WINDFARMS AND BIRDS - THE CHAUTAUQUA SCANDAL.
WINDFARM PROMOTERS TO PUT THEIR TURBINES ON MIGRATION FLYWAYS

Chautauqua, alongside lake Erie in Upstate New York, is a busy passage point for 100,000 raptors and 3 million night-migrating songbirds. A project has been presented to erect a string of 34 wind turbines across the flyway, on a ridgetop used by raptors, which include 2 breeding pairs of federally-protected bald eagles. The avian risk assessment presented by the promoter is an exercise in disinformation based on corrupt data.

OBJECTIONS TO THE CHAUTAUQUA WINDFARM PROJECT, N.Y.



Executive Summary


The Chautauqua avian risk assessment (ARA) is based on corrupt data. And it makes use of trickery to try and convince the reader that 34 wind turbines erected across a busy migration pathway will kill no more birds than 2 wind turbines located in a low migration activity area.

Based on scientific evidence from truthful monitoring studies, annual bird-kills at Chautauqua may actually reach the five-figure level. And 19 listed bird species are concerned, making this an illegal proposition.

The promoter suggests that we should approve his project so that more windfarms may be installed on migratory flyways: this makes Chautauqua a precedent-setter. Consequently, the attrition on the survival rate of endangered or threatened species will be multiplied by a factor, which is likely to be large. - Yet, cumulative effects are not considered in this ARA, in contradiction with the basic principle of conservation.

The ARA also pretends that the 2 breeding pairs of resident bald eagles do not fly in the project area: that was proven to be false by Ripley Hawk Watch observations in the spring of 2004 (27). And based on documented evidence, the rotors of the wind turbines are likely to kill these federally-protected birds.

Following are a few selected excerpts from my objections:

1.9.1.1 --- The supporting Spanish report starts with a misleading tribute to the wind industry: "wind farms have shown a spectacular growth because they have reduced the costs of energy production."

UK´s most prestigious engineering institution (23) calculated the cost of wind-produced electricity to be about 2.5 times that from conventional generating units, and 3.5 times for offshore. Thus, pretending that windfarms have reduced the cost of energy is not only a lie: it is an attempt to turn the truth around to pretend just the opposite - the correct word for this is: disinformation.

All of which puts the report at odds with objectivity, and illustrates the non-scientific nature of the document that supports the Chautauqua raptor mortality estimate.

1.9.1.3 --- In the Discussion we read: "Although we did not conduct any experiments of scavenger removal of dead birds, the number of dead birds found in our two visits per week was well below the average found in other studies of power lines using similar methodology."

This phrase is indicative of the shoddiness of the report, because:
- the low number of carcasses found does not justify the absence of scavenger removal (and searcher efficiency) experiments, quite the contrary.
- earlier, in the paragraph headed "Bird Mortality", we read: "The search frequency was at least once a week by experienced observers". This indicates that we cannot trust the "twice a week" used in the Discussion; and it naturally raises the question: what can we trust in this report?
- "well below the average found in other studies of power lines". - But this is NOT a study of power lines! Do the authors (or the editors?) know what they are talking about?

Yet, this appalling Spanish report is the cornerstone of the Chautauqua raptor risk assessment, which in turn pretends to open the gates to windfarms on migration pathways in the US, and in the world.

1.9.1.4 --- So in effect one team, possibly both, surveyed an area that had been previously cleared of carcasses by another team. This is unheard of, and clearly invalidates both studies.

1.9.1.5 --- Again in the Discussion: "Our work has clearly demonstrated that birds can detect the presence of turbines……. Soaring birds appeared to detect and to avoid the presence of the turbines better when these were functioning, based on changes in their flight direction."

And in the same paragraph: "Raptors appeared to be accustomed to the presence of turbines and many of the birds flew close to turbines".

In other words:

1) raptors avoid wind turbines.
2) raptors fly close to wind turbines.

If raptors only flew close to the turbines when these were not moving, the authors should have said so - for it would have been an important finding (although in contradiction with evidence from Altamont Pass and from around the world). But fudging about and writing contradictory statements such as these lack scientific merit.

1.9.2.1 --- Whereas the Chautauqua project is to be sited squarely on a migration pathway, the mortality surveyed by De Lucas concerns a windfarm located just OUTSIDE a migration corridor.

…………………… Therefore, using data from the Spanish windfarm E3 as a basis to assess the raptor risk at Chautauqua is unacceptable.

1.9.2.2 --- The wind turbines of Chautauqua will reach 121 meters into the sky, whereas the turbines from Spanish E3 are only 31 meters high (21 m tower, 10 m blades).

Few migrating birds fly below 31 meters agl. But 16,000 raptors at Chautauqua fly within 121 meters agl, which will be the height of the turbines.

Evidently, the Chautauqua consultant is comparing the incomparable, and using an unacceptable yardstick. This invalidates his conclusions.

1.9.2.3 --- For the reasons exposed, both reports are irrelevant: De Lucas being the worse by far. Yet, it was chosen to assess the impact of the Chautauqua project on raptor populations. - There is clear intention to deceive.


--------------------------------------


Objections (full text)


1.0 --- Objection is lodged that the proposed wind power plant (PWPP) would have a severe impact on migrating and resident bird populations, which include 19 listed species. Objection is lodged that the consultant´s assessment lacks scientific merit. Objection is lodged that the predicted maximum mortality of 110 birds per annum has been established using trickery combined with worthless yardsticks and references.


1.1 --- The avian risk assessment (ARA) under review was prepared by a consultant hired and paid by the promoter. Although wind industry followers would argue this is "normal" practice, this creates a conflict of interest, impairing scientific objectivity. To use an analogy, it is not unlike asking a poacher to present an estimate of the effect of his activity on the game population of a wildlife reserve.

The qualifications of the consultant do not make him any more objective than a lawyer in a criminal trial. His plea - the ARA in this case - cannot be objective: its purpose is to get the project approved.

Consequently, and unsurprisingly, the report presented by the consultant in this non-objective frame of mind predicts that his client´s wind machines will kill an insignificant number of birds.

To come to this conclusion, use is being made of a variety of deceitful methods. Some of these are exposed in this objection.


1.2 --- The ARA´s first misrepresentation is to minimize bird mortality at windfarms in general by comparing it to mortality by other factors.

The Executive Summary starts with this line: "It is well documented that mortality to avian species from wind turbines projects is minor when compared with other sources of avian mortality that are commonplace and widespread in our society."

This is incorrect. It is anything but "well documented". In effect, not a single monitoring study has been carried out by independent ornithologists. The few that exist have been either commissioned by the wind industry, or by organizations that stand unequivocally in favor of commercial windfarming.

As a result, we have a number of reports that predictably conclude to the insignificance of bird mortality at a number of WPPs. The scientific value of these reports is only as good as their underlying financial interest. But what commands the attention is the existence among them of a few reports that, in spite of being commissioned by vested interests, do reveal significant mortality.

Some of these were published in the early days of the rush-to-wind, before the special interests organized a tight control over the publication of such reports.

Some originated in countries where the controversy was still in its infancy, escaping the de-facto censorship which exists in some countries.

Some have been edited, falsified, and otherwise tampered with so as to eliminate incriminating evidence. But careful scrutiny was able to reconstruct the underlying evidence from the attempted cover-up (1).

Others concern Altamont Pass, an infamous WPP in California that already killed so many eagles and other protected raptors that new studies concluding to an insignificant mortality would only bring discredit to the industry.

These reports are examined in section 2 below. But first we shall address the argument presented by the consultant to the effect that cats, windows etc. kill more birds than wind turbines.

Here is what is being said in the Executive Summary, 6th line from the top:

" If non-collision-based sources of mortality are also considered, the relative mortality contribution from wind turbine projects (i.e., in relation to all non-wind project sources of morality) is even less (e.g., cat predation - 8 to 39 million bird deaths per year; pesticides, air pollution, and habitat loss/degradation to accommodate a growing human population - 72 million bird deaths per year)."

To make the point, a table of statistical data is provided that compares 10,000 - 40,000 windpower bird-kills to the millions from other causes.

Here are a few remarks that come to mind regarding this misleading comparison:


1.2.1 --- The ARA is comparing the result of 200 years of serious human encroachment upon the US environment - a considerable loss of habitat for wildlife, tens of millions of houses and buildings, nearly a billion windows, more than one hundred million vehicles, millions of domestic cats, over a million kilometers of power lines, etc. - with a new cause of bird mortality that is yet in its infancy: about 20.000 thousand wind turbines.

This is disingenuous.

Besides, the 10,000 - 40,000 annual bird-kill figure is improbable, and has not been cross-examined. If mortality statistics from the Cordelia wind turbine in Solano County, California, are taken as a yardstick, 20,000 wind turbines across the US would represent 54 x 20,000 = 1,080,000 annual deaths. And yet the Cordelia turbine is located in a low migratory activity area, so this figure is probably conservative. (section 2.6 below).

The rush-to-wind, if unchecked, will erect anywhere between 500,000 and 1,000,000 turbines across the US. To give an order of magnitude, and again using the conservative Cordelia yardstick, they would cause 27,000,000 to 54,000,000 bird casualties, yearly. Plus millions of bats, which also fall victims to these machines (20).


1.2.2 --- My second remark is that cats and windows do not kill eagles, ospreys, geese, swans, storks, falcons, hawks and other large birds, many of them from species that are protected by law. Wind turbines do (1).

And the survival of listed raptors is of particular concern. Over 1,000 golden eagles and 10,000 other raptors were killed already by the Altamont Pass WPP (see 2.1 below). The wind industry, and accommodating bird societies, pretends it is an exception; but other studies in Andalusia and in Navarra, Spain (1), evidence that raptors are indeed prone to have deadly encounters with the giant rotor blades. Other evidence from Germany and Australia confirm this propensity (7 & 19).

Hilltops, slopes and ridges are normally used by raptors for soaring, because of the presence of declivity winds. But these winds are the same that attract windfarm promoters. And as the number of wind turbines is set to increase exponentially in the next decades, their cumulative effect on the national raptor population will be severe. - Laws protecting these birds are effectively being violated when a windfarm is approved in raptor territory.

The added effect of wind turbines planted across raptor migration passage points like Chautauqua, other migration hotspots in New York State, or along the Appalachian range, may bring some species to near-extinction levels.

An aggravating factor is that there will be no safe place to release young specimens raised in captivity.


1.2.3 --- One of the main principles of conservation is to be aware of cumulative effects. Yet, the consultant´s line of argumentation is based on the opposite principle: it is all right for wind turbines to kill birds because so many are being killed by other human inventions. - This is resolutely anti-conservationist. It is also illegal, inasmuch as it is a criminal offence to kill listed species, as wind turbines routinely do.

And he has the arrogance to call this the "real life perspective". As if cynicism was a tolerable attitude when it comes to violating the law, impoverishing bird life in America, and threatening biodiversity.

An environmentally-conscious attitude would on the contrary focus on the cumulative effect of windfarms with other human causes of bird death: vehicles, domestic cats, windows, telecommunication towers, power lines, smokestacks, houses and buildings, poison, pollution, pesticides, loss of habitat, etc. These causes have brought a number of species close to extinction: adding another one will accelerate the decline of biodiversity.


1.3 --- The weakness of the ARA from a conservation point of view prompts the consultant to use arguments that are clearly out of his remit. Witness his attack on the negative effects of non-renewable energy:

" … infrastructure needs and related land use impacts, visual impacts, noise impacts, traffic impacts…" (Executive Summary, page 10, line 1)

It implies, a contrario, that windfarms have less of an impact.

This is pure disinformation. For these particular impacts apply to wind power plants to a quite higher degree:

- infrastructure and land use impacts: windfarms require many kilometers of new roads and tension lines to be built, as they are often located in wilderness areas.

- visual impact: apart from their lethal effect on birds and bats, this is probably the most notorious of all the negative consequences of wind turbines. 400 feet tall, stretching for miles across hilltops or other high ground, they affect views up to 20 miles away.

The Chautauqua project, which will produce less than 2% of what would produce a conventional power plant (24), will have a visual impact on a vast area (over 1600 square miles, potentially). Yet the consultant comes out lashing at the visual impact of other types of power plants. But these, not being built on hilltops, are much less conspicuous. - He has little regard for our mental acuity, which is an attitude normally associated with arrogance.

- noise impact: the above remark goes for this too. Windfarms create a nuisance to households up to one mile away (25); while people are protected from other industries by zoning restrictions.

- traffic impact: during construction, very large trucks will impair traffic while hauling the mammoth sections of the towers, and the 30-meter long-blades. Large earth-moving vehicles, and cranes will also be transported on the county roads. And depending upon the location of the quarry to be used, more traffic of heavy vehicles would cause more nuisance.

After construction, maintenance vehicles, cranes etc. will be present in the traffic for 25 years to come - or longer if new turbines are added and old ones replaced.


But the consultant continues, unabated, condemning traditional energy:

"…decreased energy diversity and reliability, fluctuating and increased consumer costs…"

Again this is disinformation. For if there is some truth to the fact that oil and gas is costing more and its supply is less than 100% reliable, it does not apply to coal. Secure and abundant is the supply of this fuel, and the "clean coal" technology gives it new possibilities. Besides, there are better alternatives to oil and gas than windpower: geothermal, wave and tidal, solar, CHP, energy efficiency, etc.

However, the speciousness of the argument lies mainly in that, a contrario, it implies that windpower is reliable and cheap. - But if there are two things windfarms do not offer, it is reliability and low cost:

- Reliability: whereas conventional energy generation can be ramped up or down at will to adapt to consumer demand, windpower generation cannot, depending as it does on the availability of wind on a minute-to-minute basis. That makes it the most unreliable source of energy.

Yet the consultant pretends that reliable energy is not reliable, in the hope to justify unreliable windpower. - Amazing.

The unreliability of wind also entails the need for 24-hour backup by conventional power, and the emission of additional greenhouse gases that negate those supposed to be saved by the windfarms (26).

- Low cost: windpower, as analyzed by the Royal Academy of Engineering (UK), costs about 2.5 times more than conventional power, and 3.5 times if offshore (23). Open or hidden subsidies, tax breaks, and a guaranteed purchase price higher than market only make windpower attractive to developers. For taxpayers and consumers, it is yet another burden. Denmark, which has the highest proportion of wind-produced electricity in the world (20%), has household electricity prices 100% higher than most European countries.

Conclusion: only intellectual dishonesty can explain such a deceitful line of argumentation. It does not bode well for the rest of the report.


1.4 --- Out of the 100,000 raptors and 3 million passerines that migrate over the project area yearly, some of them will land in it, or in the adjacent woods. Day-migrants normally do this at nightfall, night-migrants at dawn. But as shown in Appendix A observations were conducted " ~4 h during midday between 1000 h and 1500 h" & "~5 h of nocturnal migration observations (radar only) between 2100 h and 0300 h"

Result: the observers missed the landings and the take-offs. Their estimate of 16,000 raptors and 118,000 songbirds flying under 121-meter above ground level only reflects the peak of the migration hours, when birds fly at their maximum height in the sky. Which is to say the data supporting the mortality estimate is skewed in favor of the promoters´ interests.

There are other aggravating factors:


1.4.1 --- Strong winds will bring more raptors into the danger zone:

"In general, raptors flew lower during days with strong winds and higher during days with low wind speeds or calm conditions". - ref: page 5-38


1.4.2 --- Poor visibility is another point: there is ample evidence available from a variety of reports that, from time to time, weather conditions cause birds to collide with obstacles in large numbers, whatever the nature of the obstacle.

Example: "On 23 September 1982, 1,265 birds (30 species from an estimated kill of 3,000) were collected below chimneys at the Crystal River Generating Facility, Citrus County, Florida etc…. On 24 September, an estimated 2,000 birds were involved in chimney collisions". - Maehr, D.S., A.G. Spratt, and D.K. Voigts. 1983. Bird casualties at a central Florida power plant. Florida Field Naturalist 11:45-68. (available upon request).

If the smokestacks of a power plant can kill by collision 5,000 birds in 2 nights, how are we to believe that 34 wind turbines lined across a migration pathway used nightly by 3 million passerines will only kill 100 birds a year? Yet this is what claims the consultant.

Is poor visibility a weather condition never occurring at Chautauqua?

1.5 --- Even discounting bad weather, bird mortality will be high at the PWPP. Rigorous monitoring at a single wind turbine placed in a low migration activity zone at Cordelia, California, evidenced the death of about 54 birds a year (see 2.6 below). Yet the Chautauqua consultant wants us to believe that 34 of these machines lined across a migration hot spot will kill no more birds than twice the Cordelia number, i.e. the same as 2 turbines in a much less bird-active zone. - This is simply not credible.

Thousands of birds, possibly more than 10,000, may die yearly as 134,000* to 300.000** birds fly through the 34 wind turbines erected across their route - and as some land, take-off, circle, or make local flights in the area. Among them we have 19 listed species: 9 of raptors and 10 of passerines. The effect on American bird life and bird diversity will be significant. More so if we consider the expressed intention of the wind industry to place windfarms on many more migration pathways, as quoted in 1.7 below.
* 118,000 passerines + 16,000 raptors, as estimated by the consultant.
** 300,000 may be closer to reality, if we consider the landings and take-offs (see 1.4), and the windy and/or overcast days/nights (see 1.4.1 & 1.4.2).

1.6 --- We are dealing here with a plan that will cause, as collateral damage, the killing of quantities of birds protected by US laws. What the promoter is actually asking is a license to break those laws. So, quite logically, he pretends the killing will be insignificant in biological terms: 100 passerines and 10 raptors. And as most raptors are protected, he adds:

" Without the extreme conservatism applied (see Section 7.5.1), a total of 0.95 raptors are estimated to be killed each year (0.39 in spring migration and 0.56 outside the spring migration)." (ref: 7.8.1)

Manipulating statistics (see 1.8 below) to produce an alleged mortality of 0.39 bird per migration of 100,000 raptors is just what it looks like: an attempt to fool the law. For there is ample evidence that raptors are prone to die in great numbers where turbines are installed (see 1.2.2 & 2.1 & note 17)

1.7 --- The consultant makes no mystery of the intention of the wind industry to use Chautauqua, if approved, as a precedent to place more windfarms across migration corridors in northeastern United States.

Here is the relevant quote from his executive summary:

"The global no-action perspective evaluates the repercussions of precluding wind turbine projects in proposed locations of this type, i.e., regional migratory bird pathways. This would severely curtail wind power development in the northeastern United States…"

The promoter could not have said it more clearly: more migratory pathways are being targeted. Thus, if approved, Chautauqua will have even greater repercussions on both resident and migrating bird populations in northeastern United States. Yet the approach to such far-reaching consequences on bird life and biodiversity is piecemeal: we are being asked to approve this project on its own merits. - Nothing could be more irresponsible.

It is clear that, if bird mortality estimates are spuriously minimized in the Chautauqua ARA by two orders of magnitude, and if the project is approved, other applications using Chautauqua as a precedent will multiply the damage across the United States, and indeed the world*. - There is no better recipe for a biological disaster.

* Projects on migratory flyways are already in the pipeline in Scotland, England, Wales, France, Spain, Israel, Egypt, Morocco, Australia, etc.

In fact, what we have here is an inverted pyramid standing on a specious report. I repeat: a recipe for worldwide disaster.


1.8 --- To minimize the raptor mortality estimate, the consultant starts by alleging an "avoidance factor" of 99.99%, which he conveniently finds in another study commissioned by the wind industry:

"Erickson et al. (2003) estimated that more than 99.99% of birds (land birds) exhibited behavioral avoidance at three wind turbine facilities in the U.S." (chapter 6, page 6-25)

He then talks at length about "avoidance", conveying the idea that birds excel at dodging the rotor blades, which we know move at speeds up to 300 km/h at the tip (about 200 mph). (2)

One must be very credulous to accept such a controversial line of argumentation. For if birds were so good at avoiding wind turbines, why would so many get killed? - at Altamont Pass, at Oosterbierum, at Salajones, at San Gorgiono, at Cordelia, as well as in Belgium, in Germany (300 birds per turbine-year) , in Sweden (900 birds per turbine/year), etc.? (see section 2 below).

And if they can dodge blades moving at 200 mph, why do they get hit by cars and trucks on the highway? In the Executive Summary, a table reminds us that every year, in the US, vehicles kill 60 to 80 million birds. So where is the 99.99% avoidance in this case? Besides, vehicles are easier to see than rotor blades, which travel on an orbit, and hit the birds from above or from below, in their dead angle of vision.

1,000 federally-protected golden eagles and 10,000 other raptors killed at the Altamont windfarm; 6,800 birds in a single year at San Gorgonio; 6,450 birds in 12 months in Navarra etc. are here to prove that the 99,99% avoidance factor alleged by the consultant is not based on reality. It is just statistical manipulation with a purpose.

It is Disreali who said: "there are three kinds of lies: a white lie, an outright lie, and statistics".

11,000 dead raptors at Altamont are the reality; 99.99% avoidance is the statistic. Using this "avoidance" and other tricks, the ARA estimates that 0.39 raptor will die out of 100,000 flying above the PWPP, 16,000 of which under 121 meters agl (turbine height). In this case 16,000 is the reality, established by the consultant through visual and radar observation. And 0.39 is the statistic, established through manipulation of unreliable data.

The consultant gives us an idea of the way he conceives the avoidance factor: "the turbines of most modern facilities, such as the Project, occupy a very small percentage by volume of the PEA* (e.g., for this Project, less than 1%). Therefore, of the total number of birds in a WRA** that actually enter the PEA, the vast majority of them (for this Project, more than 99%) will have a no-risk experience, etc." - ref: 7.3.2 * project risk area ** wind resource area

Here is the flaw: the turbines are disposed in a line across the flying path of the birds. So most birds entering the project risk area (PEA) will have to cross that line. Using the total area in the calculation is trickery*, for the relevant percentage is linear: that of the rotor-swept flying space within the line of turbines.
* The consultant knows it, hence this footnote to wash his hands: "This generalized estimate assumes random bird flight through the PEA and random turbine distribution." - ref: footnote 60

The use of "random" is one of the keys to windfarm/bird statistical manipulation. Birds do not fly randomly. In this case they migrate across a ridge where 34 wind turbines will be deployed across their way; 16,000 of them will cross the line: there is nothing random in their flight, nor in the disposition of the turbines.

Nothing random either in the flight of raptors that follow ridges, a frequent behaviour amongst soaring birds caused by the presence of declivity winds that provide lift. And it is precisely along that ridge, using the same winds, that 34 turbines will rotate their blades at up to 200 mph at the tip - a perilous situation for the raptors. But statistics using random flight patterns and random turbine locations eliminate specific risks such as this one. Their effect is to produce greatly minimized, worthless mortality estimates.

Besides, some of the migrating raptors at Chautauqua do not cross the line of turbines just once: "For instance, during daylight hours, raptor targets usually exhibited circling behavior on the radar" and: "As expected, most raptors were headed in a northeasterly direction, were circling, or were making local movements." (spring 2003) ref: Appendix A, page 8

If they circle, and if they make local flights, they have more chances to meet with a turbine. And this is not taken into account in the ARA.


Then he proceeds to increase his avoidance factor from the 99% obtained by the random trick: " In addition, however, avian behavior - i.e., detection and active avoidance of the turbine and/or turbine rotor - reduces the fractional mortality still further." - ref: 7.3.2

And to calculate this "fractional mortality" (note the choice of words, and think of the 11,000 raptors killed by the Altamont windfarm - nothing "fractional" there. But disinformation selects its words carefully), he selects amongst reports from existing windfarms the one that suits best his purpose. In this case, an inappropriate and flawed report from Spain.

The result is an "avoidance rate" which is even in excess of the manipulated statistic of 99.99%, which would yield 1.6 raptors. Thanks to the Spanish report, he gets his estimated raptor mortality down to a truly miraculous 0.39 bird per migration - this out of 16,000 that will cross the deadly line of turbines.

All of this is devoid of scientific merit - more so as the supporting document from Spain is a shoddy piece of work, as we shall see now.


1.9 --- This is the Spanish report in question:

"MANUELA DE LUCAS , GUYONNE F.E. JANSS and MIGUEL FERRER Department of Applied Biology ,Estacion Biologica de Donana (CSIC ),Av .M Luisa s /n ,Pabellon de Peru ,E- 41013 Seville , Spain. (Received 10 July 2002; accepted in revised form 20 January 2003)"


We will see that it is of questionable scientific value, and irrelevant to the Chautauqua situation:


1.9.1 --- Questionable scientific value:

1.9.1.1 --- De Lucas et al. completed their fieldwork during the period July 1994 - September 1995). The field study was supported by "Ecotecnia S. Coop and by a fellowship grant from a group of seven Spanish wind developers".

The report was "accepted in revised form 20 January 2003", i.e. 7-8 years after the study was completed. Did the 7 developers, or Chautauqua Wind Power, or whoever got the report re-written and published in 2002-2004, have it substantially modified?

All we know is that it may have taken 6 months ( "Received 10 July 2002; accepted in revised form 20 January 2003" ) and that 6 people, apart from the 3 authors, participated in the redaction/editing ( "in particular F. Montoya, M.Castro and I. Sanchez. Dr Vincenzo Penteriani, Dr Carlos Alonso and Roger Jovani helped us with their comments that improved the manuscript" ) .

Whatever! One thing is certain: the influence of the final sponsor(s) is palpable throughout the report. For example: it starts with a misleading tribute to the wind industry: "wind farms have shown a spectacular growth because they have reduced the costs of energy production." (Introduction, paragraph 2).

Such mendaciousness is reminiscent of that exposed in 1.3 above. As we have shown, UK´s most prestigious engineering institution calculated the cost of wind-produced electricity to be about 2.5 times that from conventional generating units, and 3.5 times for offshore (23). Thus, pretending that windfarms have reduced the cost of energy is not only a lie: it is an attempt to turn the truth around to pretend just the opposite - the correct word for this is: disinformation.

All of which puts the report at odds with objectivity, and illustrates the non-scientific nature of the document that supports the Chautauqua raptor mortality estimate.

1.9.1.2 --- No scavenger-removal and searcher-efficiency tests were conducted. And we know from experience that these factors can change the results by an order of magnitude, or more - especially when searches are conducted weekly, as was the case.

Bodies of smaller raptors like kites or falcons may have been missed because of deficient search methods, or because they were removed by scavengers between the weekly visits. Even large birds can be removed: in Navarra, Dr. Lekuona witnessed a fox dragging a vulture away (1).

This, combined with the weekly visits, totally invalidates the study.

1.9.1.3 --- In the Discussion we read: "Although we did not conduct any experiments of scavenger removal of dead birds, the number of dead birds found in our two visits per week was well below the average found in other studies of power lines using similar methodology."

This phrase is indicative of the shoddiness of the report:
- the low number of carcasses found does not justify the absence of scavenger removal (and searcher efficiency) experiments, quite the contrary.
- earlier, in the paragraph headed "Bird Mortality", we read: "The search frequency was at least once a week by experienced observers" . This indicates that we cannot trust the "twice a week" used in the Discussion; and it naturally raises the question: what can we trust in this report?
- "well below the average found in other studies of power lines". - But power lines were NOT surveyed in this study. Do the authors (or the editors?) know what they are talking about?

Yet this appalling Spanish report is the cornerstone of the Chautauqua raptor risk assessment, which in turn pretends to open the gates to windfarms on migration pathways in the US, and the world.

The inverted pyramid we talked about at the end of 1.7 is in fact standing on it.


1.9.1.4 --- There is an overlap between the search periods of the De Lucas survey and those of another study conducted in 1993-94 by SEO/Birdlife for the government of Andalusia (6) (SEO: Sociedad Española de Ornitología, or Spanish Ornithological Society). - The SEO fieldwork on the E3 and PESUR windfarms was from 15 December 93 to 15 December 1994 (ref: 3.2 Methods); the De Lucas survey on E3 was from July 1994 to September 1995 (ref: 400 - Bird Mortality).

So here we are, however incredible it may sound: the two teams searched the same windfarm (E3) during 5.5 months.

And we read this in De Lucas: "Found carcasses were taken away to avoid double counting during subsequent surveys". - The SEO study does not specify its method on this particular point, but the likeliness of their removing the carcasses as well is not to be discounted.

So in effect one team, possibly both, surveyed an area that had been previously cleared of carcasses by another team. This is unheard of, and clearly invalidates both studies.

1.9.1.5 --- Again in the Discussion: "Our work has clearly demonstrated that birds can detect the presence of turbines……. Soaring birds appeared to detect and to avoid the presence of the turbines better when these were functioning, based on changes in their flight direction."

And in the same paragraph: "Raptors appeared to be accustomed to the presence of turbines and many of the birds flew close to turbines".

In other words:

1) raptors avoid wind turbines.
2) raptors fly close to wind turbines.

If raptors only flew close to the turbines when these were not moving, the authors should have said so - for it would have been an important finding (although in contradiction with evidence from Altamont Pass and from around the world). But fudging about and writing contradictory statements such as these lack scientific merit.


1.9.2 --- The report is irrelevant to the Chautauqua situation.


1.9.2.1 --- Whereas the Chautauqua project is to be sited squarely on a migration pathway, the mortality surveyed by De Lucas concerns a windfarm located just OUTSIDE a migration corridor.

Here is the statement we find in the SEO/Birdlife study, which covers the same E3 windfarm, in addition to PESUR: "The scarce effect of both windfarms studied on migration of soaring birds in 1994 is attributed to the fact that, although most birds have followed routes very near the windfarms, the location of the turbines are such that they do not interfere with these routes" .

This is quite different from saying that the birds know enough so as to avoid the turbines. It clearly states that the windfarms are just outside the actual migration routes.

It is certainly not the case at Chautauqua, where the consultant´s observations have concluded that, in the spring migration, 100,000 raptors fly above the windfarm site itself, 16,000 of which in the danger zone below 121 meters above ground level (agl). (ref: page 7-21, lines 4 to 9).

Therefore, using data from the Spanish windfarm E3 as a basis to assess the raptor risk at Chautauqua is unacceptable.


1.9.2.2 --- The wind turbines of Chautauqua will reach 121 meters into the sky, whereas the turbines from Spanish E3 are only 31 meters high (21 m tower, 10 m blades).

Few migrating birds fly below 31 meters agl. But 16,000 raptors at Chautauqua fly within 121 meters agl, which will be the height of the turbines.

Evidently, the Chautauqua consultant is comparing the incomparable, and using an unacceptable yardstick. This invalidates his conclusions.


1.9.2.3 --- The SEO/Birdlife study covered two windfarms and their related power lines: E3 and PESUR. The De Lucas study considers only E3, and no power lines.

Apart from not being comparable to Chautauqua because E3 is established outside the migration corridor, E3 has a bird-kill rate 5 times lower than PESUR, as measured by the SEO/Birdlife study (6) - part of it, no doubt, because of the double surveying as per 1.9.1.4.

It is revealing that the Chautauqua wind consultant chose not to consider the SEO/Birdlife study for his ARA. He selected De Lucas instead

I am not saying, however, that the SEO/Birdlife report would be relevant. It is not, first and foremost because of 1.9.2.1 (standing outside the migration corridor). Other reasons are the much shorter wind turbines, the flawed methodology (14), etc.

For the reasons exposed, both reports are irrelevant: De Lucas being the worse by far. Yet, it was chosen to assess the impact of the Chautauqua project on raptor populations. - There is clear intention to deceive.



2.0 --- Objection is lodged that evidence available from other studies has not been taken into account. Objection is lodged that the yearly avian mortality at Chautauqua will be in the thousands.


We saw in the first objection how a report devoid of scientific merit is being used as a basis for estimating the raptor risk at Chautauqua.

Another report, also likely to have been chosen for its alleged low mortality, was used to assess the risk to migrating songbirds.

As we know precious little about the data collected in that other study, and as we saw that the consultant is pursuing a non-scientific agenda, we have no choice but to look elsewhere to form an opinion.

In section 1.2 we wrote: "what commands the attention is the existence among them of a few reports that, in spite of being commissioned by vested interests, do reveal significant mortality". - Well, here they are:


2.1 --- Altamont Pass.

Several studies evidenced an on-going massacre at this very large windfarm near San Francisco. In 2002 ornithologist Grainger Hunt estimated, very roughly, that golden eagles were being killed at the rate of 40 to 60 per annum (3).

This was quite conservative - as shown in my critique of his report (28) . An in-depth study, performed by Dr. Smallwood more recently, puts the golden eagle mortality rate at 116 per annum, once adjusted for detection and scavenging (29).

Being a rich hunting ground free of territorial adults, Altamont attracts young eagles from all over California, and beyond. Dead eagles are replaced by the newcomers, who get killed in turn. The windfarm acts as a black hole, a population sink for eagles in the Western United States.

At the estimated rate of 116 per year, in excess of 2,000 eagles would have been killed by the turbines over 20 years.

And Dr. Smallwood has denied that this is exceptional, or an effect of the old lattice-tower turbines: bigger, tubular-tower models kill even more birds, including protected raptors (30). The mortality risk is the same at other windfarms. It is just that population abundance is greater at Altamont (31).

This is corroborated by the study made by Dr. Lekuona, at the request of the Navarre government, Spain: in one year, 368 tubular-tower turbines killed 7,105 birds, including 409 griffon vultures and 24 other protected raptors: golden eagles, eagle owls, booted eagles, sparrow hawks and kestrels - see section 4 below.

Regarding other raptors, Altamont takes a heavy toll as well: c. 500 yearly: hawks, owls, falcons, harriers, kites etc. (4). Cumulatively, that´s 10,000 "protected" raptors over 20 years - "at least", says Dr. Smallwood.

Other victims include doves, larks, ducks, blackbirds, gulls, swallows, herons, ravens, passerines, and bats (5).


2.2 --- Strait of Gibraltar.

In 1995, SEO/Birdlife (6) evidenced that 14 species enjoying protected status were being killed at two windfarms in Tarifa. Short-toed eagles, griffon vultures, eagle owls, kestrels, kites, egrets are included in the list.

In spite of being located slightly off the migration corridor, these two windfarms kill migrating as well as local birds. How many? This remains undetermined to be sure, because the report was trying to minimize the results. In an earlier analysis, I tried to expose this lack of objectivity:

"Here, the actual body count was: 65 large or medium-size birds for 34% of the 256 turbines surveyed "generally twice a week", and 54% of the tension lines surveyed once a week. Two short-toed eagles were among them, as well as 30 griffon vultures, 15 kestrels (3 of them on the endangered list), 2 eagle owls, 1 black kite, 1 "unidentified raptor" (it could be an endangered imperial eagle, for all we know) and one egret. Based on this, the summary estimates total mortality to be: 89 large and medium size birds – whereas a weighted extrapolation from 64 bodies on 34% of the windfarm area, and 1 on 54% of the tension lines area, would yield 190 bird carcasses for 100% of the area.
So, in effect, we are asked to believe that the estimated mortality is less than half the estimated body count." (14)

Other irregularities included the fact that, although small bird mortality was not surveyed, it was easy for the superficial reader to think all birds were included. Another was that scavenger and searcher-efficiency factors were only applied to kestrels (14).

But in spite of underestimating bird mortality at the Strait of Gibraltar, the SEO report did create waves in the ornithological community. After Altamont Pass, it had evidenced that windfarms were particularly dangerous for raptors, protected species at that.

However, the wind industry, and accommodating bird societies, decided to treat the Altamont and Tarifa examples as "exceptions". They still do, in spite of the rest of the evidence listed below, which they pretend to ignore.


2.3 --- San Gorgonio, California.

From a study by McCrary (1986) we get an overall estimate of as many as 6,800 birds killed per year, most of them nocturnal passerine migrants. (8)
Many waterbirds are on the list as well.

But strangely, 6,800 dead birds a year were judged to be "biologically insignificant", and the study was promptly forgotten.

No one bothered to ask what the cumulative effect would be, over thousands of future windfarms, over time, and over bird mortality from other causes.


2.4 --- Navarra, Spain.

In 2001, a report commissioned by the local government gave evidence that one third of the wind turbines in the region had made 7,150 victims in one year, including 409 griffon vultures, 24 eagles and other raptors, 650 bats and over 6,000 small birds, 40% of them migrants. (9)

A deceitful summary was added to the 150-page document, disclosing only 0.03 victims/turbine/mo; and the report was shelved. This falsification* of the results did not cause the Spanish Ornithological Society to denounce the fact in the press, let alone take legal action. Not even when an employee with a conscience leaked out the report to GURELUR, a local association, or when it was published on Internet by IBERICA2000.org.

*0.03 x 368 turbines = 11 victims/mo (not showing "per year" is another trick used to minimize the perceived mortality)

And the true mortality of 7,150 had to be reconstructed from various tables in the report, as it was not clearly spelled out.

Note: 7,150 / 368 turbines = 20 victims/turbine/year, substantially more than what the wind industry, and the bird societies, care to admit.

Dr. Lekuona, biologist and author of the field study, stresses that his mortality figures are conservative.


2.5 --- Flanders, Belgium.

"At 12 sea-directed wind turbines on the ‘East dam’ in the port of Zeebrugge the mean number was 39 birds/wind turbine/year." (10)

The overall bird-kill average for the Flanders windfarms studied by biologist Joris Everaert in 2001-2002 comes to 20 birds per turbine/year. The author adds that his figures are conservative.

Yet, when this study was mentioned by a comprehensive Birdlife report, only the bird species were mentioned, not the mortality rate. The protest of a few concerned individuals made them rectify in a subsequent edition - this and other misleading reportings.

It seems that many people have an interest in minimizing the windfarm bird-kill rate, including bird societies.


2.6 --- Cordelia, Solano County, California.

S. Byrne monitored a solitary wind turbine for one year, starting in 1992: "The mortality adjusted for scavenger removal and detectability suggests an actual mortality during the study as high as 54 birds."

"Findings indicated relatively low rates of waterfowl movements and nocturnal songbird migration over the wind turbine site". And the author adds: "Migration rates were considerably lower than those recorded in the eastern United States." (11)

This example is remarkable on various counts:

2.6.1 --- Searches were conducted 5 days a week during nocturnal migrations - once a week thereafter.
Too many studies are based on weekly, half-monthly, monthly, and sometimes quarterly searches. This allows for most dead birds and bats to disappear. Besides, scavenger-removal tests are not an exact science. Some biologists use road-kills that have been frozen for months; but well-fed scavengers patrolling the windfarm daily may show a preference for freshly killed victims bearing no human or road scent. - This could distort the results significantly.

Daily searches are crucial for obtaining reliable data. More so when rare species are at stake. For example: let us suppose three Bonelli´s eagles are killed at a given windfarm in a given year, and their bodies are removed by foxes (or windfarm employees) between, say, weekly searches. - The study will show zero Bonelli´s eagles among the victims. And even if top-quality scavenger-removal tests are conducted, the final result will still show: zero Bonelli´s. For a correction factor applied to a zero body-count comes out as nought.

Hence the importance of daily searches.

2.6.2 --- Being a solitary rotor, it should be easy for birds to avoid it - easier than a long string of turbines barring a migration flyway, like Chautauqua. But the high mortality evidenced by Byrne shows that even a single machine is not so easy to avoid.

Moving blades, at night, are difficult to see - worse still in overcast conditions. Rain and wind are aggravating factors: the first for visibility, the second for avoidance action. And during the day, raptors are not deterred but attracted by the wind turbines, because of the mice, rabbits, or ground squirrels that proliferate under them. Freshly moved topsoil makes for easy burrowing around the concrete bases, and cleared woodlands turn into grasslands - i.e. rodent habitat. This has been amply demonstrated at Altamont (5), and is contrary to the claim of the Chautauqua consultant regarding the 99.99% "avoidance factor".

It also invalidates his claim that wind turbines having ample space between them will cause insignificant mortality. - The Byrne turbine is a solitary one, with ample space around it for "avoidance".

2.6.3 --- The Byrne survey yielded the highest-known bird-kill rate in the United States. Yet, it was promptly forgotten - evidencing a will to downplay the negative effects of windfarms on bird life.

It is also in line with European findings (20 to 60 birds/turbine/year), whereas the US wind industry pretends that American windfarms only kill about 2 birds/turbine/year.

Unchallenged as they are by bird societies, wind promoters are able to go to extremes on the deception scale. Such is the case with Chautauqua, where the consultant has no qualms pretending that a string of 34 turbines on a ridge top across a busy migration flyway will kill a "maximum" of 110 birds/y. This compares with 54 birds killed by the single turbine studied by Byrne in an area with "considerably lower" migration activity.

If we applied the Byrne findings to the Chautauqua project:

34 x 54 = 1,836 dead birds/year

But at Cordelia, "Migration rates were considerably lower than those recorded in the eastern United States."

It is clear from this that the figure of 1,836 is not nearly adequate, for Chautauqua is a migration hotspot. A five-figure number is more likely, not including exceptional massacres due to poor weather conditions.

Yet the ARA predicts 110 dead birds/year. The gap is of two orders of magnitude. - We are being deceived by the consultant.


2.7 --- The Netherlands.

In the ornithology profession, the highest reference when it comes to evaluating windfarm survey results is Dutch biologist J.E. Winkelman. She gave her name to the "Winkelman formula", which permits to extrapolate body-counts into estimated yearly mortality. This is done through applying a number of factors - scavenger removal, searcher efficiency, etc. which are to be established for each windfarm by rigorously conducted tests.

In her 1992 study at Urk and Oosterbierum, she estimated mortality to be somewhere between 33,500 and 195,500 birds per 1,000MW (12).

If we were to apply these estimates to the 50 MW Chautauqua project, we would obtain 1,675 to 9,775 dead birds a year. But Chautauqua is a migration hotspot, so this extrapolation would be conservative.

What is more, the Dutch biologist emphasizes that her numbers are non-yearly figures: no observations were made during the summer period for both windfarms under study, or during the winter period at Oosterbierum. More victims undoubtedly fell during those periods, so the "yearly" figures are underestimates, she notes.

She also wrote (translation): " From the night-research at Oosterbierum it became clear that the real number of victims lies between the average calculated and maximum number of victim." - i.e. somewhere between 33,500 and 195,500 dead birds per 1,000 MW. Conservatively, colleagues in the profession use the figure of 46,000.

Everything points to a high four-figure/low five-figure death toll at Chautauqua.

2.8 --- Sweden.

From the PIER Study of the California Energy Commission (2002) (22):

"In a summary of avian impacts at wind turbines by Benner et al. (1993) bird deaths per turbine per year were as high as 309 in Germany and 895 in Sweden."

These bird-kill numbers are staggering. Little is known of this study, which is not available on the Net - yet another sign of the opacity around the subject of bird mortality at windfarms. And bird societies look the other way (otherwise they would publish all this data, and the reports themselves).

Applied to Chautauqua this would yield: 309 x 34 = 10,506 dead birds p.a.
and 895 x 34 = 30,430 dead birds p.a.


2.9 --- Germany.

There is a dearth of scientifically-conducted monitoring studies in Germany. Yet, the country has one third of the world´s installed generating capacity. - One is bound to conclude that the Greens, who are in charge of windpower policy in the coalition government, do not favour transparency.

It would be extreme to rely solely on the figure of 309 birds/turbine/year provided by the Benner report (see: Sweden, in section 8 above). But in the absence of other studies, what are we to do? Here is another approach:

Bernd Koop, based on monitoring studies conducted in Holland by Winkelman, estimated there would be 60,000 to 100,000 bird collisions per 1,000 megawatt installed capacity in his country - annually (13).

Applying his estimate to Germany´s 17,000 MW, we obtain: 1,020,000 to 1,700,000 bird collisions per annum. And the closer we are getting to territorial saturation, the lower the chances for migrating birds to find safe routes through the maze, especially if we add the deadly power lines.

Already, birds in Germany die in great numbers from collisions with 70,000 km of high-tension lines that criss-cross the country - 30 million birds per year is an extrapolation found in Hoerschelmann, Haack & Wohlgemuth, based on a study along 4.5 km of power lines - electrocutions excluded (14). - As windfarms need more power lines, this mortality will increase as well.

The cumulative effect of existing tension lines, plus tens of thousands of wind turbines, and yet more power lines to connect the windfarms to the grid, will be severe. The effect on migrating birds will be felt in other European countries, as well as Africa.

Note: had we used the Benner figure of 309 birds/turbine/year, we would have obtained: 5,253,000 deadly collisions per annum (assuming an average of 1 MW per turbine).

And the German government is hell-bent on doubling the country´s windpower generating capacity.


2.10 --- Discussion:


Much effort was made to put a lid on the above statistics. The Winkelman yearly figures, for instance, were converted into daily rates per turbine in order to mask their magnitude (15). In the Lekuona study, a summary was added that showed 11 victims per month, whereas the body of the report established annual mortality at 7,150 bird and bats, including 409 griffon vultures (16). These, and other examples of deception, have been analyzed and published (17).

The studies concerning Altamont, and the SEO/Birdlife report on Tarifa (Strait of Gibraltar) did reach some notoriety because of the high visibility of the raptors being victimized. But the wind industry chose to pretend they were exceptions that confirmed the rule, and ignored the rest of the evidence. Bird societies, who support that industry, by and large acted likewise.

And today we are facing a well-financed disinformation campaign. Non-objective, unscientific studies are being released to promote windfarm projects in areas that are vital to bird life.

The sad thing is that the industry gets away with it: witness the approval of a windfarm in South Gippsland* last month - in spite of two endangered parrot species, the eagles, and the migrating birds.
*Victoria, Australia.

It is to be hoped the American people will be more sensible, and sensitive to the value of their wildlife.



3.0 --- An objection is lodged that the effect of the Chautauqua WPP on the local population of bald eagles has been misrepresented.

3.1 -- The consultant did not make use of concrete data to determine the limits of the home ranges of the 2 pairs of resident bald eagles. This would have required a full year of observation, as eagles may use different areas of their ranges according to seasons.

He uses guesswork instead. Looking at the map, he tells us: the eagles will go here, here, and here; and they won´t fly over the project area because there is no body of water where they can fish. - He forgets that eagles have other behaviors besides fishing: like interacting with other eagles, courtship, territorial inspection and territorial defense, roaming (especially by juvenile and immature eagles), etc.

And indeed, the Ripley Hawk Watch spring report of 2004 (27) discloses: "On May 5th, five resident eagles cavorted in the area where the turbines are proposed. Of the 23 sightings of local eagles, 13 involved a clear potential conflict with the proposed turbines".

The consultant himself admits the weakness of his assertions: "it is impossible to conclude that a resident eagle will never fly over the Chautauqua WRA."
(ref: 7.10.11) - This is shameless deception, because he is in contact with the Ripley Hawk Watch: so he knows that local bald eagles frequently fly over the project area.

Then he continues with the hypocrisy: "eagles have excellent eyesight and maneuverability; thus, it is to be expected that they see the oncoming turbines and avoid them."

Yet he knows that eagles are prone to get killed by wind turbines. Mortality at Altamont, Tarifa, Navarra etc. have proved it (see 1.2.2 & 2.1 & note 17). Other raptors too have excellent eyesight, and many, like falcons and hawks, are even more maneuverable: but they get killed just as well (10,000 at Altamont alone).

So here we are given the full measure of his insincerity.

It does not matter that eagles have excellent eyesight: if they are focusing on a prey, a burrow, a harassing crow, another eagle, or whatever else captures their attention, they may not notice the blades until too late.

Conclusion: the consultant´s prediction that there will be no death of resident bald eagles is based on deceit. Raptor behavior, eagle-death evidence from windfarms around the world, and evidence from the Ripley Hawk Watch spring report, are being deliberately ignored.


3.2 --- As for the offspring from both nesting pairs, they will no doubt fly over the WPP as they exercise their wings and explore their surroundings. But nothing is said about the risk to juvenile bald eagles in this ARA. Yet they represent the future of the species.

It is not unreasonable to think that juvenile eagles will be attracted by the declivity winds along the ridge, where they would practice soaring and gliding. While doing so, their chances of coming into contact with the rotors will be high.

Adults too are liable to surf those winds, if only to gain height in order to glide away to another destination. The consultant did not consider this.

Wind turbines do not kill just golden eagles: white-tailed eagles, which are related to the American bald eagle, are falling victims to German windfarms (7), and wedge-tailed eagles to Australian windfarms (19), and short-toed eagles to Spanish windfarms (6). So when the consultant is saying that there is no record of bald eagles being killed by windfarms, it is irrelevant: bald eagles do not possess special windfarm-avoidance qualities. It may just occur that no windfarm has yet been placed in their habitat, or that windfarm employees have been quick to remove dead bodies.

Knowing this, and bald eagles being protected by law, it would be a criminal offense to authorize the Chautauqua PWPP.


4.0 --- An objection is lodged that the effect of the project on bats has not been assessed - in spite of bats being present on the radar observations forming the basis of this ARA. Are we to understand that the survival of bat species, some of which are on the endangered list, is of no concern to the decision makers that will state on the admissibility of this application?

Wind turbine blades kill bats in large numbers: 2000 to 4000 per annum at a 44-turbine WPP at Backbone Mountain in West Virginia (20).

5.0 --- An objection is lodged that the project will violate (1) the New York State Environmental Quality Review Act (SEQRA); (2) the State and Federal Endangered Species Acts (respectively, the State ESA and the Federal ESA); (3) the State and Federal Bald and Golden Eagle Protection Acts (respectively, the State BGEPA and the Federal BGEPA); and (4) the Federal Migratory Bird Treaty Act (the Federal MBTA or MBTA).

Because mortality for the 19 listed species will be very much higher than that alleged by the consultant - by one or two orders of magnitude. And because the consultant has been using corrupt data and deceptive tricks to dodge the law.

See developments in 1.2, and 1.4 to 3.2 above.

And see objection Nº 4 regarding protected bat species.

6.0 --- An objection is lodged that the cumulative effect has not been addressed.
Yet the consultant implies that this study will be used for further projects in migration flyways.

See comments in 1.2.2 & 1.2.3 & 1.7 above.





Mark Duchamp November 2004

Windfarm/Bird Research Manager
Proact International
Proact International

The negative effects of windfarms: links to papers published by Mark Duchamp (in English)
Energía eólica - enlaces a los artículos de Mark Duchamp (en Español)
Documents & Pictures (http://www.iberica2000.org/documents/dirlist2-main.asp?f=/eolica)
More Pictures (http://www.iberica2000.org/documents/EOLICA/PHOTOS)

REFERENCES

(1) - Birds and windfarms - Critical analysis of 4 reports on bird mortality at windfarm sites. - M. Duchamp (2003). Also available here: www.iberica2000.org/Es/Articulo.asp?Id=1223

(2) - Large turbines of the latest technology may have blades that rotate more slowly than those of older types; but they are much longer - 35 to 40 meters - and sweep much larger areas. They also reach higher in the sky, up to 125 meters high, affecting more species of birds and bats.

Furthermore, in spite of their slower rotation, speed at the tip is very high. Their increased length accounts for that. To give an example: General Electric model 1.5S has a rotor 70.5-meter-wide (diameter), and a generating rotor-speed varying between 11 and 22 rpm.

It is simple to calculate the tip-speed from this data:

70.5 meters x 3.14 (π R2) = 221.37meters circumference x 11rpm = 2435meters per minute x 60 minutes = 146 km/h

At 22 rpm (revolutions per minute), the tips go twice as fast:

70.5 meters x 3.14 (π R2) = 221.37meters circumference x 22rpm = 4870meters x 60 minutes = 292km/h

Large, fast moving blades that appear to turn slowly are a deadly trap to birds and bats.

Reference: General Electric webpage GE Also available here: http://www.gepower.com/prod_serv/products/wind_turbines/en/15mw/specs.htm

(3) - Report
(W. Grainger Hunt et al., Golden Eagles in a Perilous Landscape: Predicting The Effects Of Mitigation For Wind Turbine Blade-Strike Mortality, University of California, Santa Cruz. California Energy Commission Report, 2002.)
Also available here: www.energy.ca.gov/reports/2002-11-04_500-02-043F.PDF and:
www.iberica2000.org/documents/EOLICA/ALTAMONT/Altamont_GHunt_report.pdf

(4) -Report (http://www.iberica2000.org/documents/EOLICA/ALTAMONT/Dr.Smallwood_presentation.pdf) (K. Shawn Smallwood, Carl Thelander, and Linda Spiegel
Raptor Mortality at the Altamont Pass Wind Resource Area
Research funded by the National Renewable Energy Laboratory.)
Also available here: www.iberica2000.org/documents/EOLICA/ALTAMONT/Dr.Smallwood_presentation.pdf

(5) - Report (Thelander, C. G,Smallwood, K.S., Rugge, L. - Bird Risk Behaviors and Fatalities at the Altamont Pass Wind Resource Area - March 1998-December 2000, National Renewable Energy Laboratory Report SR-500-33829, December 2003.)
Also available here: www.nrel.gov/docs/fy04osti/33829.pdf

(6) - Report (http://www.iberica2000.org/documents/EOLICA/Tarifa_SEO_report.pdf) - SEO/Birdlife International: Effects of wind turbine power plants on the avifauna in the Campo de Gibraltar region (1995) by L. B. Jaque and R. M. Montes (especially: 4. conclusions).
Also available here: www.iberica2000.org/documents/EOLICA/Tarifa_SEO_report.pdf

(7) - German casual statistics (http://www.iberica2000.org/documents/eolica/casual_bird_mortality_record_germany.xls )

(8) - San Gorgonio (http://www.iberica2000.org/documents/EOLICA/6800_bird_fatalities.doc) - SEE "SOURCE": LINK TO REPORT AND GO TO PAGE 12 - McCrary (1986) Also available here: www.iberica2000.org/documents/EOLICA/6800_bird_fatalities.doc

(9) - Original, in Spanish (http://www.iberica2000.org/documents/EOLICA/LEKUONA_REPORT.pdf)
(J.M. Lekuona report). Also available here: www.iberica2000.org/documents/EOLICA/LEKUONA_REPORT.pdf
- Translation (http://www.iberica2000.org/documents/EOLICA/Lekuona_report_English_translation.doc) (translation of executive summary) ). Also available here: www.iberica2000.org/documents/EOLICA/Lekuona_report_English_translation.doc
- Birds and windfarms - Bird Genocide at windfarm sites (Comments in English) Also available here: www.iberica2000.org/Es/Articulo.asp?Id=1188

(10) - Report (http://www.iberica2000.org/documents/EOLICA/Everaert_report.pdf) J. Everaert report: Wind Turbines and Birds in Flanders: preliminary study results and recommendations (2003) - Joris Everaert, biologist, Institute of Nature Conservation (IN). Scientific Institute of the Flemish Community.
Also available here: www.iberica2000.org/documents/EOLICA/Everaert_report.pdf

(11) - Byrne, S. 1983. Bird movements and collision mortality at a large horizontal axis wind turbine. Cal-Neva Wildlife Transactions: 76-83. This study was conducted as a part of Pacific Gas and Electric Company´s performance monitoring program for a Boeing MOD-2 wind turbine.
- Not available on Internet.

(12) - Winkelman J.E., 1992a - De invloed van de Sep-proefwindcentrale te Oosterbierum (Fr) op
vogels - aanvaringsslachtoffers - section 5.6.8.
De invloed van de Sep-proefwindcentrale te Oosterbierum (Fr) op
Instituut voor Bos- en Natuuronderzoek (IBN-DLO), Arnhem.
- Not available on Internet.

(13) - Koop B., 1997. Vogelzug und Windenergieplanung. Beispiele für Auswirkungen aus dem Kreis Plön (Schleswig-Holstein). Naturschutz und Landschaftsplanung 29 (7): 202-207. - Used to be available on Internet here:
www.1-tra.de/Weiperfelden/windkraftanlagen_oder_voegel.htm

(14) - Birds and windfarms - Critical analysis of 4 reports on bird mortality at windfarm sites. SEE SECTION 2 - M. Duchamp (2003) Also available here: www.iberica2000.org/Es/Articulo.asp?Id=1223

(15) - Birds and windfarms - Critical analysis of 4 reports on bird mortality at windfarm sites. SEE SECTION 4 - M. Duchamp (2003) Also available here: www.iberica2000.org/Es/Articulo.asp?Id=1223

(16) - Birds and windfarms - Critical analysis of 4 reports on bird mortality at windfarm sites. SEE SECTION 1 - M. Duchamp (2003) Also available here: www.iberica2000.org/Es/Articulo.asp?Id=1223

(17) - Birds and windfarms - Critical analysis of 4 reports on bird mortality at windfarm sites. SEE ALL 4 SECTIONS - M. Duchamp (2003) Also available here: www.iberica2000.org/Es/Articulo.asp?Id=1223

- Windfarms - Red Energy - M. Duchamp (2003)
Also available here: www.iberica2000.org/Es/Articulo.asp?Id=1227

(18) - M. de Lucas, Janss & Ferrer (2002-2003): The effects of a wind farm on birds in a migration point: the Strait of Gibraltar. Department of Applied Biology, Estacion Biologica de Donana (CSIC) Seville, Spain. (Received 10 July 2002; accepted in revised form 20 January 2003). - Not available on Internet.

(19) - A. Chapman (2003) - Renewable Energy Industry Environmental Impacts:

Copy starts:
"I recently received the following information from members of the Eaglehawk Conservation Group in South Australia about the Starfish Hill wind farm, a facility developed by Starfish Hill Wind Farm Pty Ltd, a wholly owned subsidiary of Tarong Energy, based in Queensland.

· On 22 September 2003 the group said a Wedge-tailed Eagle had been killed at the Starfish Hill wind farm. This kill occurred before it was officially opened by Premier Mike Rann on Saturday 4 October 03.

· During the first week in October 2003 a second eagle was found dead under one of the turbines by the Tarong Energy Site Manager.

At least four months after the first turbine commenced operating and even after the last kill there was no official bird kill monitoring procedure in place. These two eagle kills are known only because members of the public have stumbled across them.

Copy ends

(20) - Document Merlin Tuttle, director of Bat Conservation International in Austin, Texas Also available here: www.friendsofthealleghenyfront.org/newsdown14.htm

(21) - Objection (http://www.iberica2000.org/documents/eolica/Objection_Lewis_SPA.doc) SEE SECTION E: Objection hastily removed by SNH
- M. Duchamp (2004), Objection to the Beinn Mholach (aka Pentland Road windfarm) - Also available here: www.iberica2000.org/documents/eolica/Objection_Lewis_SPA.doc

(22) - Report (http://www.iberica2000.org/documents/EOLICA/REPORTS/Dave_Sterner_2002.pdf) SEE PAGE 12 - D. Sterner, for the California Energy Commision (Dec. 2002)
A Roadmap for PIER Research on Avian Collisions with Wind Turbines in California. 12 Also available here: www.iberica2000.org/documents/EOLICA/REPORTS/Dave_Sterner_2002.pdf

(23) - RAE SEE TABLES 1 AND 2 - The Royal Academy of Engineering, March 2004 - `The Costs of Generating Electricity´ - Also available here: www.raeng.org.uk/news/temp/cost_generation_commentary.pdf

Table 1 - Cost of generating electricity for base-load plant (pence per kWh)
Gas-fired CCGT............2.2
Nuclear fission plant................2.3
Coal-fired pulverised-fuel (PF) steam plant..............2.5
Coal-fired circulating fluidized bed (CFB) steam plant...............2.6
Coal-fired integrated gasification combined cycle (IGCC).....................3.2

Table 2 - Cost of generating electricity for selected renewables (pence
per kWh) Without standby generation (a) With standby generation (b)
Onshore wind farm......a. 3.7................b. 5.4
Offshore wind farm.................a. 5.5 b................ 7.2

(24) - A huge footprint, a trickle of electricity (http://www.iberica2000.org/documents/eolica/a_trickle_of_electricity.doc) - Also available here: www.iberica2000.org/documents/eolica/a_trickle_of_electricity.doc

(25) - Noise (http://www.iberica2000.org/documents/eolica/noise)
Also available here: www.iberica2000.org/documents/eolica/noise/

(26) - Windfarms do not save on greenhouse gases. Also available here: www.iberica2000.org/Es/Articulo.asp?Id=1186

(27) - Hawkwatch (http://www.iberica2000.org/documents/EOLICA/REPORTS/Ripley_Hawkwatch_spring_report_2004.txt) - Also available here. www.iberica2000.org/documents/EOLICA/REPORTS/Ripley_Hawkwatch_spring_report_2004.txt

(28) - Birds and windfarms - Critical analysis of 4 reports on bird mortality at windfarm sites. SEE SECTION 3 - M. Duchamp (2003) Also available here: www.iberica2000.org/Es/Articulo.asp?Id=1223

(29) - DEVELOPING METHODS TO REDUCE BIRD MORTALITY IN THE ALTAMONT PASS WIND RESOURCE AREA - Dr. Smallwood & K. Thelander, Aug. 2004 - Table 3.11, 1st line:
"116.5 golden eagles p.a. adjusted for search detection and scavenging".
SMALLWOOD also available here:
http://www.energy.ca.gov/pier/final_project_reports/500-04-052.html

(30) - "It appears that factors other than tower type play more of a
role in whether a particular turbine is associated with one or more
fatalities, such as prey distribution about the tower’s base, physical
relief, and presence of declivity winds. Regardless, the number of
fatalities at tubular towers was higher than at horizontal lattice towers".
THELANDER (http://www.iberica2000.org/documents/EOLICA/ALTAMONT/Thelander_Smallwood_and_Rugge_final_2003.pdf) Bird Risk Behaviors and
Fatalities at the Altamont Pass Wind Resource Area - December 2003
Chapter 6: Discussion
Also available here: http://www.nrel.gov/docs/fy04osti/33829.pdf

(31) - "Adjusting for local relative abundance, the existing data indicate that most wind energy generating facilities have an equal impact on the local raptors."
DEVELOPING METHODS TO REDUCE BIRD MORTALITY IN THE ALTAMONT PASS WIND RESOURCE AREA - Dr. Smallwood & K. Thelander, Aug. 2004 - Table 3.11, 1st line: 116.5 golden eagles p.a. adjusted for search detection and scavenging.
SMALLWOOD - see CHAPTER 4 - PARAGRAPH 4.4.1
also available here: http://www.energy.ca.gov/pier/final_project_reports/500-04-052.html]

>> Autor: Mark Duchamp (02/11/2004)
>> Fuente: Mark Duchamp

(C)2001. Centro de Investigaciones y Promoción de Iniciativas para Conocer y Proteger la Naturaleza.
Telfs. Información. 653 378 661 - 693 643 736 - correo@iberica2000.org