As a general comment, the Service appreciates the fact that UPC Wind has conducted radar and acoustic studies on bird and bat migration and bat activity at Hardscrabble Mountain and other locations at or near the proposed project. We believe the radar, visual, and acoustic information contained in the above-referenced reports is useful, but that it is not sufficient to demonstrate, at an appropriate scale, the spatial and temporal uses of the airspace over Granby, Libby, Barrett, and Norris Mountains by birds, bats, and insects.

Rick Webb's presentation on October 17 at the Energy Virginia conference provides a thought provoking analysis of the costs and benefits of industrial wind energy.

To reiterate, if the SCC chooses to license this project, we request adherence to the monitoring and mitigation recommendations described in this letter and attachments. In the absence of such conditions, we feel this project would pose an unacceptable risk to the Commonwealth’s wildlife resources.

Below are two Phase I Avian Risk Assessments reports, prepared by Paul Kerlinger, for Vermont's East Haven Wind Farm (July 2003) and New Hampshire's Lempster Mountain Wind Power Project (June 2005). Phase I assessments have proven inadequate in assessing mortality at several sites in the U.S. including Mountaineer in West Virginia and Meyersdale in Pennsylvania. The US Fish and Wildlife Interim Wind/Wildlife Guidelines calls for multi-year evaluation of avian and bat activity using remote sensing.

Starting with our first interagency meeting on April 8, 2005, we have generally discussed three broad categories of activities that pose a potential concern for fish and wildlife resources. These include the potential for bird and bat collisions with turbines, habitat fragmentation effects on wildlife and impacts to waters/wetlands. At the April 8, 2005 interagency meeting, we recommended that CEI collect three (3) years of radar data on spring and fall bird/bat migrations to document the spatial and temporal use of the airspace by these flying vertebrates. Three years of radar data should be sufficient to gather information on the spatial and temporal distribution of birds in the airspace, including the year-to-year variability in migration patterns at this site, and represent our normal request for these data at wind projects. We have consistently requested that this data be collected at our meetings and field visits and continue to make this request for radar information.

ORDER
IT IS HEREBY ORDERED, ADJUDGED AND DECREED by the Public Service Board of the State of Vermont that:
1. The findings, conclusions and recommendations of the Hearing Officer are hereby adopted, as modified above.
2. The proposed Project will not promote the public good of the State of Vermont, and a certificate of public good shall not be issued pursuant to 30 V.S.A. § 248.
Dated at Montpelier, Vermont, this 17th day of July , 2006.

Because time seems to be running out on fossil fuels and the lure of non-polluting windpower is so seductive, some people are now promoting windpower initiatives at any cost, without investigating potential negative consequences-- and with no apparent knowledge of even recent environmental history......Throughout my experience, I could not substantiate a single claim developers made for industrial wind energy, including the one justifying its existence: that massive wind installations would meaningfully reduce our reliance on fossil fuels. When you understand this, you realize the wind business is not really that complex. But there are a lot of complicated issues swirling around it that obscure and distract from this main point, issues such as global warming, property values, the nature of wind leases, local revenues and taxes, wildlife, natural views, and a host of others. So how does one know the truth of it all? How does one go about separating the reality from spin?

Compliments of Andrew Chapman, the attached pdf files contain extensive documentation particularly with respect to the impact of wind turbines on wildlife as part of an ongoing effort to prevent the construction of the Bald Hills Wind Farm, South Gippsland, Victoria. While it has been approved by the Victorian State Government the presence in the Bald Hills area of migratory species of national and international significance that are protected by treaties with Japan and China in the Bald Hills has placed the final decision in the hands of the Federal Government. This decision is pending.

In its submission today, the department will not reiterate all of the matters raised in the 21 October submission, rather the department wishes to focus largely on the matters arising from this proposal affecting Brolga and Southern Bent-wing Bat.

The Service favors:
--conservation of wildlife in the public trust;
--development of renewable energy that is bird and bat friendly; and
--use of informed decisions based on adequate environmental assessment and sound science.