Comments on golden eagle errors in Wyoming’s wildlife action plan

The SWAP is a federal report required for federal funding that is done every ten years. It identifies 308 “Species of Greatest Conservation Need” which are grouped by priority based on a complex ranking system. For each species it also gives a summary of helpful voluntary protective actions that might be taken as well as challenges. Despite the title, it is in no sense a plan, more of a hope list.

From CFACT

By David Wojick

I submitted the comments presented below on the draft Wyoming State Wildlife Action Plan (SWAP), pointing out several serious errors in their treatment of golden eagles. They do not give the severely threatened eagles anything like the priority that is needed for their protection, especially from being killed by wind turbines.

The comments are in the jargon of the SWAP, so here is a brief introduction. The SWAP homepage is here.

The SWAP is a federal report required for federal funding that is done every ten years. It identifies 308 “Species of Greatest Conservation Need” which are grouped by priority based on a complex ranking system. For each species it also gives a summary of helpful voluntary protective actions that might be taken as well as challenges. Despite the title, it is in no sense a plan, more of a hope list.

Regarding the jargon, NSS is the Native Species Status, which is the basic ranking. Ba and Bb are degrees of risk. In Bb, the population is declining, but the factors causing that decline are not increasing, while in Ba, they are increasing. There are two levels of priority — Tier I is high, and Tier II is lower.

Here are the comments regarding errors in the treatment of golden eagles:

“The Wyoming State Wildlife Action Plan (SWAP) has three primary components — (1) various rankings plus (2) challenges and (3) suggested volunteer actions. Our concern is the golden eagle which is incorrectly characterized in several ways, as briefly explained below.

First, in Table 2 the status should be Ba and NSS2 not Bb and NSS3. The major limiting factor of wind turbines killing eagles is severe and will continue to increase rapidly given present plans. Bb and NSS3 are for cases where the limiting factors are not growing and this is incorrect for the golden eagle.

Second, the priority should be Tier I not Tier II because the golden eagle is on the verge of ESA threatened status and conservation is clearly feasible. A stated goal of then SWAP is “reducing the need for future listings under the Endangered Species Act.” The already modest golden eagle population has reportedly dropped by 30% in the last two decades as the wind turbines have proliferated. The eagle is clearly threatened and preventing further decrease should be a very high priority, not Tier II.

See my prior article for more details.

Third, the recommended volunteer actions fail to include the obvious action of reducing the number of new wind turbines erected in Wyoming. Most of the developers have numerous projects outside of Wyoming and they could easily voluntarily forego building here, in order to save the eagles. This volunteer action should be added to the list.

Fourth, the recommendation that roadkill be collected in order to reduce vehicular collision may be a bad plan. The most recent FWS estimate of golden eagle death rates places starvation at the top of the list, far above collisions. Eagles are being struck because they are feeding on the roadkill. It is entirely possible that collecting roadkill would cause more eagle deaths from starvation than it prevents from collision. This volunteer action should be removed from the list until the issue is settled scientifically.

Fifth, the challenges say there is both a lack of information and a lack of funding for protecting the golden eagle. The eagle and these sad lacks should be at least mentioned, or better to be discussed, in Chapter 3 as the golden eagle is clearly a species of great conservation need.

In summary the golden eagle should have a much high priority than the present draft provides. I will be happy to provide additional information on this issue.

Respectfully submitted,

David Wojick, Ph.D.

CFACT”

End of Comments

Given the widespread and growing concern over Wyoming golden eagles being killed in increasing numbers by wind turbines, it is both astounding and disturbing that the SWAP gives them such a low priority. See for example this.

The draft SWAP is fundamentally wrong and must be corrected. Wyoming must act to protect the golden eagles.

‘Eco-Friendly’ Energy Slaughtering Wildlife

Numerous studies by biologists and ornithologists are unequivocal in expressing rising concern about the slaughter of birds and other creatures by so-called eco-friendly technologies. Many of the researchers, while not opposed to the concept of alternative sources of energy, are dropping the pretense that wind and solar energy are benign.

From The CO2 Coalition

By Vijay Jayaraj

Numerous studies by biologists and ornithologists are unequivocal in expressing rising concern about the slaughter of birds and other creatures by so-called eco-friendly technologies. Many of the researchers, while not opposed to the concept of alternative sources of energy, are dropping the pretense that wind and solar energy are benign.

The fundamental flaw of these technologies is their low energy density. To generate the same amount of reliable electricity as a natural gas-fired generator or a nuclear power plant, thousands of acres of additional land are required by wind and solar. This is a matter of physics. Yet, in a rush to meet arbitrary “net zero” targets, the environment supposedly being protected is destroyed.

Wind and solar facilities devastate wildlife, destroy habitats, fragment ecosystems and leave ecological wreckage that extends far beyond what the green lobby cares to acknowledge. The narrative of politicians and well-heeled environmental NGOs – that wind and solar are the saviors of the natural world – is a lie. The data prove that these projects are not just displacing wildlife but are killing it on an industrial scale.

A shocking assessment reveals the extent of this encroachment. Wind and solar farms overlap with 2,310 threatened amphibians, birds, mammals and reptiles globally. This accounts for 36% of the world’s threatened species. The “green” utopia is being built on the graves of the vulnerable.

A study analyzing the footprints of “renewable” energy projects found that 2,206 operational facilities had degraded 886 protected areas, 749 “key biodiversity areas” and 40 distinct wilderness areas. The researchers project a 30% expansion of this footprint as natural refuges are further industrialized.

Another study did an examination of 84 peer-reviewed studies of onshore wind installations, documenting 160 cases of species displacement affecting birds, bats and various mammalian species.

For the golden eagle, a symbol of wild majesty, the impact is death. In the western United States, documented mortalities more than doubled between 2013 and 2024, from 110 to 270.

An assessment of 42 African raptor species documented an 88% decline over a 20-40 year period. The study identified wind farms as a major factor. In China, the rush for wind power has resulted in a nearly 10% decline in overall bird populations following the construction of wind farms. In Changdao County, located on a critical migration route for 330 bird species, local communities reported reduced bird populations and increased pest activity. In a stunning admission of failure, 80 wind turbines were demolished to save the ecosystem.

Recent research shows that in humid regions, large-scale solar plants cause near-total vegetation collapse. The panels block the sun, altering the microclimate and leading to soil instability. Without the roots to hold the earth, foundation of the ecosystem is lost.

In desert ecosystems, localized alterations caused by solar arrays disrupt the growth cycles of plants and the lives of microorganisms that keep the desert healthy. In China, photovoltaic development has caused fragmentation and habitat loss across more than 2,100 square miles of agricultural, sandy and grassy areas.

Solar development on intact landscapes reduces species richness. Perimeter fencing creates impassable barriers, trapping animals and preventing the genetic flow necessary for healthy populations.

In the United States, solar energy alone is estimated to cause between 37,800 and 138,600 bird deaths annually. Why? Because from the air, vast fields of solar panels look like water.

A study from Poland confirms this “lake effect,” showing that photovoltaic farms attract waterfowl due to water-like reflections. These birds descend, expecting a cool lake, and instead crash into scorching glass. The study identified 70 bird species at risk across six sites, with high-collision risk concentrated within 650 feet of the installations.

A Mojave Desert tortoise, an ancient survivor of harsh conditions, is losing to the solar boom. From 2004 to 2014, the species experienced a 39% loss in population. Industrial-scale solar has destroyed approximately 100,000 acres of their habitat. We are evicting a species that has lived in the Mojave for millions of years to make room for panels that will be obsolete in 20.

We must stop the reckless expansion of low-density energy projects in valuable ecosystems. The “green” transition is running red with the blood of the creatures we are supposed to protect.

Originally published in The Blaze on March 27,  2026.

Vijay Jayaraj is a Science and Research Associate at the CO2 Coalition, Fairfax, Virginia. He holds an M.S. in environmental sciences from the University of East Anglia and a postgraduate degree in energy management from Robert Gordon University, both in the U.K., and a bachelor’s in engineering from Anna University, India. He served as a research associate with the Changing Oceans Research Unit at University of British Columbia, Canada.

Wind power’s eagle-kill permits are a deadly failure, so permitting must stop

About 15 years ago, the US Fish and Wildlife Service (FWS) determined that the Golden Eagle population could not withstand an increase in human caused mortality. But there was a great queue of proposed wind projects that wanted FWS permits to kill these eagles under the Eagle Protection Act, which would certainly increase the kill rate.

Eagle bird flying on sunset sky abstract background. Animal and freedom concept. Generative ai

From CFACT

By David Wojick

About 15 years ago, the US Fish and Wildlife Service (FWS) determined that the Golden Eagle population could not withstand an increase in human caused mortality. But there was a great queue of proposed wind projects that wanted FWS permits to kill these eagles under the Eagle Protection Act, which would certainly increase the kill rate.

In response, the FWS created an offset program in which eagle deaths due to power pole electrocution would supposedly be reduced by an amount equal to the increased deaths due to wind turbines. We now know that this offset program has completely failed as there has been no reduction in electrocution deaths.

The likely cause of this failure is that the FWS uses an electrocution death rate that is extremely incorrect. As a result the number of power poles that have been made safe is just a tiny fraction of what it would take to create the desired offset.

The FWS should issue no more wind power eagle kill permits until this issue is resolved. Accurate power pole death rates need to be determined. Given there are over a hundred million poles in America, the offset numbers may be so high that the program is not feasible. In that case wind development must stop.

Here are some technical basics. In 2016 FWS published detailed guidance and assessment of the electrocution offset program, which had already been in operation for a few years. It is called the compensatory mitigation program because the wind facility getting the eagle kill permit has to pay for the power pole refits that supposedly offset that facility’s kills.

The 2016 best estimate of the electrocution death rate was 500 eagles a year. The projected eagle kill rate increase from the steadily increasing number of deadly wind turbines is a FWS secret, but it is privately estimated to be at least several hundred a year by now. If the offset program worked, the electrocution death rate should have dropped at least an equal amount. In fact FWS requires it to drop even more.

But a major 2022 study found the electrocution rate to still be around 500 deaths per year. The 26 author study is “Age-specific survival rates, causes of death, and allowable take of Golden Eagles in the western United States,” Ecological Applications, January 2022 and it is here:

https://esajournals.onlinelibrary.wiley.com/doi/10.1002/eap.2544

The death rate did not go down after six years, so the offsets did not work. Nor is there any reason to think they have worked since 2022 because the extremely low offset rate has not changed.

The number of power poles that must be made safe to offset each wind turbine death is the key number in the program. FWS uses 0.0036 deaths per pole. However, I estimate that there are around 120 million power poles in America. Given 500 deaths a year, that indicates a national average of about 0.0000042 deaths per pole.

The FWS number is a whopping 857 times the US average! On this simple account, the number of poles that need to be made safe will be over 800 times the number presently being done. In that case, it is no wonder the offset program does not work as the number of poles being made safe is trivial compared to what is needed.

Of course the reality is more complex, but the offset number(s) need to be made scientifically accurate before the program continues.

It is also very strange that the FWS has not made a Golden Eagle population estimate since 2016, or at least not a public one. About 100,000 MW of wind power, well over 30,000 turbines, have become operational since 2016. FWS should be tracking the population impact.

The dire need to carefully assess the efficacy and feasibility of the electrocution offset program before granting any new eagle kill permits fits in with the President’s executive order on wind power. Here is the key requirement abstracted from that EO:

“Review of the Federal Government’s Permitting Practices for Wind Projects

Sec. 2. Temporary Cessation and Immediate Review of Federal Wind Permitting Practices.

  1. In light of various alleged legal deficiencies underlying the Federal Government’s permitting of onshore wind projects, the consequences of which may lead to grave harm, the Secretary of the Interior and the heads of all other relevant agencies, shall not issue new or renewed permits for onshore wind projects pending the completion of a comprehensive assessment and review of Federal permitting practices. The assessment shall consider the environmental impact of onshore wind upon birds.”

No new eagle death offset permits can be issued under the Eagle Protection Act until the compensatory mitigation program can be made to work, if it can be.

Massive Wind Turbine Expansion Puts Golden Eagle on Path to Possible American Extinction as Annual Death Rate Increase Leaps by 50%

Shocking new statistical evidence has emerged that suggests the golden eagle could be on a wind turbine-induced glide path to extinction in the United States. Eagle deaths due to wind turbines in the western US were increasing by around 9% a year from 2013 to 2020, but this annual increase leapt to 13% from 2020 to 2024, a jump of 49% in the annual increase in death rate.

From The Daily Sceptic

By Chris Morrison

Shocking new statistical evidence has emerged that suggests the golden eagle could be on a wind turbine-induced glide path to extinction in the United States. Eagle deaths due to wind turbines in the western US were increasing by around 9% a year from 2013 to 2020, but this annual increase leapt to 13% from 2020 to 2024, a jump of 49% in the annual increase in death rate. Bird maps are said to show that the relative abundance of golden eagles across much of their western range has declined and areas where declines occurred, “align with areas where the most turbines have been constructed”. There are fewer than 40,000 golden eagles in the US and the recent acceleration of wind infrastructure “could have a significant negative impact on the golden eagle population”.

This data and associated conclusions have been published in a new Elsevier paper written by a group of American wildlife conservation scientists. They used a Bayesian collision risk model and inputted widely available data such as the eBird abundance maps. The Bayesian model is widely used in collision risk assessment and uses objective observations and relevant information. For obvious Net Zero reasons there is little research on wind turbine wildlife carnage, although it is known that millions of bats and birds, along with a huge insect tonnage, are crunched by ever larger and more numerous wind blades. Large birds such as eagles that hunt moving prey and rely on wind currents to fly are particularly at risk and the scientists estimate that 80,000 raptors (of all kinds) are killed by wind turbines across the US every year.

The discovery by the wildlife scientists of a recent statistical jump in golden eagle mortality is particularly disturbing. As the graph below shows, the average number of estimated deaths had risen from 110 in 2013 to 270 last year.

The scientists note that golden eagles are particularly vulnerable to mortality from wind turbines since their predatory nature places them at more danger than scavenging birds. The eagles are a slow-reproducing species and it is noted that even low levels of additional mortality due to wind turbines may have a “significant” effect on overall populations.

The danger is only likely to get worse, even if Net Zero mania in the US starts to tail off in the new Trumpian political environment. Writing recently in CFACT, David Wojick says that the threat to the eagles is “potentially enormous”. Current wind power-generating capacity is 160,000 MW, but there is a queue of interconnection applications amounting to an additional 230,000 MW. Much of this, the researchers note, is within the western range of the golden eagle.

The number of turbines is showing a significant increase but the rising rate of eagle mortality is also due to the massive growth in the areas swept by increasingly large blades. With blades now being produced that are as high as the Eiffel Tower, this increases significantly the wildlife killing zones. The scientists measure this as “hazardous volume” and state that it rose by 198% from 2013 to 2024 in the higher risk areas and 119% in the lower risk zones. This translates to an increase of the potential killing zone during this period from 17.3 km3 to 47 km3. During this time, the number of turbines increased by 26% but the hazardous volume rose much more, by 171%. This figure alone would seem to explain the concerning recent jump in estimated fatalities.

Is it fair to suggest that the golden eagle might be on a wind turbine-induced glide path to extinction in its western US habitat, and potentially other areas of the world that are blighted by massive nature-destroying turbines? The answer is yes, the threat is real, it is undoubtedly growing, and it is ignored by mainstream media and political discourse. Many governing elites are fixated by the idea that windmills can power a modern society, providing clean energy and delivering a more ‘sustainable’ world. But it is becoming clearer by the day that wind turbines have a devastating effect on the natural world, killing significant fauna that could eventually threaten the survival of many species.

Few are more adapt at turning a blind eye to ecological destruction than the local Hesse Green Minister Priska Hinz, who stated recently: “Wind energy makes a decisive contribution to the energy transition and the preservation of nature. It is the only way to preserve forest and important ecosystems.” Possibly the cynical laughter would not have been so great if she had not made the comments defending the destruction of forest in Germany to erect a number of 240 metre high wind turbines. What could have been a dirty little secret instead attracted worldwide headlines since the clearing involving the destruction of a reported 120,000 trees in the forest of Reinhardswald, the setting for the fairy tales of the Brothers Grimm. Worse, the turbines were due to be erected around the Sababurg ‘Sleeping Beauty’ castle.

Pierre Gosselin, who runs the German-based science site No Tricks Zone, was unimpressed, noting of green energy: “It’s not cost-free, it’s full of corrupt and unresponsive politicians who no longer care about democracy, and it certainly doesn’t make the environment better. It’s a nasty juggernaut of waste, fraud, corruption and ecological degradation – with dead birds, turbine vibration sickness, strobe dizziness and landscape pollution.”

Chris Morrison is the Daily Sceptic’s Environment Editor.

The Blade Stops Here: France Holds Wind Industry Accountable at Last

The recent shutdown of the Bernagues wind farm in Hérault, France, marks a long-overdue reckoning with the lethal impacts of wind energy on wildlife—particularly raptors like the golden eagle. On April 9, 2025, a French court ordered the entire site to cease operations for one year following the confirmed death of a golden eagle, a protected species, that collided with one of the farm’s turbine blades in January 2023. The decision also slapped Energie Renouvelable du Languedoc (ERL), the farm’s operator, with a €200,000 fine, half of which was suspended, and imposed an additional €40,000 fine on the company’s director.

From Watts Up With That?

By Charles Rotter

The recent shutdown of the Bernagues wind farm in Hérault, France, marks a long-overdue reckoning with the lethal impacts of wind energy on wildlife—particularly raptors like the golden eagle. On April 9, 2025, a French court ordered the entire site to cease operations for one year following the confirmed death of a golden eagle, a protected species, that collided with one of the farm’s turbine blades in January 2023. The decision also slapped Energie Renouvelable du Languedoc (ERL), the farm’s operator, with a €200,000 fine, half of which was suspended, and imposed an additional €40,000 fine on the company’s director.

This isn’t just a one-off judicial reaction. It represents a seismic shift in how the French legal system—and perhaps the broader public—are beginning to confront the uncomfortable truth about wind energy’s collateral damage. Despite the Green orthodoxy that surrounds renewables, wind turbines kill birds. And not just any birds. In this case, the victim was the breeding male of a golden eagle pair that had nested just three kilometers from the turbine site, a distance well beyond typical disturbance buffers used in wildlife protection.

Environmental groups hailed the court’s decision as a victory, but the implications go much deeper. For years, bird deaths caused by wind turbines have been ignored, downplayed, or dismissed as unfortunate but tolerable trade-offs in the race toward “net zero.” But the Bernagues case shatters that illusion. Here, a single incident carried enough legal weight to halt energy production for a year—an implicit admission that the risks to protected species may outweigh the supposed benefits of wind energy.

And this isn’t happening in isolation. Another French wind farm in Aumelas was also ordered to suspend operations just two days earlier, along with a €5 million fine against EDF Renewables. Add to this the December 2023 ruling from the Nîmes Court of Appeal ordering the demolition of the Bernagues wind farm for lacking a valid building permit, and a pattern begins to emerge: the renewable energy sector, long shielded from scrutiny, is now being subjected to long-overdue consequences.

What’s changing? In part, a growing recognition—backed by research—that wind farms are not as benign as their PR teams suggest. Two recent studies underline the broader threat to golden eagles. One, in Ecological Applications, shows that annual mortality already exceeds the threshold that eagle populations can sustain. Another, in Biological Conservation, tracks a rise in turbine-related eagle deaths in the western U.S., from 110 in 2013 to 270 in 2024. These are not rounding errors. They are statistical red flags.

And yet, the political and ideological machinery behind wind power continues to roll forward, impervious to facts. The push for “green” energy is not driven by data but by dogma. It’s a crusade rooted in carbon hysteria and the romanticization of renewable energy, regardless of ecological consequences or economic efficiency. Wind power has become the cathedral of the climate faithful, and turbines their spires—never mind the feathered corpses accumulating at their base.

This is not rational policymaking; it’s ideological fixation dressed up as science. If the goal were genuinely to balance human needs with environmental stewardship, the conversation would look very different. We’d be assessing energy sources on their real-world merits—reliability, cost, land use, ecological impact—not blindly throwing subsidies at whichever technology aligns with green slogans.

France’s court system has done what most governments have failed to do: impose real accountability on an industry that’s been operating with impunity. The Bernagues decision should serve as a precedent, not an anomaly. It’s a milestone in holding the wind industry to the same environmental standards it pretends to uphold. And it invites a critical question: if even the eagle—the emblem of nature’s majesty—isn’t safe from the blades of climate dogma, what exactly are we saving?

H/T alexander v

Two new studies imply the Golden Eagle cannot survive more wind turbines

The Bald and Golden Eagle Protection Act specifically says that the Fish and Wildlife Service (FWS) cannot issue more “take” (that is kill) permits than the population can survive. Two new studies together imply that the golden eagle wind-kill taking is at that limit or beyond.

Eagle bird flying on sunset sky abstract background. Animal and freedom concept. Generative ai

From CFACT

By David Wojick

The Bald and Golden Eagle Protection Act specifically says that the Fish and Wildlife Service (FWS) cannot issue more “take” (that is kill) permits than the population can survive. Two new studies together imply that the golden eagle wind-kill taking is at that limit or beyond.

Clearly FWS must stop issuing new wind turbine take permits until it rigorously assesses this situation. No new wind turbines should be erected. Some presently in operation may have to shut down. Fortunately, new eagle kill permits are presently on hold under the President’s Executive Order, but we are also talking about the law.

The primary area of concern is the western range of the Golden Eagle. This runs from Montana, Idaho, and Washington down to the Mexico border. Note that the eagles often migrate north to spend the summer in Canada, so the more northern states see a lot more than their local winter populations.

However, the entire US population is only about 30,000 eagles, down from an estimated 80,000 in 1980, and they are found everywhere. Thus the entire country might be in need of care.

The first study is “Age-specific survival rates, causes of death, and allowable take of Golden Eagles in the western United States,” Ecological Applications, January 2022 and it is here.

The primary point is to estimate the allowable take (death rate from human action) under the law and compare that to the present death rate. Their allowable take estimate is a range with a median of 2,227 deaths per year, while their estimated actual take is actually greater at 2,572 annual deaths.

These are very rough numbers, so the basic point is it looks like we are already at the allowable take. Adding a lot of eagle-killing wind turbines could put the Golden Eagle on the illegal road to extinction. Clearly, caution is called for.

The second study attempts to quantify the wind-killing threat. The study is “Estimated Golden Eagle mortality from wind turbines in the western United States,” Biological Conservation, February 2025, here.

Their primary conclusion is this: “Anthropogenic mortality is the primary cause of death in adult Golden Eagles and recent trends indicate their population may be declining. If the current rate of growth of the wind energy industry continues, it could have conservation implications for Golden Eagle and other raptor populations.”

They use a collision risk model that combines the spatial population density of the eagles with the spatial density of the spinning blades. This captures the fact that in addition to wind turbines getting more numerous, they are also getting much bigger.

As an aside, I proposed a roughly similar approach to quantifying the increasing risk to whales from offshore wind development. Here the wind projects force the whales into areas of greater ship traffic.

See my “The whale killing study the Feds are afraid to do” here.

Also “How to kill whales with offshore wind” here.

Neither of these eagle studies is definitive; far from it. In fact, some of their numbers disagree. The point is that the Fish and Wildlife Service must itself conduct a rigorous assessment of the allowable take for Golden Eagles and the potential impact of additional wind development on that take.

The Bald and Golden Eagle Protection Act requires such an assessment because the FWS is prohibited from approving a cumulative take that exceeds the allowable limit. This takes us beyond the wind power executive order which also calls for an ecological assessment of wind power. It is the law.

The threat to Golden Eagles from wind is potentially enormous. Wind power generating capacity today is about 160,000 MW. The queue of new wind interconnection applications is around an incredible 230,000 additional MW. Much of that is within the western range of the eagle, and they are also found in every continental state.

The Fish and Wildlife Service simply must address this huge potential threat before any new take permits are issued to wind turbine facilities. Moreover, the assessment and underlying data must be made public under the National Environmental Policy Act (NEPA). This is clearly a NEPA action.

Lift the veil on wind power killing eagles

Every land based wind facility in America has a permit to kill a certain number of eagles every year. What these kill numbers add up to is a secret that should be public information. Is it hundreds, thousands or tens of thousands?

Eagle bird flying on sunset sky abstract background. Animal and freedom concept. Generative ai

From CFACT

By David Wojick

Every land based wind facility in America has a permit to kill a certain number of eagles every year. What these kill numbers add up to is a secret that should be public information. Is it hundreds, thousands or tens of thousands?

Given these numbers we can decide how to limit them. We also need better data on actual kills so it is time to lift the veil on wind power killing eagles.

First the basics. CFACT collegian Maggie Immen puts the issue well in comments on a proposed Wyoming wind facility. She writes this:

“Wind turbines are a documented threat to bird populations, particularly raptors like golden and bald eagles. Estimates suggest that wind farms kill at least 150,000 birds annually in the U.S. alone. Wyoming, a crucial migratory corridor, is especially vulnerable.

The Rail Tie Wind Project, planned for Albany County, would place turbines dangerously close to golden eagle habitats. Wildlife biologist Mike Lockhart, a Laramie resident, warns that official bird fatality counts are likely underestimated since scavengers quickly remove carcasses before they can be recorded.

Adding to these concerns, federal regulations permit a set number of eagle deaths per wind project through incidental take permits. However, experts argue that these limits rely on flawed data that underestimate real mortality rates. Since eagles reproduce slowly, even a small number of fatalities can have devastating effects on their population. Yet regulatory agencies continue approving projects like Rail Tie without adequately addressing these risks.”

See which includes great links to more data.

When it comes to eagles and onshore wind projects there is a glaring deficiency that should be corrected — the killing is unlimited. Every project gets a permit, so the total number of allowed deaths just keeps going up and up as more projects come online. Surely this is wrong.

There should be a strict limit to the cumulative total number of kills allowed each year. In the regulatory world this is called a cap on killing. We see something like this sort of cap in the issuance of State hunting licenses for large game. It could be called the wind power bag limit.

The issuance of permits for new wind projects, if any, would be based on the total kills allowed under the existing permits. If this total was less than the cap then permits could be issued in the amount of the difference. These permits might be auctioned off, or allocated by lottery, or something else. The cap on killing needs to be strictly enforced. If a project kills its allotment then it has to shut down for, say, the rest of the year or however the cap is set.

In contrast the Biden Administration made it much easier to get eagle killing permits which were then not enforced. They created what is called a General Permit meaning individual projects did not have to submit lengthy project specific applications. The project basically just registered and paid a nominal processing fee. The requirement that reporting of actual kills had to be monitored by an independent third party was also dropped.

These ill conceived policy changes need to be reversed. The allowable kills need to be limited and the kill reports made accurate.

In addition to the allowable kill numbers the eagle death reports should be made public. People need to know that wind projects in their county or state are killing eagles, where and how many. They also need to know how many more kills are proposed.

Given good eagle kills information we can make informed decisions about capping and reducing these deaths. Lift the veil on wind power killing eagles.

Rock Creek I and II Gen Tie Remand

Rock Creek I and II is a proposed 590MW (nameplate) wind plant spread across 43,000 acres of private land. 

From Watts Up With That?

Kevin Kilty

A large wind energy plant being built for PacifiCorp unit Rocky Mountain Power in Carbon and Albany Counties, Wyoming has encountered a small hiccup in its efforts to tie the energy plant to Aeolus substation near Medicine Bow, Wyoming. A Laramie resident, who is also a wildlife researcher, and a local advocacy group for wildlife and historical preservation filed suit against The Bureau of Land Management (BLM) for their decision to allow the Gen Tie line for the project to cross BLM ground without either proper environmental review or adequate public input. BLM has remanded their decision without vacatur for further review. The press release can be found here.

Background

Rock Creek I and II is a proposed 590MW (nameplate) wind plant spread across 43,000 acres of private land. Permission to build the project had been granted by County Commissioners in June 2022, but the project has suffered significant delays in terms of delivery dates of components. While the project itself is on private land, the Gen Tie line crossed BLM ground in at least one place (see Figure 1 drawn from the only map known from permit applications).

Figure 1. Map showing a portion of Rock Creek I and II projects with arrows to Gen Tie and collector lines. Above ground collection lines and Gen Tie lines are as great a hazard to eagles as wind turbines themselves.

The National Environmental Protection Act (NEPA) seems pretty clear about such a situation. From the Citizen’s Guide to the NEPA:

“…NEPA’s procedural requirements apply to a federal agency’s decisions for actions, including financing, assisting, conducting, or approving projects or programs; agency rules, regulations, plans, policies, or procedures; and legislative proposals. NEPA applies when a federal agency has discretion to choose among one or more alternative means of accomplishing a particular goal…”

“…When a company applies for a permit (for example, for crossing federal lands or impacting waters of the United States) the agency that is being asked to issue the permit must evaluate the environmental effects of the permit decision under NEPA….”

Certainly the Gen Tie line crossing BLM ground is “assisting” a project because the wind plant would be inoperable without it. Thus it would seem that BLM would have had adequate justification for an Environmental Impact Assessment (EIA) or Environmental Impact Statement (EIS).

Since no EIA or EIS was performed for the Rock Creek I and II, the importance of missing analyses and public input can only be explained by reference to the EIA done by BLM for a neighboring project – the Two Rivers Wind Plant.

Figure 2, from the BLM EIA, shows the Two Rivers and Rock Creek wind plants in context. The two circles in the figure show what constitutes the local area for Bald and Golden Eagle populations – the Local Area Populations (LAP). Just for the readers’ information, the two circles encompass areas that are between one-fourth and one-third of the State of Wyoming in size and enclose more than 1,000 square miles of active, permitted and contemplated wind energy plants.

Figure 2. From the EIA for Two Rivers project. Note the proximity of Two Rivers and Rock Creek to one another. The local areas are for populations of Bald Eagles (Blue) and Golden Eagles (Brown). Numerous other wind energy projects are displayed, but this map is not up to date.

The BLM generated EIA from the Two Rivers project stated the following:

“…The LAP of Bald Eagles for the Project is approximately 52 Bald Eagles, and the annual 1% and 5% benchmarks for this LAP are about one and three Bald Eagles. Currently, there are six operational projects within this LAP for which take of Bald Eagles is authorized (Seven Mile, Dunlap, Chokecherry and Sierra Madre Phase 1, Pioneer, Glenrock/Rolling Hills, and Top of the World wind projects). Taken together, this Project’s take and the overlapping take of the other projects could result in a total annual take of 14.8 Bald Eagles (or 28.2% of the LAP). This is above the 5% benchmark; however, the North American Breeding Bird Survey population trend (1966-2019) estimate for Bald Eagles in Wyoming and Project LAP is 9.9% and 18.4%, respectively (Sauer et al. 2017; USGS-PWRC 2020). Analyses conducted by the USFWS showed that over most of the U.S., Bald Eagle populations are growing at a rate of approximately 5% per year (USFWS 2016b)…It is reasonable to assume that the Bald Eagle population in the Project vicinity is increasing and the conservative take estimate at the Project would not contribute to declines in the overall Bald Eagle population in the EMU….”

Similar peril is indicated for Golden Eagle populations. Notice that the estimate of Bald Eagle take for this project and six others presently holding take permits is already a staggering 28% of the LAP per year. It stands to reason that another eleven operating projects within the local areas would add to this already unsustainable burden. In fact, one project in the soutzheastern quadrant of the local area, NextEra’s RoundHouse I and II, paid a substantial fine for taking eagles without a permit. The contemplated Rock Creek I and II projects are in addition to these seventeen projects.

Things to Watch

The U.S. Fish and Wildlife Service is presently updating its Bald and Golden Eagle Take Permit regulations which should be available in draft form for public comment by spring of 2024. We will report back to WUWT on any significant developments.