Dear PUC Commissioners:
It has come to our attention that the results of the AWA Goodhue Wind pre-construction avian study completed by Westwood Professional Services do not accurately reflect the number of nesting bald eagles in the footprints of the AWA Goodhue Wind development.
… Westwood did not use updated information to form accurate conclusions in its avian study. We are aware that there may be as many as 10 occupied eagle nests in the development footprint and that these eagles could be adversely impacted if the LWECS are not appropriately sited. The USFWS recommendations for siting of structures in eagle nesting areas are as follows:
- To ensure that locations where project activities may disturb nesting bald eagles are completely and correctly described, it is necessary for the applicant to develop accurate and up-to-date information regarding the precise locations of bald eagle nests and other Important Eagle Use Areas.
- The Implementation Guidance for Eagle Take Permits under 50 CFR 22.26 and 50 CFR 22.27 indicates that because breeding home ranges of bald eagles can extend up to two miles from the nest, new potentially lethal infrastructure should be sited at least two miles away from Important Eagle Use Areas. Therefore, we recommend surveying all areas within two miles of proposed [LWECS and] transmission line routes. Nests of other migratory birds, especially other raptors and colonial nesting water birds [e.g., great blue heron, Ardeaherodias], should also be noted.
- Nests are only one component of Important Eagle Use Areas. Under the Code of Federal Regulations (50 Section 22.3) these areas are defined as “an eagle nest, foraging area or communal roost site that eagles rely on for breeding, sheltering or feeding, and the landscape features surrounding such a nest, foraging area, or roost site that are essential for the continued viability of the site for breeding, feeding or sheltering eagles.” Activities that disturb roosting or foraging eagles are prohibited under the Bald and Golden Eagle Protection Act. Consequently, we also recommend completed surveys for foraging, roosting or wintering areas within two miles of all potential [LWECS] line placements. Use of these locations by bald eagles can change throughout the year. Accordingly, we recommend a fall (pre-ice-up) and a winter (post-ice-out) survey to determine the location and use of these areas by bald eagles.
We strongly urge the PUC to require an avian study of this Important Eagle Use Area to comply with 50 CFR 22.3, 22.26 and 22.27. We further recommend that the PUC not issue a site permit until a comprehensive avian study has been completed so LWECS siting complies with federal recommendations for Important Eagle Use Areas. The information on active bald eagle nests provided by citizens should not be construed as complete or considered to be anadequate substitute for an actual avian assessment.
Tim Kelly, State Representative, House District 28A
Steve Drazkowski, State Representative, House District 28B
Download original document: “Letter to MN PUC: Inadequacy of Goodhue Wind avian assessment”
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