I am submitting comments to the Shasta County Board of Supervisors because the Board has been asked to make a ruling on whether to approve or not approve the Hatchet Ridge Wind Turbine Project. It is not possible to make a ruling if you have not been given the facts needed to make a rational decision. I have read over the Hatchet Ridge Environmental Document prepared for Shasta County. It is a carefully constructed document deliberately designed to exploit the ignorance of the public and to persuade public officials. I saw the glowing letters of approval printed in the Final Environmental Document. I would guess that most would like to withdraw these comments if they were given the truth. The truth is actually very disturbing. Thousands of birds will die at Hatchet Ridge. I will explain what has not been disclosed to the public.
I am an expert on Birds of Prey and most of my comments will be restricted to my knowledge and field experience that I have had with theses species. During the late 1970’s and early 1980’s I had a major influence on the recovery of the Peregrine Falcon on the west coast. The most successful private breeding facility on the west coast was started with 4 peregrine falcons. Three of them were my birds. Most of the offspring went to the University of California, at Santa Cruz and were released into the wild under the direction of Brian Walton. I lived in the area of the proposed Hatchet Ridge Wind Project for 16 years and spent a great deal of time in the outdoors studying the wildlife in region. I also have a degree in Wildlife Biology from the University of California, Berkeley.
Wind Power in its present form is not safe nor is it “Green”. Wind power is also not “environmentally friendly” as we have been made to believe. Each year wind turbines currently kill thousands and thousands of birds across America. This includes rare and endangered species. The kill numbers are staggering and there is an industry wide cover?up to this problem. The industry considers this loss of life as collateral damage and access to wind farms is very limited. Wind farms are now encroaching into critical habitats of the Peregrine Falcon, Bald Eagles, Golden Eagle, Spotted Owls, Ferruginous Hawks, Great Gray Owl and along primary migration routes of all bird species. The two and three blade prop wind turbine designs used by the wind power industry today are responsible for most of these deaths. The design has to be changed to a more compact design so birds will see them as an obstacle and want to fly around them. As Wind Farms spring up all over the world, bird species around the globe are facing a very grim future unless new designs are implemented. No large prop design wind turbines are safe unless there are no birds. I predict a major decline has occurred in all the local bird of prey populations in the vicinity of every wind turbine farm in North America.
Bird kills occur at wind turbine sites because birds think they can fly through to the air space they see behind the turbine blades. Some of the most vulnerable are the birds of prey. Eagles, Hawks, Falcons and Owls all hunt ridge lines. They use the same winds and updrafts that power the wind turbines. When hunting their concentration intensifies and they become even less aware of their surroundings. When focused on prey or a landscape that is seen behind blade rotation, birds become confused by the huge rotating blades traveling at speeds of over 200 miles per hour. If an Eagle flying by a turbine becomes confused for only a split second it is too late to escape the blades traveling over 300 feet per second. Imagine slashing blades rotating in a 312 foot wide circle and moving the length of a football field in less than a second. Only then can one can begin to understand the problems facing all birds of prey near wind turbines.
The bird kill problem related to in the Wind Power Industry is the “Silent Spring” of our generation. The “Green” image of wind farms that has been sold to America is nothing but a campaign of fraud and disinformation. With DDT, the Chemical Industry’s response to the claims of Rachael Carson’s was that she was “a simplistic nature worshiper intent on subverting the continuing progress of science that was central to the development of a nation”. There will be similar statements against my comments by those that are ignorant, those who are corrupt, and those seeking profits.
Undisclosed Negative Environmental Impacts
The first and foremost negative impact not discussed in the Hatchet Ridge Wind Project EIR is Blade TIP Speed. This is what kills. According to the specifications given, the blades on the proposed Turbine Towers will be 126 feet ,151 feet, and 156 feet long. They will rotate at approximately 20 rotations per minute. The diameter of each rotation is 252 feet, 302 feet and 312 feet. At 20 rotations per minute the tip speed of the blades is 264 ft/sec, 316 ft/sec, and 326 ft/sec. If this is converted to miles per hour it works out to 180 mph, 215 mph and 222 miles per hour. Some other wind turbine tip speeds are even higher. The speed and power of these blades is what amputates the wings off flying Eagles.
The Hatchet Ridge Project lies in the middle of the Pacific Flyway. The Pacific Flyway is a migration route taken by millions of migratory birds each fall and spring. There is also an east west migration in the fall and a west east migration in the spring. The EIR does not mention this or take into account the wide variety of bird species that fly through the area of the planned project. In reference to bird migration the EIR states “the data collected during the 1 year avian use study suggests that the project is not within a major migratory pathway for diurnal(day time) migrants”. This statement epitomizes the fraud of the Hatchet Ridge Wind Project. Since the EIR has such a poor analysis on birds of prey it should be assumed there are other migratory and resident Special Status Species of birds not listed in the EIR.
The list of birds of prey published in the EIR at risk from this project does include many Special Status Species. Below is a list of birds of prey I am familiar with in the Hatchet Ridge Region. They are not listed in the EIR as Special Status wildlife at risk.
1) Rough-Legged Hawk – Risk not disclosed. Each year hundreds of these hawks pass through or winter in the region. At risk during migration and hunting.
2) Swanson’s Hawk – Risk not disclosed. This rare Hawk is a migratory visitor to the inter- mountain region. It is listed on the California Threatened Species List. At risk during hunting and migration.
3) Gyrfalcon – Risk not disclosed. The largest of all falcons. It is a rare migratory winter visitor from the Arctic. At risk during migration and hunting.
4) Tundra Peregrine Falcon – Risk not disclosed. These falcons migrate from the Arctic through the inter-mountain region every fall and spring on their way to and from South America. The inter-mountain area is a resting and hunting stop during migration. At risk during migration and hunting.
5) Red-Shouldered Hawk – Risk not disclosed. This hawk breeds in the riparian habitat along the Pit River and creeks of the inter-mountain region. It migrates to lower elevations during the winter. Most at risk during dispersal and migration.
6) Burrowing Owl – Risk not disclosed. Small owl that lives nests in the ground. Prefers grassy areas. Uncommon in the region. At risk during hunting, dispersal, and migration
7) Great Gray Owl – Risk not disclosed. The Largest North American owl and very rare. Listed as Endangered in California. There could be as few as 100 of these owls living in California . I have only seen three in the inter-mountain area. This Owl may nest in the region because of the different times of the year the three were seen. At risk during hunting, dispersal, migration.
8) Great Horned Owl – Risk not disclosed. Another large Owl that nests and resides in the region. At risk during hunting, dispersal, and migration.
9) Pygmy Owl – Risk not disclosed. A very small seldom seen Owl. This owl is a resident in the region. At risk during dispersal and local migration.
10) Saw-Whet Owl – Risk not disclosed. Uncommon resident of the inter-mountain region. At risk during hunting dispersal and migration.
11) Screech Owl – Risk not disclosed. Common resident of the inter-mountain region. At risk during hunting dispersal, nesting and migration. 12) Barn Owl- Risk not Disclosed. Uncommon resident of the inter-mountain region. At risk during hunting, dispersal and migration.
Below is a list of birds of prey listed in the EIR as Special Status Wildlife that are poorly discussed:
1) Anatum [American] Peregrine Falcon – Poorly discussed. This falcon lives and hunts in the habitat of the project site. There is a historical nest site located in the Pit River Canyon that has been known to the Department of Fish and Game for over 30 years. I discussed this nest site with former DFG Non Game Supervisor Bob Mallette, in his Sacramento office in 1977. At the time it was only one of 5 nest sites known in California and 2 of them were experiencing reproductive failure due to DDT. The hunting territories for their nest sites extend for 100-300 square miles. Historical nest sites are used for hundreds of years. Being located on a ridge above the nest site, the Hatchet Ridge Wind Project will have a major impact on the local population of Peregrine Falcons. This nest site will be abandoned due to collisions with the Hatchet Ridge Turbines. Parents mate for life. The few local Anatum Peregrine falcons are at great risk during hunting dispersal, nesting, and local migration. The loss of one or both parents will impact offspring survival at nest site. Loss of this Historical nesting site is very likely. The EIR falsely states “low likelihood for potential occurrence”.
2) American Kestrel – Poorly discussed. This small falcon lives and breeds in the region and migrates to lower elevations in the winter returning in the spring. Contrary to what is written in the EIR it is not very common in the inter-mountain region and will not represent the most commonly killed raptor species at the project site.
3) Red-Tailed Hawk – Poorly Discussed. Common to the inter-mountain region. This raptor will not represent the majority of raptor fatalities at the Hatchet Ridge Wind Project site as suggested in the EIR.
4) Bald Eagle – Poorly discussed. There are many well documented Bald eagle nest sites in the inter-mountain area. Many additional Bald Eagles also migrate from the north each year to winter in the inter-mountain region. The Eagles also migrate east to west and west to east. All Bald Eagles in the region are at risk during dispersal and migration. Offspring from nests from 25-50 miles away will all be at risk. Bald Eagles will die every year at Hatchet Ridge. Expect population declines.
5) Prairie Falcon – Poorly discussed. This falcon lives east and west of Hatchet ridge in the dryer habitats. More commonly seen in the region than the Peregrine Falcon, it migrates from the north and to lower elevations. Also has east to west migration in the fall and west to east migration in the spring. Most at risk during hunting and migration
6) Spotted Owl – Poorly discussed. Hatchet Ridge Project EIR discusses the California Spotted Owl and the Northern Spotted Owl. The dividing line for the distinction of the two species is Highway 299. This is an absurd classification drawn up by moneyed interests. In reality they are both the same species and I know of no other case in the world where a species is delineated right through the middle of a population gene pool that interbreeds, disperses and hunts the same general territory. Either way, the Project site will put the Spotted Owl at great risk and it is a Federally Protected Species. California Spotted Owls and Northern Spotted Owls will die from both sides of Highway 299 at the Hatchet Ridge Wind Project. These owls also do not just inhabit the forest canopy as suggested in the EIR. Marginal habitat is used by immature non- nesting Spotted Owls ,just as it is with the off-spring all birds of prey. Critical habitat is the habitat needed for success at a given nest site. Adults defend these territories to insure the food source for their young. Sadly adult Spotted Owls will be killed, offspring will be killed during dispersal, and the loss of one or both parents in the spring will impact offspring survival at nest site.
7) Golden Eagle – Poorly discussed. It does nest and lives year round in the project area contrary to the statements in the EIR. Hunting territories are vast and like the Peregrine Falcon can encompass several hundred miles. Eagles mate for life and hunt in pairs. On many occasions I have watched pairs of Eagles hunt the ridge lines of the inter-mountain area. One flying several hundred feet high, the other flying below as they hunt the ridge lines as a team. Golden Eagles will be killed and populations will decline at the project site because of hunting, dispersal of young, and local migration.
8) Merlin – Poorly discussed. A small rare falcon that is a seasonal migrant from Washington and British Columbia. Washington State considering threatened status designation. Hunts pockets of open space near forest edges. At risk during hunting, and migration. Hatchet Ridge EIR States no known occurrences in the project area. I saw these falcons every year in the region.
9) Long-Eared Owl – Poorly discussed. A medium size owl that nests and lives in the region. At risk during hunting, dispersal and local migration. I knew of one nest that had 3 week old young blown to the ground from a violent wind storm. I climbed the yellow pine and put them back in their nest.
In terms of impact, the Hatchet Ridge Wind project will have the greatest impact on the species with the lowest populations. In my opinion the Peregrine Falcon, the Spotted Owl and the Great Gray Owl are the most at risk species from this project. The Great Gray Owl is of extreme importance because of their low overall population numbers. The Peregrine has one nest site and maybe two in all of Shasta County. If there is only on pair a of a rare species like the Peregrine Falcon living in a several hundred square mile hunting territory, then the loss of 1 or 2 has a very high impact. The Spotted Owl has a dozen or two active nest sites in the region, but this area represents one of its last strongholds known for this Federally Threatened Species.
Of the three species that will be critically impacted, more Spotted Owls will be killed at Hatchet Ridge. This is because there are higher numbers living in the immediate area of the project. The project site is surrounded by “critical habitat”. Young owls will disperse into the marginal habitat around project site and adults will hunt at or near the site on a regular basis.
In general, expect serious population declines over time for all birds of prey within a 25 miles radius of this site. For example the Golden Eagle has been very closely monitored in a several hundred square mile area northwest of Altamont pass on the slopes of Mt Diablo. I have been told that these areas no longer have ANY eagles. No Eagles have nested there for years. In the past when these nest sites were active some of the offspring from these Golden Eagles were tagged and were later found dead at the wind turbines of Altamont Pass. The habitat for the eagles is still there but they cannot survive the turbines. Expect the same in the region of Hatchet Ridge.
When it comes to bird mortality all species in the vicinity of this wind project are at risk and every known bird species that uses the inter-mountain region will be on the species kill list. There will be well over 100 different bird species that will be killed at this site. The numbers killed will vary from species to species depending on population numbers and frequency of use. Some species will have few kill numbers but their populations are so low that the loss of an individual would have a high impact.
The Altamont Pass Wind Turbines located in the Bay Area kill an estimated 880-1300 birds of prey each year. It has been going on for nearly 25 years. The location of Altamont Pass is not nearly as critical as the habitat surrounding Hatchet Ridge. Hatchet Ridge is located in some of the most richest and diverse wildlife habitat in America. In fact the Hatchet Ridge Wind Project has the potential to have the highest bird mortality rate of any site in the world.
Disinformation and Cover-Up
The Hatchet Ridge Wind project is full of carefully chosen words, meaningless graphs and pseudo science. Examples of carefully chosen words used in the environmental impact report are “likely”, “may”,”could”, “unlikely”, “may possibly”, “potential” and “probable”. These words do not accurately describe what is to come. It is very obvious to me that the backers of the Hatchet Ridge Wind Project hired staff to write an EIR that would pass the scrutiny of the public and skirt environmental law. In reality, this project is as dangerous to birds as a school crosswalk located on Interstate 5 would be to children. The outcome would be obvious.
I feel there are many in the California Department of Fish and Game, as well as wildlife biologists working for the United States Forest Service, and the US Fish & Wildlife Service that would agree the Hatchet Ridge EIR is a false document. The problem with all this is the fear of losing your job. This is the reality of the world we live in. Qualified people cannot speak up out of fear of repercussions. I know this from my experience with Northern California Deer Management. I had many people in government positions talk to me if I promised not to disclose their names, I never did.
The wind power industry learned a valuable lesson from the astounding number of bird kills at Altamont Pass. Instead of pursuing better wind turbine designs that would limit bird kills, they chose a path of cover-up and deception. Today most Wind Turbine Sites have very limited access on private land and workers will loose their jobs if they disclose the truth. Outside agencies, Universities and wildlife groups all deserve the truth should have unlimited access to every Wind Turbine Site in America.
The Environmental Impact Document for Hatchet Ridge Wind Project is not in accordance with the requirements of CEQA and State guidelines. California Law clearly states that an Environmental Impact Report shall include identification of all significant effects, alternatives and potential mitigation measures. An EIR should be prepared and can be certified if it shows good faith effort at full disclosure of environmental information and provides sufficient analysis to allow decision makers with the information which enables them to make a decision which intelligently takes account of environmental consequences. Failure to comply with CEQA, to provide full disclosure of information during the CEQA process, which would result in relevant information not being presented to the public agency would constitute prejudicial abuse of discretion, leaving the project proponent open to possible lawsuit. The California Endangered Species Act emphasizes early consultation to avoid potential impacts to rare, endangered and threatened species and to develop mitigation planning to offset project losses of listed species.
The Hatchet Ridge Wind Project has NOT complied with California Environmental Law for three main reasons (1)Alternative safe wind turbine designs were never presented or discussed in the EIR, (2) the mortality impacts to all birds as well as birds of prey have not been fully disclosed or mitigated as required by CEQA and (3) The Hatchet Ridge Wind Project EIR does not show a good faith effort at full disclosure.
This problem will not change until the public is educated. Wind power is the future, but the killer designs of today are not. Promising new designs are already available and scholars and engineers will develop even better designs. Compounding the problem is a Government contaminated from the lobbying of wind power interests. Wind Power is a profit driven multibillion dollar industry. If people start saying, “No”, to this industry it will encourage the wind power industry to move in the right direction.
How many Wind Turbine sites have to go up before this madness stops? There needs to be a complete change in the wind power industry with Government regulations that limit the industry to wind power designs that are proven to be safe. All wind farms should be fully accessible to outside agencies, universities, and groups for the assurance of lawful compliance. It should also be a felony to discard unreported carcasses. Wind turbine operators also know that the longer the time between searches the better the chance scavengers like coyotes have to eat up the remains of the victims.
The people that stand to profit from the Hatchet Ridge Wind project live in mansions far away from the site. This project has tentacles that reach Wall Street, Washington, and all the way across the Atlantic. These profiteers will not be there to pick up the mangled bodies of the dead and wounded birds. They will not have to experience this horror. The citizens of Shasta County will.