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Hawk Migration Association Industrial Wind Turbine Siting and Monitoring Policy 

Author:  | Canada, Regulations, U.S., Wildlife

The Hawk Migration Association of North America’s official mission is to conserve raptor populations through the scientific study, enjoyment and appreciation of raptor migration. As a scientific, educational and conservation organization, HMANA collects data from hundreds of affiliated raptor monitoring sites throughout the United States, Canada and Mexico, and publishes a journal Hawk Migration Studies that includes data from participating hawk watches as well as articles on raptor conservation and other issues impacting raptors.

HMANA is concerned about the threat posed by industrial wind energy developments to migrating, nesting and wintering raptors. Wind conditions favorable for industrial wind energy projects may coincide with locations where concentrations of raptors occur. Industrial wind projects have been placed and are being proposed along known migratory flyways and near nesting and wintering concentrations of raptors. Some industrial wind energy developments have been clearly demonstrated to cause high mortality rates in a variety of raptor species, frequently as a result of inappropriate siting.

The National Environmental Policy Act (NEPA), the Endangered Species Act (ESA), the Migratory Bird Treaty Act (MBTA) and other federal legislation require federal agencies to carefully consider and assess the possible adverse effects in their projects and permitting practices. HMANA supports federal guidelines for the siting of wind power projects that are consistent with and at least as rigorous as provisions in the NEPA, the ESA, the MBTA and other existing federal legislation.

HMANA urges the establishment of final and mandatory design and siting standards-international, national and state-requiring that developers of industrial wind energy projects avoid known bird migration pathways and daily movement flyways, avoid features of the landscape known to attract raptors (such as ridgelines and coastlines), avoid areas formally designated as Important Bird Areas and avoid documented locations of any species protected under the federal Endangered Species Act. Such requirements are consistent with the U.S. Fish and Wildlife Service interim siting guidelines proposed in July 2003, which HMANA strongly supports. Unfortunately, delays in establishing permanent and binding regulations or guidelines have meant a lack of clear, unambiguous federal guidance to the state and local governments that must make decisions regarding the proper siting of proposed projects.

As articulated by the U.S. General Accountability Office report of 2005 and the National Academy of Science report of 2007, there is currently a lack of knowledge about the impacts of new-generation turbines on raptors. Accordingly, HMANA urges the establishment and consistent application of pre-construction and post-construction monitoring procedures for industrial wind power projects that are capable of improving the understanding of risk to wildlife posed by industrial wind power projects. Because knowledge of raptor migration and other behavior patterns is incomplete and raptor monitoring demonstrates high year-to-year variability in numbers of migrants at most sites, mandatory design and siting standards must require the collection of at least three years of pre-construction study data for projects where landscape features, natural history patterns or other data suggest raptor concentration is possible. Pre-construction studies of raptor behavior should not be limited to migration issues but should be comprehensive and include not only the risk associated with direct turbine strikes and possible avoidance behavior, but also terrestrial habitat degradation and its effects on nesting and wintering raptors, as well as the effect of such degradation on migrating raptors’ roosting needs.

When multi-year preconstruction studies confirm migration, wintering or breeding season concentrations of raptors in a particular area, then plans for development in that area should be abandoned and development forbidden; if such study shows minimal concentration of raptors, or if specific designs can be demonstrated to pose minimal danger to wildlife present in the area, then projects can be considered. In such cases, when developers have invested in diligent efforts to locate wind power development appropriately, it is still possible that post-construction monitoring might show an entire project or individual turbines to be particularly fatal to raptors: when this happens, turbines must be decommissioned or their operation suspended during the periods when the problematic turbines are found to be most destructive. Developers must agree to such remedial action as a precondition of project approval by federal, state and local permitting agencies.

HMANA urges that international, national and state and provincial standards for pre- and post-construction monitoring be promulgated and enforced that will make possible the scientifically valid assessment of risk associated with industrial wind power development. In light of the absence of binding standards for pre- and post-construction monitoring, monitoring protocols must be specifically designed for each project by qualified and independent consultants in collaboration with federal or national regulatory and conservation agencies (e.g. the USFWS), state or provincial agencies, appropriate non-governmental conservation and scientific organizations and independent experts. The protocol for this monitoring and the monitoring results must be peer-reviewed and publicly accessible.

HMANA supports alternative energy technologies if they can be shown to pose minimal risk to wildlife when appropriately designed, sited and developed. New approaches to wind turbine technology and design in particular might be possible in the near future that pose less risk to wildlife and habitat. HMANA urges investment in research into such new technologies and their development.

Adopted by the HMANA Board of Directors on July 8, 2008.

This material is the work of the author(s) indicated. Any opinions expressed in it are not necessarily those of National Wind Watch.

The copyright of this material resides with the author(s). As part of its noncommercial educational effort to present the environmental, social, scientific, and economic issues of large-scale wind power development to a global audience seeking such information, National Wind Watch endeavors to observe “fair use” as provided for in section 107 of U.S. Copyright Law and similar “fair dealing” provisions of the copyright laws of other nations. Queries e-mail.

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