Wiegand Comments - Wind Energy Guidelines

Courtesy of Jim Wiegand of Redding, California.

August 2, 2011

RE: Wind Energy Guidelines - Comments

Dear Sir or Madam:

I have reviewed the U.S. Fish and Wildlife Service Revised, Draft Guidelines for Land-Based Wind Energy Projects. The influence by the wind industry upon the recommendations made by the Wind Turbine Guidelines Federal Advisory Committee, are obvious.

I found the guidelines to be nothing more than a device whose sole purpose is to castrate the USFWS from its duties and absolve the wind industry from accountability. The use of the word Guidelines is also misleading because there really are no guidelines. The guidelines are all voluntary and allow the industry to be self regulating. If adopted, the guidelines will handcuff the USFWS so there is no hindrance by this agency from the destruction to wildlife and their habitats being done by the wind industry.

I believe the proposed guidelines will also be used as a foundation for the wind industry to steamroll across any habitat, National Park, refuge or mountain range they want, with virtually no oversight.

If one compares both the 2003 Voluntary USFWS guidelines and newly proposed guidelines they will find that both are really quite absurd. They in essence, give the wind industry the privilege of diplomatic immunity. With these new guidelines project developers are just "encouraged" to comply and the guidelines are only "intended to promote" compliance. The language in the Guidelines is riddled with examples of ambiguous language, language that will leave the industry with very few rules or regulations for the development of wind projects. The bottom line is that if the U.S. Fish and Wildlife Service Revised, Draft Guidelines for Land- Based Wind Energy Projects are put in place, America will just have to rely on the moral conduct or good conscience of the wind industry.

Looking back, what have the 2003 USFWS voluntary guidelines really accomplished? I have seen what the good conscience of this industry has brought to America. There are now thousands of lethal wind turbines in California condor and whooping crane habitat, with thousands more on the way. Where there is wind, they will build. If there is an impact from a project to a critical species, there mercenary biologists will create bogus documents to predict minimal impacts. Then after the projects are installed, protected species killed by the turbines are routinely hidden. I encourage the USFWS to show me any wind industry impact report and I will show you deception, incompetence, omissions or fraud. Since 2003, the industry has become a runaway train.

If the primary mission of the USFWS "is working with others to conserve, protect, and enhance fish, wildlife, plants, and their habitats for the continuing benefit of the American people", the USFWS should explain exactly how any of these so called guidelines could ever conserve, protect, and enhance fish, wildlife, plants, and their habitats when there is no transparency. I must remind the USFWS that the fish and wildlife in this country do not belong to the wind industry.

Imagine a District Attorney trying to prosecute a murder case if there were state laws/guidelines in place that were written in the same manner as these guidelines. The District Attorney would encounter language similar to this. "We encourage everyone to show restraint when angry and recommend minimizing all hostility in an attempt to avoid the taking of a life". Sadly, this illustrates just how ridiculous these guidelines are. Of course the courts would be empty and this brings up another underlying purpose of these guidelines.

The USFWS needs to return to it roots. You should put these guidelines in the dumpster and get back protecting the wildlife in this country. For starters the USFWS should be sure to address the wind industry's contrived baseline studies and its pattern of looking for target species and behavior at the wrong time and places for a predetermined outcome. A list of all those involved in the bogus documents should be noted in a special incompetence file. For this task, I would be happy to assist the USFWS.

Secondly, in order to get a real grasp on the damage being done to the thousands of protected species killed daily by the wind industry, the USFWS service should require with consequences, that every wind project save and report all fatalities starting from day one of operation. Without accurate knowledge it is impossible to properly manage the impacts caused by this industry. Analysis and significance of the fatalities should be left to experts completely unrelated to the wind industry. Additionally there is also no need for the wind industry to conduct their own post construction studies. They have demonstrated over and over, they can not be trusted.

Thirdly, it is time to take another look at Altamont Pass, the grandfather of all wind farms. An accurate raptor survey is badly needed taking into account the numbers of, or lack of, permanent raptors living in the habitat in and around the wind turbines of Altamont Pass. Instead of just counting bodies under the turbines there needs to be a meaningful raptor nest inventories and aerial surveys study that looks at the actual ongoing impacts to the populations living in the Altamont Pass region. It may very well be that many of the permanent resident raptors have been killed off and now you are dealing mostly with raptors dispersing from other regions., I guarantee that with an honest study, the 59 pairs on nesting golden eagles once claimed to be living within a 19 mile radius of this wind farm, will not be found. I also suspect that any study area of several hundred square miles would clearly show more raptors residing per square mile in similar habitat the further away one gets from Altamont pass. The 25 year impact of killing raptors at Altamont Pass should be documented.

The USFWS has made it clear that the U.S. Fish and Wildlife Service Revised, Draft Guidelines for Land-Based Wind Energy Projects are intended to address the potential negative effects of wind energy development on fish, wildlife, and their habitats. If this is true, then my suggestions will be put in place and the lack of wind farm transparency will end. Otherwise none of these guidelines will be worth the paper they are printed on.

While on the subject of Land Based Wind Projects, I would also suggest that the USFWS look into the possibility that some of the drought conditions in Texas and Oklahoma could possibly be due in part to the many thousands of huge wind turbines installed in these two states. There is a possibility that there could be an atmospheric influence from the wall of thousands turbines to the north and northwest of Austin and the wall of turbines being built to the south along the coast. I suspect that the air turbulence and infrasound (ELF Waves) given off by the new generation of large wind turbines is having an influence on the normal mixing of cooler air coming from the north with the gulf air movements from the south. ELF waves are known to travel great distances and bend while moving upward into the atmosphere. These waves are known to have an impact on water vapor. It may explain the lack of rainfall in this report coming out of Mongolia.

In conclusion I would like to remind everyone that the lack or regulations, and enforcement has already cost this country dearly. Two recent examples are the Minerals Management Service and its relationship to the Gulf oil spill and the Fed's lack of oversight of the banking system. With these newly proposed guidelines, a new disaster for wildlife is in the making.

Jim Wiegand

Wildlife Biologist and raptor expert