to reduce global warming or green house gases in a meaningful way because their actual capacity to generate electricity at 40%, 30%, 20%, or as low as 10% in the summer when demand is highest and back up fossil fuel emitting generators have to be cranked in to meet that demand.

Voluntary siting guidelines have proven to be totally inadequate in the protection of terrestrial and avian wildlife and their habitats. If these “voluntary” guidelines that were chiefly prepared by the Fish & Wildlife Wind Advisory Commission, consisting of mainly biased wind industry folks, are adopted, they will continue to harm species and fail to adhere to laws under which the Fish and Wildlife Service are ruled such as the Migratory Bird Treaty Act, the Endangered Species Act, or the Bald and Golden Eagle Protection Act.

The tiered approach for reviewing projects is only as good as it is applied. It must be mandatory and should apply to all projects, not merely those on Federal Lands.

An excellent example of the need for uniform mandatory guidelines for all wind projects is what has happened in Maryland. When a proposed project by Synergics on Backbone Mountain was before the Public Service Commission, the Department of Natural Resources recommended the deletion of a number of turbines that were to be sited on State rare or endangered species territory. The PSC dropped those sites and angered the owner of Synergics, Wayne Rogers who was former head of the State Democratic Committee and well connected to the heavily Democratic legislature. He retaliated by getting the legislature to pass legislation to eliminate environmental review for projects under 70 mgws. A year or so later he reapplied for a permit under 70 mgws that included the same sites previously denied, and today, those sites and species that should have been protected are now destroyed by turbines.

Using Maryland as another example, adequate site reviews must be undertaken by unbiased scientists not connected to the wind industry. Paul Kerlinger is an example of an industry hired ornithologist who did a one or two day walk through and testified that the sites on Maryland’s Appalachian ridges were adequate. Dr. Chan Robbins, a renowned ornithologist who has conducted breeding bird surveys in the area for over 50 years and knows the area to be a major migratory bird corridor was ignored in his testimony on another project in the area.

Cumulative impacts of projects must be considered before permits are granted. Projects considered in isolation of one another fail to take into consideration the adverse impacts beyond that of a sole project. The migratory birds and bats flying the gauntlet of turbines along their traditional corridors could eventually become extirpated.

The proposed guidelines must be mandatory for any project receiving federal financing through grants, subsidies, loans, loan guarantees or any other form of federal funding.

It simply would not be lawful for a federal agency to permit the taking of a protected species by allowing industry to voluntarily follow or ignore protective laws.

Finally, I urge the U.S. Fish and Wildlife Service to consider these comments and make the proposed guidelines mandatory/binding.

Sincerely,

Ajax Eastman

Baltimore, Maryland 21212