This letter was sent to the Oklahoma Department of Wildlife Conservation in response to a wind energy development proposal slated for the Hal and Fern Cooper Wildlife Management Area (WMA).

M. David Riggs, Chairman
Wildlife Commission, ODWC
PO BOX 53465
OKC, OK 73152

Dear Sir,

We are writing this letter in response to the proposal recently presented by Oklahoma Gas and Electric Company to the Oklahoma Department of Wildlife Conservation (ODWC) regarding wind development on the Hal and Fern Cooper Wildlife Management Area (WMA). We appreciate your Commission's commitment to the management of Oklahoma's resources, and we recognize that commitment includes financial leadership. Therefore, the potential for leasing of wind rights or outright sale of ODWC lands demands your attention. However, we have serious concerns regarding the likely outcomes a decision to allow wind power development on WMAs will have. We have outlined these below for your consideration.

First, a decision to allow wind development on WMAs would set a precedent not only for other Oklahoma public lands, but also for public lands in adjacent states. This could cascade into large-scale habitat fragmentation which would directly conflict with the stated goals of management of these lands. Additionally, private landowners in the immediate area would essentially see any wind development on public land as an indication that wind power is compatible with ecological integrity and function. The scientific and conservation communities have ample data that indicates it is not. We believe that wind development on WMAs would seriously impede the outreach efforts of the US Fish and Wildlife Service (USFWS), The Nature Conservancy, Sutton Avian Research Center, and Oklahoma State University Cooperative Extension Service in addressing habitat fragmentation concerns on private lands. Furthermore, endorsing wind development on a WMA would directly contradict the professional recommendations of wildlife biologists, including ODWC staff, which will compromise the credibility of wildlife professionals at multiple levels.

Second, we feel that the sportsmen who contribute the bulk of ODWC funding, and the Federal Aid providers that match those funds, will not be supportive of wind development on WMAs. The political backlash could be a serious impediment for the Department for years to come. In particular, nonresidents contribute large amounts of income to local economies in NW Oklahoma. They come to Oklahoma for high quality hunting and scenic vistas. Wind power will negatively influence both of these experiences. Additionally, many ODWC land acquisitions are made possible because the landowner selling or donating the land believes in ODWC's mission. We can not speak for how Hal and Fern Cooper would feel about wind turbines on this land, but it is likely that development on WMAs will hinder future land donations or acquisitions that could add to public hunting access and species recovery in the state.

Finally, as you are well aware the Lesser Prairie-chicken, a game species in serious decline, is known to have recently occupied the Cooper WMA and adjacent lands. The USFWS is currently considering if the Lesser Prairie-chicken's candidate status warrants elevation. This is due primarily to the effects of habitat fragmentation from rapidly increasing oil, natural gas, and wind power development within the range of the species. Prairie grouse in general exhibit strong avoidance of vertical structures, habitat fragmentation, and human disturbance. As Cooper WMA is one of the few publicly-managed parcels within occupied range, wind power development would be detrimental to the Lesser Prairie-chicken's current status and future recovery. If the last remaining protected lands are developed for wind energy, the USFWS may be forced to report the species in imminent threat of extinction. We fear that an Endangered Species Act listing in partial response to wind development on public land would be looked upon most unfavorably by the agricultural community and national public. In addition to concerns regarding the Lesser Prairie-chicken, this area also falls within essential flight zones for the endangered Whooping Crane and Mexican free-tailed bat maternity caves.

We realize that, on the surface, wind power appears attractive as a source of renewable, non-polluting energy - something all of us in the conservation community support. However, we must stand by the data, which raise serious concerns regarding wind energy production potential, limited carbon offset, minimal local economic benefit, and permanent fragmentation of habitat. Thus, the ecological footprint is large relative to the meager environmental benefits. We can provide data from around the world to support that wind turbines and the associated infrastructures have deleterious effects on wildlife species. In fact, The Wildlife Society (the professional organization of wildlife biologists) recently released an official statement entitled "Impacts of Wind Energy Facilities on Wildlife and Wildlife Habitat" that clearly states the negative consequences of wind power with recommendations regarding placement.

We believe there are ample private lands in Oklahoma that are appropriate for wind development, such as cultivated lands where wildlife habitat has been degraded. However, high quality public native rangeland occupied by sensitive species is not an appropriate place for such development. We recognize that ODWC could potentially purchase additional lands with funds acquired from leasing wind rights or selling public lands. However, we submit that the above mentioned concerns of fragmentation, federal regulatory protection, public perception, public land precedent, impediments to outreach, and loss of future land acquisition options outweigh any possible short-term financial gains.

Our professional recommendation as wildlife ecologists is that leasing or selling any public lands for wind energy should be unilaterally rejected. This position in no way precludes the development of wind siting plans and mitigation policies with the wind industry in Oklahoma. We support the development of relationships with state legislators and the wind industry to identify pathways that accommodate both wind development and wildlife values. To begin this dialogue, we request that your Commission approach Governor Brad Henry to convene a special summit on how wind development may move forward in this state without jeopardizing the unique cultural and ecological assets of the region. Similar directives from Governor Dave Freudenthal in Wyoming regarding energy development and the Greater Sage-grouse have proven beneficial.

In closing, we write only to offer perspective and support for the decision the commission must make on this issue. The inescapable reality is that Oklahoma lies at the national forefront for wind development potential. This will require great leadership from the elected and appointed officials responsible for the natural resources in this state. If we can provide any information to assist the Commission, please contact us at any time. We thank you for your consideration in this matter, and we appreciate your dedication to the natural resources and biological wealth of Oklahoma.

Respectfully,

 

Dr. R. Dwayne Elmore, Treasurer
Dr. Craig A. Davis, President
Oklahoma Chapter, T
The Wildlife Society Oklahoma Chapter,
The Wildlife Society

Dr. Rick Baydack, President
Dr. Steve K. Sherrod, Executive Director
North American Grouse Partnership Sutton Avian Research Center

Donald H. Wolfe, Senior Biologist
Dr. Timothy J. O'Connell, President
Sutton Avian Research Center Oklahoma Ornithological Society