The United States Fish and Wildlife Service has proposed guidance documents which will clarify how it will apply laws concerning wind energy. The West Virginia Highlands Conservancy has made these comments on that proposal:
The West Virginia Highlands Conservancy, a 45-year-old statewide membership organization devoted to the conservation and appreciation of the natural resources of West Virginia, and especially of its highlands region, offers the following comments on the Fish and Wildlife Service’s Draft Land- Based Wind Energy Guidelines.
(1) The Guidelines, when finalized, should be regulatory and binding on all commercial wind energy facilities. Experience with the interim guidelines since 2003 has demonstrated that a voluntary approach will not work. Proper enforcement of the Migratory Bird Treaty Act and Bald and Golden Eagle Protection Act requires that wind energy operators actually comply with, not merely consider, the Service’s advice at every stage of their projects.
(2) We appreciate the Guidelines’emphasis on the importance of siting wind energy facilities. Sites may be unsuitable for such facilities because of the cumulative effects of other nearby facilities as well as because of their discrete properties. The guidelines should state clearly that the Service will consider cumulative effects in making decisions about which sites ought to be avoided. Identification and assessment of cumulative effects should be acknowledged as a fundamental purpose of the Guidelines.
(3) By the same token, the Guidelines should encourage comprehensive regional planning including analysis of cumulative effects.
(4) Finally, we agree with other comments that call for the Service to address the problem of bias among consulting scientists. Several suggestions have been made for minimizing the apparent effect of payment on opinion. The Service’s best course is to rely on its own trusted staff but we realize that can’t always be done.
Here in the West Virginia Highlands, industrial wind energy projects have been proposed for nearly every ridge and mountain between our Maryland and Virginia borders. Case-by-case decisions, with no consideration of cumulative impacts, would have a ruinous impact on the local habitats and typical migrants that the Service is supposed to protect. We desperately need effective mandatory guidelines. We appreciate the opportunity to comment and look forward to working with you.
W. V. HIGHLANDS CONSERVANCY
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