Documents
The PA Biological Survey (PaBS) - a non-profit scientific, educational, and advisory organization of professional biologists, incorporated under the laws of the Commonwealth of Pennsylvania - sent this report to the Pennsylvania Game Commission (PGC).
The report, authored by the Wind Energy and Bats subcommittee to the Biological Survey's Mammal Technical Committee, documents the PGC's direct side-stepping of a long-established memorandum of agreement with the PaBS when the Game Commission developed and finalized the Wind Energy Voluntary Cooperation Agreement without the review or input of the Biological Survey. The memorandum of agreement was created over 10 years ago to help ensure that the Game Commission obtained advice from experts about actions affecting the mammals inhabiting the Commonwealth.
The report also undercuts the legitimacy of claims by Secretary DeBerardinis that "The Game Commission's voluntary agreement is a model for the nation" which "grew out of their participation in a science-based, collaborative effort of government, industry and others"; these statements were incorporated in the April 2007 PGC's press release that praised the signing of this Agreement by a dozen wind energy developers - see: http://www.pgc.state.pa.us/pgc/cwp/view.asp?A=11&Q=171573 .
The main body of the report critiques the terms of and research protocols included in the Game Commission's Wind Energy Cooperation Agreement.
In concluding their report, the Pennsylvania Biological Survey "urges the PGC to abandon the current Protocol to monitor Bat and Bird Mortality at Industrial Wind Sites (Exhibit C of the Wind Energy Cooperative Agreement) and develop a more realistic, more meaningful, and more scientifically sound protocol, that will evaluate wind turbine impact, and protect the wildlife and other resources of the Commonwealth of Pennsylvania."
It further states that "The current PGC protocol is not based on the "best science available" and is not in keeping with recommendations and/or does not address concerns of the US Fish and Wildlife Service (2003), The US Government Accountability Office (2005), the National Research Council Report (2007), the position held by the Mammal Technical Committee in a previous communication to the PGC (Appendix I), the position of Bat Conservation International (Appendix II), recent expert testimony before the US Congress (Committee on Natural Resources, 2007) and numerous government and independent bat experts and scientists in the US and Canada. To continue to promote and use such a protocol would be to put the interest of the wind industry before the interest of the Commonwealth."
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