Why are wildlife species even mentioned when it is only land being mitigated for, not any deaths due to direct impacts? These deaths are a taking violation of the Migratory Bird Treaty Act in most cases, yet those impacts seem to be ignored. Why is that?
What is the view of a wind development company on these voluntary guidelines? It seems doubtful that a company would consult with NGPC and FWS and then have any need to review these guidelines as well. So, what is the value for them doing so? Perhaps this could be indicated? Their value as a preconsultation tool should continue to be indicated.
Why would a developer go through a voluntary guideline process when they will have to pay administrative fees? This document list four items - from finding to assessment - that any acquisition funds would be used for, and that would simply take funds away from what is most important: habitat conservation. Companies are placing turbines so they can make a profit, not pay fees to someone else!
How can this document have an especially beneficial influence on being helpful to avoid turbine placement in sensitive areas? To be useful, it needs to be more than a repeat of a federal document. Are there state specific issues or concerns that can be given particular attention? It would seem that the wetland resources would be one item, especially fens or saline wetlands...
Mitigation should not be focused on providing conservation easements should rather focus on habitat replacement. A conservation easement does not replace lost habitat so this item should be listed as the last option, not the first.
The option of habitat replacement is discussed in such a limited extent, it should be expanded to provide some details on potential entities that could become owners of mitigation properties and manage them for the long term. There are many potential options. Minimal funds should be used for administrative purposes and the vast majority of funds should be used for acquisition. It is easy to prepare a plan once suitable habitat is acquired.
If a group/agency is going to receive some property because of a mitigation effort, what in-kind contribution can they make. Perhaps there could be a mitigation bank established where certain valuable properties have been appraised and would be available for purchase. This is already being done with wetland fill projects and there is no reason the same can't be done for turbine development?
Why isn't the American burying beetle included as a species sensitive to turbine developments?
The whooping crane priority stopover map perhaps should also indicate critical habitat as already designated by the FWS.
Why is there no reference to the findings by UNL staff as a result of research on turbines and prairie chickens? Are there especially important sites/areas where turbines could be especially detrimental to this species of concern?
How can this document be made useful to landowners with interest/concerns with turbine developments. A state document could be especially valuable to its citizens. How can this document be useful for residents to ensure protection of local resources that find important, and which may be influenced by turbine placement? These topics seem to be missing?
Perhaps an example of an approximate timeline process for a turbine development could be illustrated, so appropriate and adequate preplanning occurs?
Details on how to use the mitigation worksheet might fit better in the appendix where the mitigation worksheet is discussed.
Please take some time to revise the verbiage to streamline the text to make it easier to read. There are too many useless transition words used: lastly, therefore, due to, in addition, etc.
Five sentences in one paragraph and four of them begin with playa, and twice with playa clusters. Whew!
There is no such thing as a "living" document. This is a document subject to review and update as needed (i.e.: "This document is based upon the best").