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May 4, 2011
Attention: Wind Energy Guidelines
Division of Fisheries and Habitat Conservation
U.S. Fish and Wildlife Service
4401 North Fairfax Drive, Mail Stop 4107
Arlington, VA 22203–1610.
The following comments are filed in strong opposition to the
USFWS proposed Land-Based Wind Energy Guidelines and Eagle
Guidance. Those guidelines are extremely onerous,
unreasonable, unworkable and unnecessary. The guidelines cannot
be scientifically justified. They amount to burdensome,
over-regulation and will result in dramatic pre and
post-construction studies, adding tremendous cost and lengthy
delays to wind energy projects of all sizes. Such added costs
will also be deal killers for small turbine and community wind
projects at the very time when President Obama and Congress have
called for aggressive steps toward United States energy
independence and expanded investment in renewable energy,
including wind energy, for the purpose of re-industrializing the
U.S. manufacturing infrastructure.
Major economic concerns according to a survey of American
Wind Energy Association members indicate that the policies will
jeopardize: more than 34,000 megawatts of wind power
projects; more than 27,000 jobs; $103 million in potential
landowner revenue; and $68 billion in investment.
The policies and guidance are not based on sound science:
The wind energy industry’s impacts on wildlife are minor,
especially when compared to other human activities and other
forms of energy; The National Academy of Sciences (NAS) and even
the U.S. Fish and Wildlife Service (FWS) itself have
acknowledged that wind turbines represent a minor, small
fraction of bird mortality resulting from human causes. Vastly
larger numbers of birds are killed every year by house cats,
automobile windshields and urban buildings. Very few bird deaths
result from wind energy but these policies will be job killers
at the very time that the U.S. economy is in desperate need of
wind energy-stimulated new jobs and growth.
A much better solution already exists: For nearly three
years the wind energy industry actively participated on the
Federal Advisory Committee (FAC), an entity created by the
Department of Interior specifically for the purpose of advising
the Secretary on wind energy guidelines. The FAC
specifically: included representatives from state wildlife
agencies and wildlife conservation organizations, plus others;
only relied on peer-reviewed, sound science; submitted these
broadly-agreed upon recommendations to Secretary Salazar in
March 2010, signed by all Committee members, including all
representatives from industry, states, and environmental NGOs.
Unfortunately the FWS inexplicably threw out the FAC’s seriously
and thoroughly debated, consensus-based recommendations without
any credible rationale or explanation. The FWS did not provide
any demonstrated conservation benefit from their revised
approach.
The FWS guidelines, including the “eagle permit rule” are more
restrictive and stringent than what exists for more vulnerable
species under the Endangered Species Act (ESA). Permits would
only be available for five years and most wind projects need
financing for ten years or more. A five year permit limit makes
financing difficult, perhaps impossible. The science clearly
indicates that wind energy projects have minimal impact on
eagles. The FWS guidance document fails to rely on sound science
but will have a reliably negative economic impact on our U. S.
sustainable, clean energy future.
For all the reasons mentioned herein Secretary Salazar should
immediately reject the Fish and Wildlife Service Land-Based Wind
Energy Guidance and adopt the Federal Advisory Committee
recommendations.
Sincerely,
Gale Lush, Chairman
112374 State Hwy 4
Wilcox, NE 68982 |
