Submission to USFWS – 2014

USFWS public enquiry about the issue of eagle “take” permits to windfarms (licenses to kill eagles).

This submission was sent to USFWS via direct online docket on Sept. 10, 2014, aknowledged as follows: “Comment Tracking Number: 1jy-8eaf-qqfc”

Dear Sir or Madam,

Save the Eagles International (STEI) and the World Council for Nature (WCFN) are unequivocally opposed to “take” permits being issued to wind “farm” operators allowing them to kill “accidentally” with their machines a certain number of golden or bald eagles over periods of 5 or 30 years. We have explained our position in a letter sent to you on January 11th 2012, and published here: STEI opposes “take permits” for golden eagles

Bald eagles are equally at risk as wind turbines are also being erected in habitats near bodies of water, or in their migration bottlenecks (e.g. the shores of the Great Lakes).

bald eagle with fish

It is a little-known fact that eagles, like other raptors, are being attracted to wind turbines. The reasons for this have been explained here: Biodiversity Alert , and the attraction is confirmed by pictures and videos published here:
Pictures/video of raptors perched on blades, nacelles etc.

As a consequence of this attaction, every wind turbine has the potential of attracting the great birds, and killing them. If one or more of these tall structures happen to be within the vision range of an eagle, which is remarkably extended, there is a chance that the bird may decide to investigate them for perching and/or hunting over the open space that is usually found under them, and where rodents abound in addition to injured and dead birds. Coming within striking distance of the blades, the eagles themselves become likely casualties of the turbines. This includes migrating eagles, as these must stop-over during their journeys, for resting and foraging, and wind turbines offer them opportunities for both. In fact, if anyone had wanted to design the perfect trap for attracting and killing (or maiming) eagles, he would have designed a wind turbine.

eagle in two pieces

The United States Fish & Wildife Service (USFWS) and bird societies are turning a deaf ear to our warnings: they willingly ignore the alarming reality that eagles and other raptors are being attracted to the deadly wind turbines. Yet this disturbing fact has been confirmed by America’s most-quoted expert on birds and windfarms, Dr. Shawn Smallwood. He observed that “raptors spent significantly more time flying at close proximity to turbine blades … than 51-100 m away … or >100 m away … Analyzing the total number of minutes of flight time reveals that something about wind turbines may attract red-tailed hawks to fly near turbines and at dangerous heights. Similarly, American kestrels flew in proximity level 1 (ie 1-50m from turbine) nearly four times longer than expected by chance, golden eagles two times longer, and northern harriers three times longer” – Source: BIRD RISK BEHAVIORS AND FATALITIES AT THE ALTAMONT PASS WIND RESOURCE AREA, THELANDER, C. G, SMALLWOOD, K.S., RUGGE, L. Period of Performance: March 1998-December 2000, National Renewable Energy Laboratory Report SR-500-33829, 2003.

This attraction explains why so many eagles and other raptors are struck by wind turbine blades, which travel at up to 300 km/h at the tip. Over 25 years, according to Smallwood’s estimate of 116 eagles a year, about 2,900 golden eagles have been killed by the Altamont Pass windfarm alone – Source : DEVELOPING METHODS TO REDUCE BIRD MORTALITY IN THE ALTAMONT PASS WIND RESOURCE AREA – Dr. Smallwood & K. Thelander, Aug. 2004 – SEE CHAPTER 3, TABLE 3.11, 1ST LINE: “116.5 golden eagles p.a. adjusted for search detection and scavenging.” Already, the California population of golden eagles has dropped sharply, in spite of assurances to the contrary spread by the pro-wind chorus. More information may be found on this website: Save the Eagles International

Keep off our lakeshore

The lack of interest of USFWS in disclosing the truth about the effects of windfarms on raptors can only be explained by the fact that you must obey crony politicians who will help the wind industry at any cost to wildlife. On the other hand bird societies, including the American Bird Conservancy in spite of their gesticulations to the contrary, are blinded by a conflict of interest. This leaves WCFN and STEI for blowing the whistle on this second biggest scandal of our times, the first being that wind farms produce intermittent electricity of little practical value but at a huge cost to society and to the health of neighbors. Nowhere in the world are they actually saving on CO2 emissions.

Your responsibility in the ongoing massacre of our great birds, and that of the bird societies which look the other way, is paramount. Some will consider your actions as being no less than criminal. Indeed, there is such a thing as a crime againt wildlife. You ought to know.

Mark Duchamp
Chairman, World Council for Nature
President, Save the Eagles International

9 Responses to “Submission to USFWS – 2014”

Leave a Reply