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30-Year Eagle Kill Permits: Comment to the U.S. Fish & Wildlife Service on Windpower

By Sherri Lange -- September 10, 2014

“The wind industry is in tatters in Germany, being routed out in Spain, and reduced to operating without mandates such as the RET (Renewable Energy Targets) in AU. It is only a short matter of time before the U.S. and Canada begin their unraveling. It is time for the USFWS to demand complete accountability from developers and pressure the Department of Interior for rapid and realistic policies to protect Eagles, not ‘stabilize’ an industry that wobbles with its every assertion.”

Re: Docket No. FWS–R9–MB–2011–0094-0491 (September 4, 2014)

On behalf of the Great Lakes Wind Truth Group, USA and Canada, and NA-PAW (North American Platform Against Wind Power), representing more than 350 groups, we vigorously protest any permitting AT ALL, for killing of endangered or at risk species via the U.S. Fish & Wildlife Service (USFWS) 30-year permit consideration before you.

Any organization or policy maker promoting proper “siting” or endorsing certain numbers of kills as acceptable in order to support “renewables,” will find itself in the quagmire of having ignobly promoted a dangerously fraudulent industry.

Europe has discovered the fallacies and is living through a lurching reclamation of energy policies and pushback from environment havoc. We know that USFWS has spoken of giving “stability” to the wind industry. We do not envision USFWS as a promoter of wind power. It is clear that federal policy is in favor of developers; and the 30-year take permitting only widens the path of kills. There has never been honest reporting. Lawsuits and threats of legal actions are escalating.

Please don’t use numbers like 475,000 annual bird and bat deaths from windpower. The real numbers are in the millions annually in the USA alone. Species extinctions are under way. Do not allow the USFWS to aid and abet an industry that abides by no rules, virtually none.

 

· “Tim Eicher, a retired special agent with U.S. Fish and Wildlife Service, says if birds are electrocuted or die in oil pits, they face prosecution. But regulators with the federal agencies believe that global warming justifies pushing through wind and solar without regard for bird deaths. He says, “They’re saving the planet, and if eagles die in the process, so be it.””

· “Dominic Dominici, another former investigator with the agency, confirms that the federal government is “prepared to turn a blind eye” to negative aspects of so-called green energy projects. Not only does the government fail to prosecute wind or solar companies that kill birds, they are now even granting those companies permits allowing them to kill protected bird species with no consequences. Anyone else doing so could face felony prosecution.” https://www.wind-watch.org/news/2014/09/01/u-s-fish-wildlife-whistleblowers-denounce-agency-for-turning-blind-eye-to-birds-killed-by-wind-and-solar-facilities/

 

Everyone now knows that there have been egregious lies and misrepresentations about eagle kills due to wind turbines.

Rigged surveys, proponent-driven pre- and post-construction studies, flagrant and wrenching suffering of birds that are decapitated, sliced, often found scrambling off miles away, many uncounted as they have been scavenged, and USFWS and ornithological support meandering down a lame argument trail that wants to “PERMIT” kills and habitat loss to endangered species, all in total favor of a corrupt and nonperforming industry.

Someone is loading his pockets, while all this suffering is permitted. This is not to mention the vast tracts of land that are now habitat unfriendly, and of course, misplaced and fragmented food sources and nurseries.

Our organization at GLWT (Great Lakes Wind Truth) is obviously targeting the protection of the Lakes and its bird rich habitats. Hawk watch data has shown how significant the raptor migration corridors are around the Great Lakes along with significant also movement over the Great Lakes.  Near the Duluth, Minnesota, Hawk Ridge Hawk Watch adjacent to Lake Superior in 2011,  the greatest (by far) number was recorded (migrating bald eagles) of any area in North America. They counted a record 5,778 bald eagles that year migrating south primarily out of Canada, past a unique jutting out area of Lake Superior.

Significant numbers of golden eagles also are counted at this hawk watch.

Near to us at Lake Erie there is also a significant eagle migration: This migration and Eagle abundance is also observable on the Canadian side at Port Stanley.

Please rescind the 30-year permit. Please work with us to deconstruct the massive lies of wind power, and help us to once again be true protectors of Eagles. Do not allow any permits at all. It is completely bogus to pretend that there is any benefit from industrial wind. There is none. How pointless, then, to promote the destruction of Eagles and the utter devastation of habitat?

GLWT and NA-PAW acknowledge the legal protection of Bald and Golden Eagles under the Bald and Golden Eagle Protection Act (BGEPA). We object to any purposeful take of these species which is illegal, marking exception for legitimate educational and scientific purposes. We also consider Accidental take to be illegal in the absence of an incidental take permit issued by FWS. We know that these incidental takes are as mentioned, widespread, underreported, hidden, and involving high level abuse to wildlife.

The USFWS in advance notice, requested comments on the following questions: “Under what circumstances should permittees be required to provide compensatory mitigation? To what degree should any required mitigation offset the detrimental effects to eagles?”

We would expect that permittees would be required to demonstrate the amount of viable power that is created by wind factories, and refer specifically to factual data to demonstrate the reality of the fantastic claims this industry has made. To date, all we see is lack of confirmational data, and killing fields based on complete fallacies.

The wind industry is in tatters in Germany, being routed out in Spain, and reduced to operating without mandates such as the RET (Renewable Energy Targets) in AU. It is only a short matter of time before the U.S. and Canada begin their unraveling. It is time for the USFWS to demand complete accountability from developers and pressure the Department of Interior for rapid and realistic policies to protect Eagles, not “stabilize” an industry that wobbles with its every assertion.

Sincerely,

– Suzanne Albright, Founding Member, Great Lakes Wind Truth; Member, NA-PAW

– Alan Isselhard, Wolcott, New York; Great Lakes Concerned Citizens; Great Lakes Wind Truth, Founding Member; Coalition On Article X; Lake Ontario Riparian Alliance

– Sherri Lange, Executive Director, Canada, Great Lakes Wind Truth; CEO, NA-PAW (North American Platform Against Wind Power); Founding Director, Toronto Wind Action; VP Canada, Save the Eagles International

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Public Comments Processing; Division of Policy and Directives Management; U.S. Fish and Wildlife Service

4401 N. Fairfax Drive, MS 2042-PDM  Arlington, VA 22203

http://www.regulations.gov; September 4, 2014; Docket No. FWS–R9–MB–2011–0054-0165

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