This week, the U.S. Fish and Wildlife Service transmitted its final set of recommendations on how to minimize the impacts of land-based wind farms on wildlife and its habitat to Secretary of the Interior Ken Salazar. In the press release that accompanied the document, the Service claimed the recommendations represented the consensus of "22 diverse members of the Wind Turbine Guidelines Federal Advisory Committee".
'Diverse' is not a term we'd use. In fact, the Committee's membership from the outset was grossly skewed in favor of industry representatives and ignored leading experts on critical wildlife impacts, a direct violation of the Federal Advisory Committee Act (FACA).
Windaction.org and others raised this objection with the Secretary of the Interior on at least two separate occasions.
In a letter submitted on January 17, 2008, we called on then-Secretary Dirk Kempthorne to revamp the membership of the Wind Turbine Guidelines Advisory Committee after finding that:
1) No committee members possessed research expertise or publication record regarding bats, nor direct knowledge or experience involving bat interactions with wind turbines. This was a glaring omission in light of ongoing reports of massive bat mortality at wind energy facilities;
2) The committee lacked the requisite expertise regarding bird impacts, especially with respect to effects on migratory birds using the Appalachian mountain ridges in the eastern U.S., despite the fact that dozens of planned wind projects are slated for this part of the country;
3) No committee members had significant research, scientific, or regulatory experience with wind energy development and associated wildlife impacts resulting from onshore wind projects in the eastern U.S.
These scientific and technical omissions were especially troubling in light of the many individuals on the committee who either expressly represented or were clearly aligned with the interests of the wind industry.
Only after that letter was sent, and only after some of the original members declined to serve, did the Secretary agree to add two people to the Committee with any experience in bat biology.
A second letter sent May 11, 2009 reiterated our concern with the Committee membership and informed Secretary Ken Salazar that after more than one and one-half years since the Committee's formation, the draft recommendations read more as an unabashed endorsement of wind power than a rigorous effort to address the harmful - and ever growing - effects on wildlife of poorly sited and constructed wind power projects.
Despite its charter to provide advice and recommendations to the Secretary of the Interior regarding effective measures to avoid or minimize impacts to wildlife and their habitats related to land-based wind energy facilities, the Committee's draft recommendations did little more than offer justifications for not developing rigorous, enforceable criteria to address the escalating wildlife impacts.
The Department ignored our letter.
The final set of recommendations just released provides a laundry list of basic suggestions that we would expect from individuals and local town boards just learning about wind energy development and its possible impacts. The report creates an illusion of concern, but offers nothing more than what a wind developer might recommend if asked. If this is the best the U.S. Fish and Wildlife Service can produce, then the entire exercise was a waste of time and public dollars.