Avian Mortality: Industrial Wind in Ecological Trouble

The U.S. Secretary of the Interior, Doug Burgum, posted a memorandum back in August calling on the agency to ensure compliance with the Bald and Golden Eagle Protection Act, “to ensure that our national bird is not sacrificed for unreliable wind facilities!”

A woman in a pink beanie gently holds a hawk while standing in front of wind turbines during sunset.

From Master Resource

By Sherri Lange

“Wind projects are known to kill eagles, and climate extremists in the Biden admin still greenlit scores of these projects. @Interior is enforcing the Bald and Golden Eagle Protection Act to ensure that our national bird is not sacrificed for unreliable wind facilities!” ( – Interior Secretary Doug Burgum, X)

The U.S. Secretary of the Interior, Doug Burgum, posted a memorandum back in August calling on the agency to ensure compliance with the Bald and Golden Eagle Protection Act, “to ensure that our national bird is not sacrificed for unreliable wind facilities!”

A memorandum from the U.S. Department of the Interior discussing compliance with the Bald and Golden Eagle Protection Act, dated August 4, 2025, outlining actions related to wind energy projects and eagle protection.

This is a long overdue threat to major wind projects that have been living a lie. After all, it was the Los Angeles director of the Sierra Club who coined the term “Cuisinarts of the Air” to capture the bird-chopping nature of industrial blades to the most treasured/protected birds of prey.

The “avian mortality” problem has a long history. May the new initiative finally (!) get to the bottom of things.

Government Neglect

The Burgum/DOI memorandum is significant given the failure of the Fish and Wildlife Service to act on the documented killing of Golden and Bald Eagles by industrial wind. The dodge of estimating electrocutions from power poles as a “mitigation” strategy in this area (see David Wojick’s analysis, below) is unacceptable.

North American Platform Against Windpower (NA-PAW) keenly awaits the new DOI priority. It is well known that the ability to “mitigate” eagle deaths include a lack of suitable and rigorous testing; incomplete implementation; limited technology; ignored interacting factors; site specific requirements; lack of collaboration.  Add: developer-led counting and methodology; use of less bird occupied testing sites; natural flow of natural processes where scavenging replaces/negates counting; massive level obfuscation including reference points to cats and cars and windows.

The actual numbers of kills are completely unknown. ABC (American Bird Conservancy) estimates some years ago (2021 article), 880 bats and 573,000 birds dead. Actual numbers, again years ago, referencing the Spanish Ornithological Society numbers, a valid coordinate to the USA, is between 13 and 31 million annually. Then add electrocution.

In a 2014 study, researchers estimated that 25.5 million birds are killed each year due to collisions with powerlines, and another 5.6 million are killed by electrocutions. Therefore, powerlines built exclusively to connect new wind facilities to the existing energy grid result in additional bird mortalities that should be factored in to the total toll in birds associated with wind energy development.

David Wojick of CFACT (Committee for a Constructive Tomorrow) has penned several succinct assessments of the problem. “Federal regulators concluded that the golden eagle population cannot survive increased kills from human activity,” he noted, “and also determined that wind turbines substantially increase eagle deaths.”

The feds then offered a solution only a bureaucrat could love: Don’t protect the eagles from turbine strikes, but “offset” their deaths by reducing electrocutions from power poles. Government then underestimated the number of power poles that would need to be made “safe” by a factor of as much as 241 and failed to save any meaningful number of eagles. See link for full report.  See here for executive summary.

Time for Action

NA-PAW expresses the hope that Secretary Burgum’s request to FWS is diligently applied, that no new wind factory permits are allowed; and retroactive closures of non-compliant wind factories are administered post haste.

Non-compliant yardsticks must be rejected. After-the-fact counts of dead birds and bats (in this case protected species, Golden and Bald Eagles) is not nearly enough. The corollary idea that reducing related power pole deaths can in some way “mitigate” wind turbine deaths is not credible.

NOTE: Mr. Wojick has not had a reply from his numerous emails to FWS.

CONTACTS:

Sherri Lange, CEO North American Platform Against Wind Power, Great Lakes Wind Truth; Vice President Canada, Save the Eagles International” Advisory Board Member, All About Energy

www.na-paw.org www.greatlakeswindtruth.org www.allaboutenergy.org

David Wojick dwojick@craigellachie.us

David Wojick, Ph.D. is an independent policy analyst and senior advisor to CFACT. As a civil engineer with a Ph.D. in logic and analytic philosophy of science, he brings a unique perspective to complex policy issues. He specializes in science and technology intensive issues, especially in energy and environment. As a cognitive scientist he also does basic research on the structure and dynamics of complex issues and reasoning. This research informs his policy analyses. He has written hundreds of analytical articles. Many recent examples can be found at https://www.cfact.org/author/dwojick/ Often working as a consultant on understanding complex issues, Dr. Wojick’s numerous clients have included think tanks, trade associations, businesses and government agencies. Examples range from CFACT to the Chief of Naval Research and the Energy Department’s Office of Science. He has served on the faculty of Carnegie Mellon University and the staff of the Naval Research Laboratory. He is available for confidential consulting, research and writing.

FWS is violating its own eagle-kill regulations

Every on-land wind project requires a permit to kill eagles from the U.S. Fish and Wildlife Service (FWS). These permits are based on an offset program in which eagle deaths are supposedly offset by saving the lives of other eagles by making power poles safer.

A bald eagle soaring through the air with its wings spread wide, set against a backdrop of green trees.

From CFACT

By David Wojick

A majestic golden eagle soaring through the sky, showcasing its detailed feathers and sharp beak, with a scenic mountainous background illuminated by a warm, golden light.
Eagle bird flying on sunset sky abstract background. Animal and freedom concept. Generative ai

Every on-land wind project requires a permit to kill eagles from the U.S. Fish and Wildlife Service (FWS). These permits are based on an offset program in which eagle deaths are supposedly offset by saving the lives of other eagles by making power poles safer.

In a recent study I found that this offset program is not working.

See the report here: 

https://www.cfact.org/2025/06/29/cfact-report-feds-fail-to-offset-wind-turbine-eagle-kills/

It turns out that failure to verify that this offset program is working is a deep violation of FWS’s own regulations. The regulations passed in 2016 clearly contemplate the possibility of offset program failure and require the FWS to track program effectiveness. FWS has done no such thing.

The U.S. Fish and Wildlife Service is not in compliance with its own permitting regulations, so permitting should stop until compliance is achieved. Existing permits to kill eagles should also be declared invalid, since they are based upon an offset practice that has not been shown to work and cannot work in its present form.

The offset program is called compensatory mitigation because the wind project owner pays to mitigate the eagle deaths caused by its project. The money is used to make power poles safe from electrocuting eagles, supposedly in numbers of eagles that are equal to or greater than the number killed by the project.

The permitting regulations require FWS monitoring of the effectiveness of compensatory mitigation, which they have not done. It is the law.

Here are the relevant regulatory requirements. The eagle-kill permits specify the required compensatory mitigation actions and measures:

“Section 22.220 Compensatory mitigation

(b) All required compensatory mitigation actions must:

(4) Use the best available science in formulating, crediting, and monitoring the long-term effectiveness of mitigation measures.

(7) Include mechanisms to account for and address uncertainty and risk of failure of a compensatory mitigation measure.”

The Regulation’s Environmental Impact Statement spells it out in more detail:

“Compensatory mitigation must be based on the best available science and must use rigorous compliance and effectiveness monitoring and evaluation to make certain that mitigation measures achieve their intended outcomes, or that necessary changes are implemented to achieve them.”

Even though the Regulations specifically refer to the risk of failure, FWS has done no effectiveness monitoring of the compensatory mitigation measures. Given that approximately 30,000 wind turbines have been permitted to kill eagles, this is noncompliance on an enormous scale.

Moreover, as I explain in my report, it is virtually certain that the compensatory mitigation program is highly ineffective. Here is why:

“The likely cause of this failure is FWS’s use of a wildly inaccurate electrocution death rate. As a result, the number of power poles made “safe” is just a tiny fraction of what would be required to create a legitimate offset. While FWS currently requires about 278 poles to be “made safe” per wind-killed eagle, the correct number, according to the results presented in this report, may be closer to 67,000.”

If FWS wants to use an offset program for wind turbines killing eagles, it must first do the research to establish the effectiveness of the offset measures. The present program is based on a single small 2010 study, with results so extreme as to be questionable.

This research must be done before offsets can be used to permit wind power killing eagles under the Eagle Protection Act. As things stand, FWS is deeply violating its own permitting regulations.

Wind power is buying eagle-kill indulgences

Every operating wind power facility has a US Fish and Wildlife Service (FWS) permit to kill eagles on an ongoing basis and many do kill eagles. Each permit depends on eagle-kill offset rules which appear to be false. If so, then the killing is illegal, a violation of the Bald and Golden Eagle Protection Act.

From CFACT

By David Wojick

Every operating wind power facility has a US Fish and Wildlife Service (FWS) permit to kill eagles on an ongoing basis and many do kill eagles. Each permit depends on eagle-kill offset rules which appear to be false. If so, then the killing is illegal, a violation of the Bald and Golden Eagle Protection Act.

The offset is called “compensatory mitigation,” which means the wind power facility pays the FWS or their agents to have their eagle killing offset by helping others live someplace else. Compensatory mitigation is used in other regulatory systems where it may actually work. For example, under the Clean Water Act you can destroy a wetland if you create an equivalent one someplace else.

The problem is that while it is easy to verify wetland offsets, it is impossible in the case of eagles. Moreover, it is extremely unlikely that these offsets actually work.

The issue is electrocution. By coincidence, the spacing of the wires on the standard power pole is just right for electrocuting eagles. These are the poles that line most roads and many streets in America, delivering power to the myriad of homes and businesses along the way. Some eagles occasionally die this way.

The wires on these poles can be restructured in a way that avoids electrocuting eagles and this is what wind power compensatory mitigation is paying for. The first problem is that there is no way to know how many eagles are not being electrocuted. The deeper problem is that there are likely many millions of these poles and the fraction being converted must be very small.

Note that this compensatory mitigation practice has been going on since at least 2016. It is discussed in a FWS report titled “Bald and Golden Eagles: population demographics and estimation of sustainable take in the United States, 2016 update” found here.

https://www.fws.gov/media/population-demographics-and-estimation-sustainable-take-united-states-2016-update

Here is the essence:

“When authorized take (killing) exceeds EMU (Eagle Management Unit) take limits, Service policy is that take must be effectively offset by compensatory mitigation such that there is no net increase in mortality. Currently, the only offsetting mitigation measure the Service has enough information to confidently apply in this manner is retrofitting of power lines to reduce eagle electrocutions….”

and

“Offsetting mitigation is mostly an issue affecting take authorization for golden eagles, as EMU take limits are set at zero requiring all authorized take to be offset.”

(Executive Summary)

In short the number of Golden Eagles saved has to at least equal the number killed. We do not know what that number is because while the FWS gets eagle kill reports from all wind facilities, that data is held secret to keep the industry from public scrutiny. There are published third-party estimates placing the number in the hundreds per year, but it could be higher.

How the FWS has determined the dollar amount of compensatory mitigation also looks to be a secret, as I can find nothing on it. The method is called Resource Equivalency Analysis, but searching the FWS site for that just yields a calculation spreadsheet.

How the FWS gets from these dollars to the actual saving of the required number of eagles’ lives is a mystery. I do not see how such an analysis is even possible, let alone verifiable. Where is the derivation and justification for this preposterous program with 160,000 MW of secret wind killing supposedly offset annually and 230,000 MW more in line?

That retrofitting some power poles can effectively offset the ongoing and increasing wind turbine slaughter of eagles seems completely unrealistic. Compensatory mitigation looks like a legal loophole designed to help the wind power industry avoid the Eagle Protection Act. The wind power facilities are just buying the indulgence of killing eagles year after year, more every year.

The Feds are hiding the eagle death data

Imagine there is an industry product that is killing thousands a year and the number is growing. The government is tracking it closely, while keeping the data secret in order to protect the product. Outrageous, right? But that is exactly the case with wind power killing eagles.

From CFACT

By David Wojick

North American Bald Eagle – patriotic symbol of the United States of America

Imagine there is an industry product that is killing thousands a year and the number is growing. The government is tracking it closely, while keeping the data secret in order to protect the product. Outrageous, right? But that is exactly the case with wind power killing eagles.

Every wind-killed eagle found at an industrial wind site is quickly reported to the federal Fish and Wildlife Service (FWS). Every year each site also submits an annual kill report to FWS. None of this data is publicly available.

The FWS eagle kill data is all a big government secret designed to protect the wind industry from public outrage. This has to stop.

The public has a right to know about all these eagle kills. In addition, this data would support research on ways to reduce the killing. For example, it has been suggested that painting the blades black would help the eagles avoid the blades. In fact, there are a lot of technologies that could be studied given comprehensive kill data.

It is no secret where all this kill data is. It is all in one big FWS database called the Injury and Mortality Reporting System (IMR), but all you can do is enter your kill data. You cannot look at anyone else’s data such as all the kills in a given wind facility or group of facilities.

Important wind facility groups might include those using a given technology, or in a specific county or congressional district. There are lots of analyses that might be important, but only FWS can see all this data. It is a government secret.

Another approach should be to ask for specific kill data, but that does not work either. For example, the Wyoming based Albany County Conservancy (ACC) sent FWS a Freedom Of Information Act (FOIA) request for some very specific kill data from four wind projects.

When the response finally came, FWS said ACC could only see 256 pages or 22% of the 1156 pages that corresponded to their query. The other 910 pages were secret. The available 22% did not begin to answer their questions. The wind-kill data is simply secret.

In addition, every wind site has a permit to kill up to a specified number of eagles a year before preventive action must be taken. None of this data is publicly available either. There is not even a public map or list of permitted facilities that I can find, much less permit data available for analysis.

Ultimately, there is no way to see how many kills are being allowed on a local or regional basis, or to analyze these kill allowances for impact. The national numbers may be in the tens or hundreds of thousands.

Nor is the method used by FWS to calculate these kill allowances available for analysis as far as I can tell. They may be allowing too much killing. I can find no published research on this topic.

There is another point of interest in the kill permits. The FWS permit conditions state that the kill reports only have to find about a third of the actual kills.

Here is the standard permit language: “(1) Fatality Searches. (a) You must achieve an average annual site-wide probability of detection (accounting for spatial and temporal coverage, as well as potential scavenging or detection bias) of at least 35% for every Five-Year period during the permit tenure.”

At this 35% detection rate, the actual kills would be roughly three times those found! So they know the report numbers are way low. It is built in. Any research or findings based on the kill reports needs to take this likely low ball error into account. If a facility says 30 eagles were killed, it is fair to assume it was more like 90.

Wind power is killing a lot of eagles. The federal government is tracking this destruction, but it is all a big secret. We have a right to know what is happening to our eagles.

Enviro-Spin Unravels: Eagle ‘Saving’ Technology Just Another Wind Industry Lie

The wind industry has just been caught out lying about a technology that was meant to prevent Eagles being slaughtered by their turbine blades. Cars, cats and skyscrapers don’t kill Eagles, but 60-80 m wind turbine blades with their tips travelling at 350 Kph routinely smash them out of existence.

From STOP THESE THINGS

Lucky survivor: Craig Webb with Tasmanian wedge-tailed eagle rescued post turbine collision.

The wind industry has just been caught out lying about a technology that was meant to prevent Eagles being slaughtered by their turbine blades. Cars, cats and skyscrapers don’t kill Eagles, but 60-80 m wind turbine blades with their tips travelling at 350 Kph routinely smash them out of existence.

The rampant slaughter of millions of birds and bats – includes rare, endangered and majestic species, like America’s iconic bald and golden eagles, and Tasmania’s extremely rare wedge-tailed Eagle.

Faced with outrage from real environmentalists, to date, the default response from the wind industry is to lie like fury and – when the corpses can no longer be hidden and the lying fails – to issue court proceedings to literally bury those facts (see our post here).

However, a couple of years back its spin doctors began seeding the narrative with the claim that the industry had developed a new, whizbang technology – IdentiFlight – that would prevent so much as a feather from being ruffled, by shutting off turbines as eagles, hawks and kites etc approached them.

Well, surprise, surprise, it turns out that the IdentiFlight system is yet another cynical ploy by the wind industry to placate those concerned about the fate of our apex avian predators, by pretending to actually care about the critters it’s been killing, en masse, for decades now. Matthew Denholm has this report on how the wind industry’s latest enviro-spin effort has unravelled, with a mounting pile of rare and endangered wedge-tailed Eagle carcasses to prove it.

‘Cutting-edge’ Tasmanian wind farm still a wedge-tailed eagle killer
The Australian
Matthew Denholm
17 August 2023

A wind farm with so-called “industry-leading” bird avoidance technology has killed at least eight endangered Tasmanian wedge-tailed eagles, prompting calls for an urgent moratorium on new turbines in eagle zones.

Cattle Hill Wind Farm in Tasmania’s Central Highlands uses IdentiFlight camera technology – which it describes as a “cutting-edge avian detection system” – to stop the wind turbines when birds approach.

However, the system – which is spruiked by the industry and regulators as the foremost solution to wind turbine bird deaths – has failed to prevent the deaths of at least eight eagles in less than four years.

The Australian understands that figure – confirmed by Tasmania’s Environment Protection Authority – includes five eagle deaths in the past 12 months.

“We should be very concerned about this because what we’re looking at here is the start of a planned huge industry,” said eagle expert and wildlife biologist Nick Mooney.

“Everybody has ignored rule 101. That is, if you’re worried about eagles, don’t put wind farms where there’s lots of eagles, and the overseas (scientific) literature stresses that.”

He was aware of 61 wedge-tailed eagles and five white-bellied sea-eagles being found dead or incapacitated during periods of formal mortality monitoring at Tasmania’s existing wind farms.

This was likely the tip of an iceberg, with some wind farms no longer required to monitor for bird deaths and formal monitoring restricted to areas under ­turbines, missing birds that die further afield after being struck.

He was aware of another nine large-scale wind farms proposed for Tasmania, which was concerning given that cumulative impacts of multiple wind farms was still not factored into federal environmental approvals.

Cattle Hill Wind Farm confirmed the deaths. It said its modelling had predicted its turbines would kill 14 eagles after four years and this was allowed under its permit conditions.

Mr Mooney said the system’s shortcomings and any solution should be independently verified.

He said he believed several turbines at Cattle Hill may need to be shut down in the interim, and the massive industry expansion in eagle density areas put on hold until an effective bird avoidance system was developed.

The wedge-tailed eagle recovery plan was due to be updated in 2010, but a promised revamp was yet to materialise, despite the proliferation of wind farms since.
The Australian

Kym Dixon with a not-so-lucky wedge-tailed Eagle, Waterloo SA.