Dan Boone's comments are critical of the proposed California Energy Commission guidelines for conducting post-construction bird-bat mortality surveys. The concerns raised by Mr. Boone center on procedures which, as written, will likely bias any study toward underreporting of fatalities. These include:
- A recommendation by the CEC that searches of wind turbines for dead birds and bats be conducted only once every 2 weeks.
- CEC's guidelines that define a "small" bird as being 10 inches or less in length (from tip of tail to bill tip). As noted by Boone, "relatively few bird carcasses found during wind turbine mortality studies are more than 6 or 8 inches in length - the vast majority of carcasses found are much smaller than 6 inches (i.e., songbirds)."