Comments in response to the details given in the draft Land-based Wind Energy Guidelines
Submitted to the U.S. Fish and Wildlife Service via email on August 3, 2011
There should be no incidental take permits allowed for federal and state listed threatened or endangered species.
Wind farms should be sited away from habitats known to regularly used by threatened or endangered species, especially and certainly including the Whooping Crane and within its known migratory corridor.
Wind farms should not be allowed to be placed in association with wetland habitats/areas. All effort should be made to ensure they are sited on "disturbed land" and do not get placed within areas of native habitats such as prairies or woodland tracts.
If incidental take for birds that are not threatened or endangered is allowed, there should be mitigation required that will conserve/manage habitat nearby for the benefit of migratory birds. This requirement should not be fulfilled by obtaining a conservation easement. Mitigation efforts should occur within ten miles of the project site. A specific limit to incidental take should be established, and if the project should exceed the designated limit, it should remove the troublesome turbine(s) or take other measures to reduce the take - killing of birds or bats.
Turbine farms should not be allowed within a particular distance of known breeding areas for sensitive birds or species in peril.
No turbine farms should be allowed within any national wildlife refuge or other wildlife lands owned by the FWS.
Every effort possible should be made to avoid the ruination of important scenic vistas, along scenic rivers or other sensitive and unique lands.
Presite evaluation should be required for turbine farms at areas known to harbor numerous migratory birds with a valid scientific evaluation done to ensure there will be no or minimal impact to migratory birds.
Developers should be required to bear the cost of a suitable analysis, as a proper environmental review is a cost of doing business. The burden should not be placed on the regulatory agency. The cost of energy obviously includes its impact on the environment and natural resources.
There should also be an opportunity for the public to know of FWS involvement in the process, preferably through an online site which presents pertinent details such as project name, FWS contact, project size, stage in review process, potential impacts and findings. This information could be easily presented in a data-format where it is kept timely and available, which is an advantage of using an internet format.
The FWS should promote wind energy at sites close to where the energy developed would be put to use and do not require extensive construction of transportation wires. This would mean near urban centers and not out in the rural countryside where the power would have to be transported long distances. Developers should be required to adhere to particular aspects of the guidelines before they will receive authorization for a project. If a developer chooses to build a project without authorization and there is "incidental take," they should be fined (i.e., Migratory Bird Treaty Act) and the turbines shut down until they suitably adhere to required measures.
Wind energy can provide power for America, but it needs to be developed in a safe and responsible manner which does not harm migratory species, especially those in peril. The proposed guidelines should be implemented as soon as possible.