**Need for a Coherent Strategy to Address a Wind Energy Boom on Western
Public Lands**

Conservationists must act rapidly to bring about Appropriate Siting of
wind facilities on public lands in the West. BLM is quickly issuing
scores of new three year rights-of-way for placement of wind energy
sampling apparatus (MET towers), the precursors to full-scale site
development. Wind energy development threatens the heart of unfragmented
sagebrush-steppe habitats critical to sage grouse, areas with
concentrations of nesting raptors, and nesting habitats and migration
corridors of migratory birds.

DOE's wind energy initiative calls for obtaining 5 per cent of the
nation's electricity from wind turbines by 2020. This will require
placement of more than 132,000 new wind towers -- three times greater
than the number of existing communications towers in the US. ////. Cite.
*Environment and Climate News* July 2002. Government and NGO reports in
recent years have highlighted the wind energy potential on western
public lands, encouraging a prospecting boom by wind energy companies.
Subsidies provided for renewable energy development are a driving force
behind the boom. Domestic and foreign energy companies are aggressively
pursuing test site rights-of-way, and some are pursuing full-scale wind
farm development.

Use of best available science and the reasonable policies developed by
federal agencies (USFWS, BLM) to guide siting and development could
limit impacts to public lands, especially if guidance for Appropriate
Siting was followed. Unfortunately, BLM is wantonly ignoring FWS
guidance and its own policies. The wind energy industry is not policing
itself. Instead, some companies are pursuing wind development in
ecologically disastrous sites.

# Wind Energy Prospecting

There are several documents or Web resources that highlight wind
potential in the West. These include:

*Renewable Energy Atlas of the West*. Nielsen et al. 2002. Hewlett
Foundation and the Energy Foundation. [www.wind](http://www.wind/) . The
report contains maps to help developers "gain a better understanding of
where the best renewable resource areas are found", in order to
"significantly minimize the cost and time in prospecting". The report
claims to have screened out areas "not suitable for wind power
production". However, this screening in no way reflects values of lands
for wildlife, and is based on existing special land designations such as
"Wilderness" or "Refuge". Sites shown as best renewable resource areas
for wind prospecting have not been legitimately screened for wildlife or
most other conflicts.

*Assessing the Potential for Renewable Energy on Public Lands*.
USDI/USDOE. February 2003. "Collaboration" between agencies was used to
identify BLM planning units with highest potential for private-sector
development of renewable resources", including geothermal, wind, solar,
biomass, low-impact hydro. The agencies believe that "most renewables
can be accommodated under existing Land Use Plans that identify
wilderness, ACECs and special management designations" - which are very
limited, and often unrelated to wildlife habitat concerns.

Screens used in the GIS analysis for DOE/BLM report were:

-   Wind is class 4 or above (short term) 3 or above (long term). Scale
    is 1-8.

-   Federal, state and local policies support wind.

-   Transmission access is within 25 miles. (Many places).

-   Site must be compatible with wind energy development; scenic areas,
    view-sheds, and non-development regions must be eliminated. (Based
    on very limited and inadequate screening).

-   Site must have access to road within 50 miles. (Nearly everywhere!).

Following along with the Hewlett report, DOE and BLM "site
compatibility" appears to have been largely based on Special
Designations like Wilderness. While creating the illusion of screening
out sensitive wildlife habitats and other important areas, in actuality
the report does not do this.

Many BLM Land Use Plans are very outdated, and do not contain a valid
current inventory of public lands resources. These plans did not
anticipate and do not address wind facility development and associated
infrastructure in wild land areas. Past BLM land use plans "zoned"
utility corridors for powerlines/natural gas, mineral entry, fluid and
non-fluid mineral entry lands, and at times established seasonal
"avoidance" zones to protect some limited habitats for wildlife during
critical periods of the year. These plans did not anticipate or address
impacts of wind farm development in wild land habitats.

Areas emphasized in BLM/DOE report include: Nevada -- Elko District,
rated third in the nation for wind development. This includes 12 million
acres contiguous with southern Idaho. Note: This appears to have been
based on averaging over the whole area, and does not highlight
individual "best" sites. Carson City also rated high. However, MET tower
r-o-ws have been issued or are pending in BLM offices across Nevada,
tracking mapped high potential wind sites.

In Idaho, the Owyhee Field Office is shown as having large blocks of
higher wind potential sites. Despite a new (in BLM terms) Owyhee Land
Use Plan finalized in 1999, complications of wind facility and
infrastructure siting were not dealt with in the Plan. As in Nevada,
wind energy companies are pursuing rights-of-way in BLM Field Offices in
many locations,, including two highly controversial proposals in the
Jarbidge Field Office (Browns Bench), Burley District (Cotterell
Mountain) which will be described below.

*Web Sites* containing maps and some information on wind potential are:

[www.windpower.org](http://www.windpower.org/) . Provides maps of
portions of many western states -- all of Idaho, some of Nevada.

[www.idwr.state.id.us/energy/wind/](http://www.idwr.state.id.us/energy/wind/)
. IDWR site. Access to interactive wind maps.

# Potential for Fragmentation of Critical Wildlife Habitats Is Great

A coarse review of various reports and Web site maps highlighting
potential Wind Energy sites shows that the areas with higher wind
potential are frequently lands with little existing development. Many
high potential wind sites are located in critical wildlife habitats.
Construction of new facilities in these areas will fragment higher
quality, relatively intact habitats for sagebrush-steppe species. For
example, many Owyhee County and Elko BLM lands within the Interior
Columbia Basin were rated as better condition shrub-steppe habitats by
ICBEMP, compared to nearly everywhere else in the Basin. Yet, these are
lands identified as having some of the highest wind potential

North-south running ridges, or plateau edges, in the Great Basin and
southern Idaho are indeed windy. These areas are generally bordered by
steeper slopes, often rugged or rocky topography, or are plateaus
located above valley floors. These are the precise characteristics that
to some degree have limited human development and intrusion. They are
often refugia or critical habitats for important declining sage-steppe
species like sage grouse. Rocky outcroppings or small canyons on their
edges provide raptor nesting sites. Plus, good winds may signal
importance as migration corridors, which are little-studied in the
Interior West.

# Recent BLM Wind Actions, or Analyses Underway

*Broad-Scale Actions*:

Programmatic Wind EIS. Letter of Nov. 5, 2003. BLM is preparing a PEIS
"to assess the potential for development of wind energy on western
BLM-administered land". The process is expected to be completed in 2
years. It "will evaluate issues associated with development and consider
amendment of individual land use plans throughout the western region".
See also *Federal Register* Notice October 17, 2003. FR 68 201-page
59814.

BLM Guidelines/Instruction Memo. Press Release of 10/21/02. "Clarke
Announces New Wind Energy Policy". BLM issued an Instruction Memorandum
with new guidelines for the role of wind energy in Bush's National
Energy Policy. "BLM currently administers 25 wind energy right ways
authorizations on public lands in CA and WY. The sites cover
approximately 5000 acres and generate about 500 megawatts of electrical
power per year. Interest is increasing, and BLM **recently received 30
new applications** for projects in NV, ID, NM. CA, WY, WA. Note: the
land area in the Browns Bench r-o-w finalized in late 2003 is **more
than double** the land area of all existing development on BLM lands.

*Site-Specific Actions:*

Rights-of-way for placement of MET (wind sampling) towers on BLM lands
are being widely issued without public input and review. Energy
companies are vying for the sites with greatest potential, many of which
are located in important wild land areas. Regard for Appropriate Siting
has been cast aside.

In authorizing three-year rights-of-way for MET (sampling) tower
placement, BLM has used Categorical Exclusions (CEs). These are a
minimal form of NEPA that is basically a checklist of "no effect"
conclusions on environmental components ranging from air quality to
special status species. There is no public input process, and no appeal
process for decisions made at the low level of a CE. Nevada MET tower
rights-of-way that we have reviewed were issued on the basis of CEs, in
lands ranging from Carson City to the Elko District BLM lands on the
Nevada portion of Browns Bench contiguous with the Idaho border. An EAs
is underway for a recent application in the Winnemucca District. Idaho
BLM issued a right-of-way under a CE to allow MET towers to be placed on
Cotterell Mountain, and has already given the go-ahead for development
of an EIS for a wind facility there.

Due to intense public concern about the Browns Bench proposal, BLM
prepared an EA for MET tower placement, with public comment and review.
However, the EA was primarily a rubber stamp exercise, and public
concerns were cast aside.

\[Note: BLM Manual 6840 directs BLM to ensure that any activities
authorized, funded or carried out do not contribute to the need to list
any species\].

Wind Energy Companies Are Misleading the Public on BLM Lands - Saying
One Thing, and Doing Something Else

The aggressive and single-minded actions of RES, UK in pursuing the
Browns Bench proposal illustrate how wind energy companies are deceiving
the public.

In the Cotterell Mountains, pre-MET tower maneuvering occurred
behind-the-scenes. A land exchange to facilitate development, -including
a land exchange deceptively billed for other purposes - before any
public input occurred. The whole project was immediately put on a fast
track. The EIS is being strong-armed through, with concerns brushed
aside.

**US Fish and Wildlife Service Interim Guidelines**.

FWS issued Interim Guidelines for wind energy development in May 13,
2003. FWS states that wind energy facilities can adversely impact
wildlife, especially birds and bats, and "the cumulative effects of this
rapidly growing industry may contribute to the decline of some wildlife
species". "Wind is rapidly expanding into habitats and regions that have
not been well studied. **The Service therefore suggests a precautionary
approach to site** **selection and development**. Each proposed
development site is unique, and requires detailed, individual
evaluation.

The Guidance covers: **Proper evaluation of potential wind energy
development sites**; Proper location and design of turbines and
associated structures within sites selected for development; and Pre-and
post-construction research and monitoring to identify and/or assess
impacts to wildlife. This should be done through: "Proper evaluation of
potential Wind Resource Areas (WRAs) selected for development.

Site identification. Develop reference sites within the same general
geographic reference area. "Reference sites are high-quality wildlife
areas where wind development would result in the **maximum negative
impact on wildlife**. Use reference sites to determine comparative
risks. Browns Bench and Cotterells, in actuality, fit the criteria to be
designated reference sites, as does the Nevada Browns Bench site.

FWS Interim guidelines allow comparison between sites. Evaluation should
include a "footprint" "encompassing all of the turbines and associated
structures for the facility including adjacent wildlife habitats. FWS
excludes the transmission lines extending outside the footprint.

FWS site development recommendations include:

\* **Avoid** placing turbines in documented **locations of any species
of wildlife**, fish, or plant protected under the Federal Endangered
Species Act.

\* **Avoid fragmenting** large, contiguous tracts of wildlife habitat.
Where practical, place turbines on lands already altered or cultivated,
and away from healthy, intact native habitats. If not practical, select
fragmented or degraded habitats over relatively intact areas.

> \* **Avoid** placing turbines in **habitat known to be occupied by
> prairie grouse** or other species that exhibit extreme avoidance of
> vertical features and/or structural habitat fragmentation. In known
> prairie grouse habitat, avoid placing turbines within 5 miles of known
> leks (communal pair formation grounds).

\* **Avoid** locating turbines in known bird migration pathways or in
areas where birds are highly concentrated.

-   **Avoid** placing turbines near known bat hibernation, breeding, and
    maternity/nursery colonies, in migration corridors, or in flight
    paths.

All of the preceding guidelines emphasize Avoidance, i.e. don't build a
facility in the wrong place!

Other guidelines address site facility design and operation. These are
really mitigation for facility construction.

Sadly, this is not what is occurring. Instead, an energy boom mentality
reigns. BLM/DOE, IWDR, Hewlett, etc. are saying: "Wow! This is a windy
place. It is a good place for wind energy development". Energy companies
are responding by placing MET towers, and gaining a boothold for future
mega-development. With minimal, if any, regard for the vast array of
public lands wildlife and other values at stake

**Case Examples of BLM Ignoring Protective Policies for Wildlife and
Public Concerns**

The Browns Ridge and Cotterell Mountain proposals in southern Idaho are,
in their respective geographic areas, some of the least developed wild
lands. They are also critical habitats for local sage grouse
populations. The Browns Bench area is a sage grouse stronghold, by any
one's definition -- and the very worst place in the entire 1.7 million
acre Jarbidge Field Office for placement of a wind energy facility.

<http://www.audubon.org/chapter/wa/wa/bev/bevnum4-01_2.htm> "First, do
extensive surveys of migratory bird populations and patterns in the
area. Migratory bird corridors can be identified and factored into
facility siting. Studies should be conducted prior to siting wind farms
to ensure that new wind farms are developed in areas least likely to
impact Neotropical migrants and other avian species of concern.

**October 16, 2002. BLM Instruction Memo**. "Interim Wind Energy
Development Policy".

"Wind energy and other renewable energy generating sectors of our
economy are the fastest growing in the US". There has been an extension
of federal wind energy production tax credit, and state-level tax
credits and other incentives.

BLM's general policy is: "to encourage the development of wind energy in
acceptable areas". BLM claims most WE test siting can be done under
existing LUPs.

BLM issues rights-of-way for test siting (MET towers) and wind energy
development projects. Adverse impacts." Negative impacts can be
minimized by **avoiding special** **management areas** with land use
restrictions, **avoiding major avian (bird migration routes, and areas
of critical habitat for species of concern**, establishing siting
criteria to minimize soils disturbance ad erosion, avoiding significant
historical and cultural sites, mitigating conflicts with other land
uses.

However, BLM is not following this in allowing siting. It is issuing
testing ROWs, and EIS process is already underway in one area (Cotterel
Mountain). Siting oks seem based purely on desries of energy companies,
which are competing for highest energy wind sites. BLM is using wind
inventory as the basis for addressing wind energy resource development
opportunities.

Refers to developing FWS guidelines "to assist the wind industry in
avoiding or minimizing impacts on wildlife by wind energy development".

A procedure for pre-development evaluation of potential wind resource
areas based on their impact on wildlife.

BLM issues 3 types of ROWs:

-   Site-specific wind energy site testing and monitoring row grant for
    individual MET towers with a term limited to three years.

-   Wind energy test siting and monitoring row grant for a larger site
    testing and monitoring project area, with a three year term that may
    be renewed beyond the initial three years. The holder retains an
    interest in the site, and others may not apply. Then, submits a
    separate application to BLM for analysis, review, decision for wind
    farm development.

-   Long-term commercial wind energy development row with a term that is
    to limited by regulations, but is usually in the range of 30 to 35
    years.

The Browns Bench MET tower is the only project where we know has had an
EA prepared for MET tower placement.

BLM is segmenting the NEPA analysis process, claiming analysis of MET
towers is separate from development. Yet, it is allowing placement of
several 160 foot tall towers without prior studies of movement. Thus,
there is no valid baseline to determine sage grouse movements and use in
an area. Placement of towers which may cause birds to avoid sites could
skew results of subsequent studies of sage grouse or other species as
wind farm EIS data is gathered.

**BLM Is Ignoring the Public**

BLM failed to adequately respond to a broad range of public concerns
that overwhelmingly opposed the project.

Even the Lower Snake River District BLM Resource Advisory Council, a
group which rarely agrees on anything, unanimously opposed the project.
The RAC wrote a letter voicing opposition to the project to BLM Director
Kathleen Clarke. The RAC was ignored, and the Jarbidge BLM Manager
Guerrero signed a Final Decision to authorize MET tower placement. The
decision was appealed by WWP and Idaho Bird Hunters. BLM then tried to
get the appeal thrown out, saying that a letter Guerrero had sent that
claimed to extend the appeal deadline was not valid. In retrospect, this
letter was likely a purposeful attempt to mislead conservationists.
BLM's internal Appeals system, IBLA, rejected BLM's claims, but denied a
petition for Stay of the Appeals, which allows placement of MET towers
to go forward. Placement of four to six 160 foot high towers in critical
habitats may alter baseline data on sage grouse habitat use and
movements.

BLM Managers and Industry Are Running Roughshod Over Balanced Decision
Processes

WWP has been contacted confidentially by several agency scientists and
specialists concerned about wind projects and the BLM's abdication of
its management duties in assessing environmental impacts of both wind
MET towers and full-blown farm development. Agency scientists are being
forced to make concessions that they do not agree with, and being
forbidden to participate in analysis in their field of expertise. WWP
has been urged to be involved in two wind proposals, and challenge
industry-biased decisions that are coming down. Internal quashing of
environmental concerns seems to be a result of both the atmosphere of
the Bush BLM as well as the aggressiveness of the energy companies
pursuing projects in ecologically terrible locations.

# Conflicts Between Conservation Groups

Conservation groups need to all be on the same page on wind development
on public lands. This is not the case at all at present. Salmon and
river advocates see wind energy as at least a partial solution to
problems cased by dams. Clean air advocates and others see renewable
energy as a part of the solution to air pollution. Nuclear groups ...

It is critical to educate these groups on the ecological harms that will
undue from large-scale wind development in BLM lands in the Interior
West -- unless strict adherence is paid to Appropriate Siting.

What Needs to Happen -- Soon! Before BLM Goes the Next Step, and Issues
30 Year Rights-of-Way in Critical Habitats and Wild Land Areas

BLM's Draft and Final Programmatic Wind EIS are slated to come out
within the next two years. We can not realistically expect that this
document will provide necessary data, analysis, and actions to address
environmental concerns about wind energy development on western wild
lands and wildlife populations. It is more likely it will be a document
designed to "streamline" NEPA, and clear hurdles to development. It is
essential that conservationists interested in protection of sage grouse,
raptors, migratory birds, bats and other native biota act quickly to
assemble information on potential impacts of wind energy production on
BLM lands, and develop a coherent strategy for addressing wind
development in some of the West's least developed wild lands.

We need to develop our own comprehensive review of cumulative impacts
anticipated from wind development in wild land areas of the West, and
use it as basis for a public education campaign about Appropriate
Siting.

At the time of the Draft PEIS:

-   Have a unified, coherent policy that highlights Appropriate Siting
    as an overwhelming consideration on public lands. An Inappropriate
    Site can not be adequately mitigated. Mitigation must be by
    avoidance.

-   Assemble information on wildlife, cultural and other values of lands
    in locations in Idaho and Nevada shown as having high wind potential
    (BLM/DOE, Hewlett, others). high value wind sites, and all areas
    where MET tower right-of-ways have been issued, or are pending.

-   Catalogue data gaps -- like migration corridors or migratory birds
    in the Interior West. Figure out what to do about it.

-   Produce maps that show Appropriateness vs. Inappropriateness of
    sites where projects are likely.

-   Produce maps that show more "fragmented" vs. less "unfragmented"
    sage grouse habitats, known migration corridors, etc., overlaid with
    wind development sites.

-   Facts and figures on how much infrastructure is required to develop
    a site in a wild land area, and get the energy to the grid for
    selected "windy" sites.

-   Have respected scientists knowledgeable about charismatic species,
    impacts of development in Inappropriate Sites, etc. publicly voice
    concerns, and advance and promote a policy of Appropriate Siting.

BLM/DOE are currently **prospecting** for energy companies -- based on
wind alone, but not on appropriateness of wind farm and infrastructure
development on public lands in "windy" sites. BLM is abrogating its
management duty.

DOE's wind energy initiative calls for obtaining 5 per cent of the
nation's electricity from wind turbines by 2020. This will require
placement of more than 132,000 new wind towers -- three times greater
than the number of existing communications towers in the US. Between
four and five million birds are killed every year in collisions with
stationary, generally solitary, communications towers. Michael
Heberling, *Environment and Climate News* July 2002. "A 295-foot tall
wind turbine can be viewed as a "communications tower" with an
additional bird killing surface area of 21,113 square feet -- the size
of half a football field.

FWS recommends that a team of agency professional make decisions on
appropriate siting. However, BLM is now cutting knowledgable
professionalslands where the most knowledgeable and experienced agency
staffer on wildlife issues has been excluded from the "team", and
job-related recrimination has occurred.