Kevin Kawula distributed his letter below to environmental organizations throughout Wisconsin in hopes of raising awareness about the shockingly high bat mortality discovered at operating wind energy facilities in the State. Windaction.org shares Mr. Kawula's concerns and thought it appropriate to feature his letter in this week's Wind Alert!

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"The notion that the wind industry is predominantly made up of small, environmentally conscious operations is one that must be quickly dispelled. These are large, corporate-scale utility companies, not unlike coal and oil conglomerates ... with a checkered environmental track record to date. Voluntary guidelines will not change that paradigm, and will work about as well as voluntary taxes." -- George Fenwick, President American Bird Conservancy

Things are going badly for our wildlife populations in and around the operating industrial scale wind projects in Wisconsin.

Anecdotal reports from people living in Wisconsin wind projects report an absence of normal wildlife, i.e. no turkey, no deer, fewer or no songbirds, and no bats. Relatives and friends outside the wind facility report greater numbers of deer and turkey.

The birds and deer are leaving the area, but the bats are as likely to be dying, as leaving.

A recent post-construction bird and bat mortality report, conducted by We Energies (WEPCO) CLICK HERE TO DOWNLOAD as part of receiving approval for its Blue Sky Green Field project, shows that the bird deaths were 11 to 12 bird deaths/per turbine/per year. This is four times higher than the national average of 3 bird kills/per turbine/per year.

Even more alarming are the bat kill rates of 40.54 to 41/per turbine/per year This is more than ten times the reported national average of less than 4 per turbine per year.

Wisconsin's turbine related bat deaths are among the highest in North America, and equal to the bat mortality numbers from Pennsylvania/Appalachia area which stunned conservationists across the nation.

The total number of bats killed by the 88 turbine Blue Sky Green Field project is estimated to be between 3,500 to 3,600 per year.

Two additional post construction reports show the same bat kill rates at the Cedar Ridge project, and slightly higher kill rates at Invenergy Forward Energy project near the Horicon Marsh.

These three projects alone have resulted in an estimated 8,000 bat deaths per year.

That's 16,000 dead bats for the two years these projects have been in operation.

Predictions for number of bat kills for the pending Glacier Hills wind project are expected to be equally as high, adding at least another 3500 turbine related bat deaths per year.

Can Wisconsin bat populations sustain this kind of impact?

Bats are not being struck by the blades (135 feet long with tip speeds of 180mph), but are suffering catastrophic damage to their lungs as they fly into the low-pressure zone that is created behind the rotating blades.

This drop in pressure causes their lungs to expand rapidly, burst, fill with fluid and blood, and they drown. It is called barotrauma - deep-sea divers get a version of it called the bends, when raised too quickly from the depths.
Birds have different lung structures, so they are not as readily affected, but bats are mammals and have lungs much more similar to ours, so take a deep breath, and imagine you can't stop inhaling until your lungs burst.

Bats live up to thirty years, reproduce slowly, maybe one pup a year, and because they maintain tight family groups, the loss of a single bat can have a significant impact.

Bats are a vital link in the natural balance of Wisconsin's wild and not so wild areas.

I cannot think of a time in human history that bats have not been flying over Wisconsin, but the loss of our bat population could happen in our lifetimes.

White nose syndrome, a nasal/respiratory fungus, is threatening cave roosting/hibernating species of bats, in the eastern United States into extinction, but has not yet reached Wisconsin.

Industrial wind turbines kill all species of bats, even the tree roosting/migrating species we hoped might be spared from the white nose blight.

If the state continues to follow its plan to add 200 to 300 new industrial turbines each year until 2025, turbine related bat deaths could be as high as 131,200 to 192,700 bats per year.

This total annual mortality number is unlikely, because the remaining bat populations would likely crash from mounting annual losses before then.

I am asking that we, as conservationists, help stop this needless slaughter.

Contact the Department of Natural Resources and the Public Service Commission of Wisconsin with your concerns.

Shari Koslowsky, Conservation Biologist with the DNR, has been very helpful in explaining the post construction mortality numbers. She can be reached at shari.koslowsky@wisconsin.gov , (608) 261- 4382.

My main concern is that there is no representative of any organization with expertise in wildlife and natural habitat protection on the Wind Siting Council. The Wind Siting Council is a 15 member organization currently working on creating guidelines for siting wind turbines in our state.

I am asking that the DNR require the PSC to stop the operation of industrial scale wind turbine facilities at night (curtailment) when electrical demand is low and easily met by existing base load generation which cannot be shut off.

The period from dusk until dawn must be reserved for migrating and feeding wildlife as an equitable distribution of a state ("free wind") natural resource, for the greater good of the whole rural community, human and animal. Night time curtailment would ensure safe passage for bats and night migrating birds, and provide a reliable period of quiet for the undisturbed sleep that is vital to any being's health.

CLICK HERE to leave a comment on the Public Service Commission of Wisconsin's Wind Siting Council's docket.

Energy independence will eventually mean grid independence, but until then the decision makers need to face the facts and take responsibility for the harm caused by their decisions, and remedy the problem.

Mr. Kawula is a board member of the Rock County Conservationists, TPE Member, Spring Valley Planning and Zoning board member, Owner and operator of Lone Rock Prairie Nursery, and Rock County Parks Volunteer.
lonerockprairienursery@gmail.com

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Significant bat mortality at wind energy facilities first became widely known in the United States in 2003 when research scientists observed alarming numbers of bats killed at FPL Energy's Mountaineer wind energy plant in West Virginia. The forty-four turbine site located along the forested Backbone mountaintop was found to be slaughtering bats at annual rates of over 50 bats per turbine with some estimates placing the count at close to 100 bats. High mortality was also observed that year at the Meyersdale wind farm in Pennsylvania, another FPL project.

Researchers from Texas-based Bat Conservation International ("BCI") were invited to investigate the cause for the high mortality with the intent of trying to minimize and/or avoid the impact. FPL (now Next Era) initially agreed to cooperate, but in 2004 abruptly changed course and banned further visits by scientists to the sites. To our knowledge, bat kills are continuing unabated and Windaction.org has no independent information to suggest anyone is even monitoring the problem.

In 2007, renown bat expert Dr. Thomas H. Kunz and others published "Ecological impacts of wind energy development on bats: questions, research needs, and hypotheses", which detailed the significant risk that industrial-scale wind turbines posed for migratory and local bat populations in the Mid-Atlantic region of the United States. The authors projected that by 2020, annual bat fatalities at wind energy facilities in this area alone could reach 111,000 bats.

The authors also made clear that their preliminary projections of cumulative bat fatalities were likely unrealistically low.

And developers' own consultants agree. During court proceedings before the U.S. District Court involving the Beech Ridge wind energy facility proposed for West Virginia, experts predicted that more than 135,000 bats would be killed by the turbines through a combination of direct collision with the turbine blades and barotrama. The Beech Ridge project is close geographically to the Mountaineer facility.

Dr. Kunz elaborated on his concerns in written testimony submitted to the court as follows:

"the most severe threats facing bats in eastern United States are habitat loss, White Nose Syndrome, and proliferation of poorly sited industrial wind developments. Habitat loss and degradation as a result of human activity has been occurring for a long time, but the recent threats of White Nose Syndrome and industrial wind developments - and particularly the cumulative effects of the two simultaneous threats -could have especially deleterious effects on a number of bat species in the eastern United States, including the endangered Indiana bat."

Vermont's Agency for Natural Resources is taking bat mortality very seriously. In recommendations to the Vermont Public Service Board involving a 5-turbine project along Vermont's Georgia Mountain, the agency proffered maximum allowed mortality thresholds:

"Adverse impacts to bat populations may occur as a result of the new wind facility and should be addressed when estimated bat fatalities for the period July 1 through September 30 at the Green Mountain site exceed 0.0 threatened and endangered bat species/ turbine (Indiana or small footed bat), 3.0 migratory bats/ turbine (combinations of red bat, hoary bat and silver- haired bat) or 5.0 bats/turbine of other species (combinations of little brown bat, big brown bat, northern long-eared bat, and tri-colored bat)."

But wind developers building in agriculture areas or areas away from forests essentially ignored the bat problem believing it only applied to a few projects along ridgelines in eastern States.

In proceedings before the Wisconsin Public Service Commission on the Blue Sky Green Field Wind Energy Center (88 turbines), developer We Energies dismissed recommendations by the State's Department of Natural Resources (DNR) that pre- and post- construction studies be conducted to understand the effect on resident and migratory bats. Their witness testified that the "project's bat mortality rate is reasonably likely to compare with the published mortality rates at wind farms located in similar agriculturally-dominated landscapes."

Still, the Commission required the project conduct post-construction studies and the results were staggering. Bat mortality was found to be over 40 bats per turbine per year with counts nearly split between migratory and resident species. In an expected 20-year project life, over 70,000 bats will be decimated by this single project.

Scientists at the DNR made it clear to the Commission that there were too few scientific studies completed nationwide for anyone to understand the estimated potential for impacts for a particular wind farm simply by performing a literature review and extrapolating the results from wind farms located in similar environments. And they were right!

The State of Wisconsin now has a decision to make on what to do about bat mortality. Windaction.org hopes Wisconsin and We Energies will act more responsibly than NextEra and the State of West Virginia. An important step is to first acknowledge that the problem exists.

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Since 2003, with the discovery of significant bat kills at the Mountaineer wind energy facility sited on a forested ridgeline in West Virginia, the wind industry has been battling the issue of how best to predict and site wind facilities to avoid, or minimize the problem. High bat mortality has since been reported at project sites worldwide, particularly involving migratory species, prompting concerns of cumulative effects on bat populations.

World renown bat expert, Dr. Thomas H. Kunz, and others, in their peer-reviewed paper entitled "Ecological impacts of wind energy development on bats", detailed the significant risk that industrial-scale wind turbines pose for migratory and local bat populations in the Mid-Atlantic Highlands region of the United States. The authors projected that by 2020, annual bat fatalities at wind energy facilities in this region alone could reach 111,000 bats. They also state that their preliminary projections of cumulative bat fatalities are "likely to be unrealistically low, especially as larger and increasing numbers of wind turbines are installed." 

High bat mortality is not limited to the eastern region of the U.S. Drs. Kunz and Merlin Tuttle raised the red flag in Texas where limited or no studies are underway and researchers in Canada, where barotrauma was first identified, are also trying to quantify the problem. When the devastating bat-killing disease white-nose syndrome - which has now spread to much of the East Coast - is factored into the equation, it's easy to understand why leading bat experts are predicting truly dire consequences unless drastic changes are made in the way that wind power projects are sited and regulated.

With that background, we introduce the law suit filed by Animal Welfare Institute, Mountain Communities for Responsible Energy, and others against Beech Ridge LLC.

At issue is whether the massive Beech Ridge project - consisting of over 120 industrial wind turbines spread out over 23 miles on multiple Appalachian ridges in Greenbrier County, West Virginia - will likely kill, wound, harm, harass, or otherwise "take" any federally endangered Indiana bats during the two decades that the turbines will operate. Discovery taken to date by the plaintiffs' attorneys reveals the scale of risk to bats as follows:

• that Defendants' own consultant - BHE Environmental ("BHE") - has predicted that more than 135,000 bats would be killed by the turbines, through a combination of direct impacts with the turbine blades and barotrauma;

• that such deaths will likely include other "myotis" species - the taxonomic group that includes Indiana bats - including such species that have been captured on the Beech Ridge site and that resemble the Indiana bat and share similar ecological characteristics;

• that other wind power projects built on Appalachian ridges - including the "Mountaineer" facility in West Virginia, which is close geographically to the Beech Ridge project - have had far higher rates of bat mortality than wind power projects located in other parts of the country, and that the available data reflect that Appalachian projects have killed higher percentages of myotis species than elsewhere in the country;

• that hundreds of Indiana bats presently hibernate in caves within ten miles of the project site - including some that are less than seven miles from turbine locations - and that there are no currently operating wind power projects closer to known Indiana bat hibernacula;

• that Indiana bats can and do migrate between summer roosting and foraging habitat much further than the distance between the hibernacula and the project site;

• that there is in fact "suitable" Indiana bat habitat on the project site itself, as confirmed by the parties' site inspection;

• that the 23 miles of Beech Ridge turbines will be physically located between known Indiana bat hibernacula to the south and east of the project and known Indiana summer foraging and roosting habitat to the west and north of the project;

• that Defendants performed no surveys whatsoever regarding Indiana bat - or, for that matter, any other bat - use of the site during the crucial Fall migration period although both the United States Fish and Wildlife Service ("FWS") and WV DNR sent BHE letters urging that such surveys be performed.

Despite these facts, the developer asserted that Indiana bats were unlikely to be killed, injured, or otherwise taken because Indiana bats have never been detected on the project site itself.

But, in fact, pre-trial investigations uncovered that several such surveys were completed in July 2005. The developer now admits a subcontractor collected "ultrasound" data and the acoustic data sat in a file cabinet unanalyzed. Two experts for the Plaintiffs, Drs. Lynn Robbins and Michael Gannon have analyzed these long-hidden files and have determined that Indiana bats were almost certainly present on the site during the survey.

The trial start date is set for Oct 21; Windaction.org will be watching these proceedings closely. This single project, if permitted to proceed, will pose an alarming risk to bats, including Indiana bats. But what sobers us most is that data involving the Indiana bat was never publicly revealed until a civil suit was filed and the right document requests made. There is no excuse for this cover-up by Beech Ridge LLC and its environmental consultant, BHE Environmental Inc., and they shouldn't be allowed to get away with it.

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This week, Cleveland Plain Dealer bird blogger, Jim McCarty, wrote a delightful article on the successes of Audubon's Seabird Restoration Program in nurturing and tracking the return of rare seabirds to Maine's coastal areas. Mr. McCarty is obviously a bird enthusiast who has spent time researching and writing about the risks to migrating birds should a "string of colossal power-producing windmills" be erected in Lake Erie. 

This week he offered an update to his research by reporting on the U.S Fish and Wildlife Service ("USFWS") Advisory Committee now preparing turbine siting guidelines designed to protect birds from wind turbines. He wrote that this action by USFWS "came in response to pressure from environmental conservation groups" including the National Audubon Society and the Cornell Lab of Ornithology and opined that a "bird-friendly boost from the U.S. Fish and Wildlife Service" will convince wind proponents to make necessary concessions in order to protect our feathered friends.

Unfortunately, Mr. McCarty's optimistic explanation for why USFWS established the Advisory Committee reflects a rewrite of history dating back to 2003. Windaction.org warns that he and other wildlife activists not take any solace in the Committee's work for a host of reasons.

A time line of the events as they relate to this Committee may help reveal why skepticism of its work product is warranted.

May, 2003: The US Fish and Wildlife Service released its Guidance on Avoiding and Minimizing Wildlife Impacted from Wind Turbines.  USFWS regional directors were informed that "wind energy facilities can adversely impact wildlife, especially birds and bats, and their habitats. More facilities with larger turbines can lead to cumulative effects that will initiate or contribute to the decline of some wildlife populations." The Service made it clear that the guidelines did not negate or otherwise weaken existing federal laws protecting wildlife. The guidelines called for a minimum of three years of preconstruction studies to assess risk to migrating birds.

January 2006: The wind industry viewed the USFWS Guidelines as "impractical, inappropriately restrictive, and developed without adequate industry input". A letter surfaced, authored by Mark Sinclair of Clean Energy States Alliance, a wind advocacy group, announcing a collaborative process for resolving wind/wildlife conflicts. His letter stated the outcome of this process "may result in a product that is significantly different than the existing USFWS Interim Guidance". Members of the collaborative included USFWS, the American Wind Energy Association - the powerful wind industry trade group - National Audubon Society, Sinclair's Clean Energy States Alliance, and others. The meetings were not publicly noticed, nor were they open to the public. Laurie Jodziewicz, spokeswoman for AWEA, said the point of the group was to "develop guidelines that everyone could agree on." 

Make no mistake. This effort was not triggered by environmental conservation groups. To the contrary, such groups, including National Audubon, were complicit in the industry's effort to weaken our national Guidelines. 

January 31, 2006: The founders of Windaction.org with others sent a letter to Interior Secretary Gale Norton inquiring about the collaborative process and asking whether USFWS intended to "comply with the basic openness and accountability provisions of the Federal Advisory Committee Act ("FACA"), 5 U.S.C. App 2." FACA applies to any committee established or utilized by one or more agencies in the interest of obtaining advice or recommendations for the Federal Government. Its provisions also require that committees be fairly balanced in terms of points of view represented and the function to be performed.

We were rightly concerned that closed-door meetings would simply be an opportunity for the wind industry and its advocates to force revisions of the agency's Guidance in a manner that made turbine siting and operation easier, but detrimental to wildlife.

February 9, 2006: Scheduled first meeting of the Collaborative. Upon receipt of our January 31 letter, the process was canceled.

March 2007: The USFWS announced it would be forming an Advisory Committee based on FACA. The intent of the Committee was to evaluate and develop guidelines for the safe siting of wind energy facilities.

October 2007: The Committee and members list were formally announced. Of the 22 members (including Mark Sinclair) none possessed research expertise or experience involving bat interactions with wind turbines nor expertise in bird impacts especially with respect to effects on migratory birds using the Appalachian mountain ridges in the eastern U.S. Other expert deficiencies were glaring. 

January 17, 2008: Windaction.org and others submitted a letter to Interior Secretary Dirk Kempthorn informing him that the composition of the committee was illegally skewed in favor of wind industry representatives and the selection process ignored leading experts on critical wildlife impacts.

Shortly after, Dr. Clait Braun declined his appointment to the Committee telling Windaction.org that one reason was that the Committee was stacked in favor of wind interests. Others declined participation leaving a few openings. In response to our letter, the Service scrambled to fill the slots with bat "experts".

March 6, 2008: USFWS Career Deputy Director Ken Stansell responded in a proforma letter stating "We believe the selection of the members met the goal of achieving balance" among geographic regions, wildlife interests and industry interests.

January and April, 2009: The first few drafts of the guidelines were released by the Committee for public comment.

May 11, 2009: Windaction.org and others submitted a second letter to Secretary Salizar requesting he immediately suspend work on the committee citing excessive industry influence in preparing the Committee's draft recommendations.

To date, our concerns with the Committee's membership have been ignored.

Scientists have written to USFWS expressing concern with the draft guidelines including Dr. Shawn Smallwood, a prominent biologist in the area of impacts of wind turbines on avian life. Those familiar with the history of the Committee and the 'agendas' of its individual members have little faith that its work product will serve any value in protecting vulnerable wildlife resources - a job we would have thought to be the highest priority for the USFWS.

Windaction.org encourages greater Congressional oversight by the House Natural Resources Committee. Some States are being more proactive than the Feds. For instance, Mr. McCarty and other bird enthusiasts may wish to look to New York State for its guidance released in January 2009.

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