National Renewable Energy Laboratory

Innovation for Our Energy Future

A national laboratory of the U.S. Department of Energy

Office of Energy Efficiency & Renewable Energy

NREL is operated by Midwest Research Institute ● Battelle Contract No. DE-AC36-99-GO10337

Subcontract Report

NREL/SR-500-47129

April 2010

An Integrated Risk Framework 

for Gigawatt-scale Deployments 

of Renewable Energy: The U.S. 

Wind Energy Case

October 2009

Bonnie Ram

Energetics Incorporated
National Renewable Energy Laboratory

1617 Cole Boulevard, Golden, Colorado 80401-3393

303-275-3000 • www.nrel.gov

Operated for the U.S. Department of Energy

Office of Energy Efficiency and Renewable Energy

by Midwest Research Institute • Battelle

Contract No. DE-AC36-99-GO10337

Subcontract Report

NREL/SR-500-47129

April 2010

An Integrated Risk Framework 

for Gigawatt-scale Deployments 

of Renewable Energy: The U.S. 

Wind Energy Case

October 2009

Bonnie Ram

Energetics Incorporated

NREL Technical Monitor: Kathleen O’Dell

Prepared under Subcontract No. KLCX-4-44453-15
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i

Acknowledgments and Disclaimer

The author would like to acknowledge partial financial support of this work from the National 

Renewable Energy Laboratory’s (NREL) National Wind Technology Center and the Office of 

Wind and Hydropower Technologies of the U.S. Department of Energy (DOE). The author 

assembled a panel of nationally recognized risk experts and held a one-day workshop to discuss 

comments on this paper (see Appendix A). In addition, the DOE Office of Wind and 

Hydropower Technologies reviewed it and provided detailed comments. These comments 

informed this version of the paper. The author appreciates the professional support of Dr. 

Robert Thresher and the participation of the peer reviewers but is solely responsibility for the 

content herein. Various Energetics personnel also assisted with the research and production of 

the report, including Russell Raymond and Wendy Wallace. Susan Kaczmarek and Tommy 

Finamore provided layout and graphics support. The views and content do not necessarily 

reflect the viewpoints of the peer reviewers, the DOE, or NREL.
ii

List of Acronyms

CEQ Council on Environmental Quality

CO2 Carbon Dioxide

DOE U.S. Department of Energy

DOI U.S. Department of the Interior

EIS Environmental Impact Statement

EPA U.S. Environmental Protection Agency

FWS U.S. Fish & Wildlife Service

MBTA Migratory Bird Treaty Act

NEPA National Environmental Policy Act

NOx Nitrogen Oxide

NRC National Research Council

NREL National Renewable Energy Laboratory

NWCC National Wind Coordinating Collaborative
iii

Table of Contents

Introduction .................................................................................................................................. 1

Risk Assessment Is Not a New Invention .................................................................................... 5

A Description of the Integrated Risk Framework ........................................................................ 8

What Is the Decision Problem?........................................................................................ 10

Sector Risk Analysis........................................................................................................ 10

Sector Risk Characterization and Uncertainty Summary ................................................ 13

Extended Risk Analysis................................................................................................... 15

Comparative Analysis and Determining Risk Tolerability.............................................. 18

Management Options and Strategy.................................................................................. 19

Summary..................................................................................................................................... 24

Next Steps................................................................................................................................... 25

References .................................................................................................................................. 27
iv

List of Figures

Figure 1. The formative stages of risk-assessment design Source: Adapted from NRC 2009c:73

...................................................................................................................................................... 2

Figure 2. A framework for integrated risk analysis: Gigawatt-scale wind energy deployments. 9

Figure 3: Causal Chain of Risk .................................................................................................. 19
1

Introduction

Assessing the potential environmental and human effects of deploying renewable energy on 

private and public lands, along our coasts, on the Outer Continental Shelf (OCS), and in the 

Great Lakes requires a new way of evaluating potential environmental and human impacts. 

Deployment of renewables requires, I will argue, a framework risk paradigm that underpins 

effective future siting decisions and public policies. 

Risk assessment is not a new ingredient to decision making. It has been widely applied 

throughout the federal government and corporate sectors, though not yet for renewable energy 

except within specific sectoral impact areas, such as bird and bat collisions. Developing and 

applying an integrated risk assessment framework that assesses and compares energy-related 

risks and benefits are critically needed to make good decisions in a timely way under 

conditions of significant uncertainty. Of course, risk assessment by itself does not include all 

the elements needed for complex decisions. However, it provides one body of information and 

analysis essential for complex decision making. Throughout this paper, we discuss “riskinformed” rather than “risk-based” decision making. Accordingly, we recognize that no generic 

number exists as the “answer” for setting standards or interpreting regulations on any sector. 

Risk assessment provides valuable information, but the decision process always reflects 

“value” considerations that are embedded in the political arena (NRC 2009b). Other issues 

beyond environmental and human risks—such as financial risks, workforce training and 

education, federal R&D policies supporting new technology developments, and transmission 

infrastructure—also must be considered in making decisions. 

Evaluating potential risks and making energy decisions requires a sustained program of 

assessment and research that collects relevant data for each sectoral risk, whether on land or in 

the sea. (See diagram below for the sectoral risks, e.g., mammal migrations, habitat 

fragmentation, safety within shipping lanes, and visual effects.) Data collection alone, however, 

will not lead to better decision making. Arriving at a broad and integrated risk profile of 

environmental and human effects requires an approach that accounts for the scientific evidence, 

compares other energy supply options and benefits, and considers stakeholder and public 

concerns. 

Every potential wind energy site has a unique set of potential risks (e.g., navigation may be the 

principal problem at one offshore wind site, community concerns and tourism impacts at 

another, and land or marine use conflicts at others). Thus, analysis is needed across risks and 

sites to discover the principal problem areas or where the benefits may be. An integrated 

framework also seeks transparency of the major “tradeoffs” of siting decisions for a renewable 

technology or some other energy supply option.

Proceeding in this direction can be complicated, given that the current regulatory framework 

for assessing risks and permitting varies across localities and states—although this may be a 

challenge that all energy supply options face rather than a wind-specific one. The current 

approach for evaluating potential impacts of wind energy facilities still focuses on sector-bysector assessments, sometimes with an environmental impact statement or environmental

assessment [required under the National Environmental Policy Act (NEPA) for federal lands or 

laws] and/or a permit application prepared by a government agency and/or a private developer. 
2

Government-sponsored risk research often is designed around perceived “barriers” to wind 

developments that arise from new problems or piecemeal concerns. One example is radar 

interference. Federal agencies responsible for hazard assessment of wind developments related 

to radar performance could employ risk reduction strategies for upgraded software and 

hardware systems. This approach balances the risks and benefits within the broader context of 

national security and clean energy deployments. Also decisions about radar interference 

research would be made in relation to other sector risks. 

Perceptions of significant risks also relate to important, but narrow, agency regulatory 

missions, such as the Migratory Bird Treaty Act (MBTA), in which even one death from a bird 

collision is forbidden by statute. This risk approach seeks to sensitize agencies, whether local or 

national, to the advantages of an integrated knowledge base for different approaches to decision 

making.

The integrated knowledge base includes the major ecological, human health, and 

socioeconomic risks. It does not attempt to embrace all matters of risk specifically, nor does it 

treat all issues relevant to decision making. Nonetheless, it provides an integrated view of the 

major body of environmental, health, and community risks that are critical to any energy 

facility siting or deployment initiative. 

The issue of how to integrate risk assessment into a broader decision-making process is 

captured in Figure 1. The figure takes into account “non-risk” considerations, such as utility 

decision making and state renewable portfolio policies.

Figure 1. The formative stages of risk-assessment design

Source: Adapted from NRC 2009c:73
3

The site-, sector-, or project-specific risk analyses are central to a better understanding of risk, 

but again, they do not serve the decision maker well. The decision maker needs to understand 

the broad spectrum of risks and benefits across all potential sites to make sound decisions. The 

proposed framework can be applied at different scales of problems and addresses issues that 

decision makers face at national and regional sites.

In addition, weighing the size or significance of the risk allows a more objective assessment of 

whether the tools, methods, and metrics are appropriate to assess the level of risk and make 

comparisons among energy facility choices. Of course, there are a wide variety of tools and 

methods, and each sector needs a specific set of analytical tools to address the specific 

questions related to different sector risks. In some cases, the tools may be more cumbersome or 

precise given the level of the defined risk and its “impacts” on the human and physical 

environments. Although the dataset or the analyses may be incomplete and uncertainties are 

still apparent, expert judgments can assist in determining the adequacy of our knowledge base 

and the research gaps that exist. An important revelation in the risk field is that further research 

does not always reduce uncertainty (e.g., National Research Council (NRC) 2005, especially 

Chapter 4). Therefore, this analytical framework can help an agency or industry group decide 

where to invest scarce resources to fill knowledge gaps in areas where risk reductions are 

possible and cost-effective.

In other cases, adaptive management strategies may be employed along with a precise 

monitoring program. Adaptive management is more than a slogan about postponing difficult 

decisions related to environmental risks. As Kai Lee, a noted voice in environmental 

management issues, aptly said, “adaptive management [is] treating economic uses of nature as 

experiments, so that we may learn efficiently from experience.” He continued: “adaptive 

management is an approach to natural resource policy that embodies a simple imperative: 

policies are experiments: learn from them.... Adaptive management takes uncertainty seriously, 

treating human interventions in natural systems as experimental probes” (Lee 1993:8-9).

Agencies, organizations, and developers are quick to suggest employing adaptive management 

strategies for risk and uncertainty associated with wind projects on land and at sea, but 

institutionalizing adaptive management strategies is a more complex challenge than is typically 

discussed in renewable energy circles. It involves openly acknowledging mistakes that will 

inevitably be made, creating institutions that can incorporate lessons learned, and encouraging 

bold leadership that can admit these mistakes and take a new path (Holling 1978, Walters 

1986). It is not clear whether institutions responsible for wind energy decisions—on the local, 

state, or national levels—are prepared for these challenges. Pathways of “social learning”

require a combination of adaptive management and political change that demands debates by, 

and commitments from, institutions unaccustomed to these circumstances, transparency, 

and openness.

Although the lifecycle footprints of renewable energy deployment are small today, large-scale 

deployments are planned on land and in the ocean over the next decade within North America, 

Asia, and Europe. Now is the time to construct an integrated risk framework that systematically 

and comprehensively evaluates the range of adverse risks and impacts and compares them with 

those of other energy supply options. A central principle of such an integrated risk framework 

is that risks (sector effects) must be compared with each other to develop a transparent 
4

evaluation of temporal and spatial impacts on a site or a region and national effects on this and 

future generations. An evaluation of only one sector separated from other potential problem 

areas leads to a skewed and incomplete understanding of significant risks, encourages an 

approach of “subsystem dominance,” and dangerously risks a reactive, “risk du jour” approach. 

(This is an approach that involves responding to risk events as they happen or as they delay 

individual project developments.)

The lesson is simple. Risk assessment must not make assumptions about what the risk of 

concern will be at any site or future time. It must follow a strategy that allows work on any 

particular risk to proceed in a framework in which our understanding of the panoply of risks 

and uncertainties, and the needed knowledge base, always moves forward. 

Nuclear power provides a compelling historical example of how not to do risk analysis. 

Although it was widely recognized that nuclear plants, like wind plants, entailed a range of sitespecific risks, the assumption was made in the late 1960s and 1970s that reactor accidents were 

the risks of concern and should be the focus of attention. A systematic approach to risk was not 

taken because it was assumed that we knew the main risk problem. As a result, nuclear waste 

disposal was neglected, and it contributed significantly to the reason nuclear plants have not 

been built over the past 30 years. Clearly, we can take valuable lessons from other experiences 

(NRC 2008a:167). 

The major risk in each case is context-driven; it will typically differ from site to site, and a 

sound risk framework is needed to ensure that an integrated risk knowledge base can be drawn 

on by developers, state officials, and local officials. This, of course, in no way prevents or 

discourages a vigorous research program on any particular risk. It simply ensures that any 

particular risk is always put into a local context and addressed within the context of other risks 

and benefits. 

An integrated risk framework also contributes to effective siting strategies, which are based on 

avoiding irreducible risks, mitigating those that can be avoided or reduced, and employing costeffective, adaptive management practices wherever possible. While the nation moves forward 

in deploying renewable energy, lessons learned and new data will trigger new problems and 

new solutions to the potential impacts on our communities, landscapes, and the marine 

environment. Therefore, an important theme lies in understanding that exhaustive studies are 

not necessary for identifying the most significant risks. Often, more data uncover new problems 

rather than resolving uncertainties. In the risk analysis world, the focus is on decisions, not the 

pursuit of perfect knowledge. 

An integrated risk framework is discussed and presented graphically in this paper. It identifies

the specific analytical steps needed for a systematic and complete assessment and explains how 

these activities can provide the knowledge base to inform better decision making, effective 

management approaches, and smarter siting strategies. In the Department of Energy’s report 

20% Wind Energy by 2030, a risk framework was identified as a needed step to scale up 

deployments to gigawatt-scale levels (DOE 2008: 114). The report called for a more systematic 

approach to environmental risks than the current piecemeal approach, which does not 

systematically evaluate risks and benefits. This framework can be employed across all 

renewable energy sources, not just wind energy. 
5

A risk perspective is a major asset for the renewable energy community. It not only addresses 

important aspects of the broader energy portfolio debate but also can show whether renewable 

technologies, compared with conventional energy options, are more benign energy sources in 

terms of health and environmental risks and offer more positive effects on climate change and 

national security. 

Risk Assessment Is Not a New Invention

Risk assessment and integrated risk frameworks are not new inventions for decision makers. 

Since the publication of the National Research Council’s “Red Book” in 1983, they have been 

widely applied to a range of environmental and health issues within federal and state agencies 

and in many global corporations. They provide a well-established set of tools and methods that 

comprise an integrated analytical approach for assessing potential problems and decision 

making related to technology deployments (NRC 1983). Risk assessments can also provide a 

focal point for cooperation among local communities and state and federal government 

agencies. Further, they can build the knowledge base and approaches for determining how safe 

is “safe enough” and what major tradeoffs exist among different technology and policy choices. 

In the wind case, the primary question has often been “How many bird and bat fatalities are 

tolerable?” (See the case study highlighted in Section 3.2, below). Other important questions 

are “What level of landscape impacts to habitats on land and at sea are tolerable?” and “How 

should wind energy risks and benefits be balanced with climate change benefits?” 

Well executed, risk assessments also can identify major divergences between public 

perceptions and concerns and expert judgments. There is a wealth of literature on risk 

paradigms (NRC 1996, NRC 2005, Gregory 2003) and ecological risk assessments and their 

application to an array of health threats and environmental problems (NRC 2008b). Indeed, the 

recent NRC (2009c) review of risk assessment practices lists 53 reports by the Environmental 

Protection Agency (EPA) on risk assessment. In addition, risk analyses have been applied to a 

variety of industrial sectors and regulatory agencies, including:

• Nuclear power and the nuclear fuel cycle (e.g., deterministic and probabilistic risk and 

human mortality analyses)

• The EPA and its regulation of the chemical and heavy metals industries (e.g., 

carcinogenic effects and exposure assessments)

• The Food and Drug Administration (e.g., food safety threshold analyses)

• The Bureau of Reclamation (e.g., dam failure and societal risk assessments)

• The Federal Aviation Administration (e.g., deterministic and probabilistic risk

assessments). 

The EPA Ecological Risk Assessment Guidelines (1998) were developed to help guide EPA 

scientists in assessing ecological risks to the environment from chemicals and other agents. In 

addition, the guidelines inform EPA decision makers and the public about procedures. The 

EPA published an initial set of five risk assessment guidelines (relating to cancer, mutagenic 

effects, developmental effects, exposure assessment, and chemical mixtures) in 1986, as 
6

recommended by the National Academy of Sciences. In addition to publishing these guidelines, 

the EPA continues to develop new guidelines as experience and scientific understanding 

evolve. A 2008 NRC report (NRC 2008a) summarized the guidelines’ origin quite clearly by

stating that “the premise central to EPA risk assessment practices can be found in enabling 

legislation for its four major programs: air and radiation, water, solid waste and emergency 

response, and prevention, pesticides and toxic substances.” It stemmed from the science-based 

regulatory actions from environmental legislation of the 1970s, although the term risk 

assessment was not incorporated into the statutes (Risk analysis emerged in the late ’70s and 

’80s). As yet, studies have not explored energy choices, although the guidelines and methods 

are clearly relevant to assessment and decision making in the wind case. 

According to the EPA (1992), “Ecological risk assessment evaluates the likelihood that adverse 

ecological effects may occur or are occurring as a result of exposure to one or more stressors.” 

Also: “It is a flexible process for organizing and analyzing data, information, assumptions, and 

uncertainties to evaluate the likelihood of adverse ecological effects. Ecological risk assessment 

provides a critical element for environmental decision making by giving risk managers an 

approach for considering available scientific information along with the other factors they need 

to consider (e.g., social, legal, political, or economic) risks in selecting a course of action” 

(EPA 1998). Risk assessment is not intended, it should be noted, to cover the array of risks that 

any energy option entails.

For example, the EPA conducts ecological risk assessments to evaluate the adverse effects of 

human activities and pollutants on the plants and animals that make up ecosystems. The 

ecological risk assessments provide a way to develop, organize, and present scientific 

information so that it is relevant to environmental decisions. These decisions may include the 

regulation of hazardous waste sites, industrial chemicals, and pesticides. When conducted for a 

particular place (such as a watershed), an ecological risk assessment can identify vulnerable 

and valued resources, prioritize data collection activity, and link human activities with their 

potential ecological effects. The limitation of an ecological risk assessment is that it is a partial 

assessment of a complex set of risks—such as risks to economic health and social systems—

beyond ecology. As a partial assessment of risk (e.g., for species-specific exposure), its value is

incomplete until the results are “integrated” with other risk assessments and results.

Wildlife issues have been the focus of risk research in the wind community since the Altamont 

Pass controversy of the 1990s (See NREL 2009). Nuclear and other toxic materials are absent 

in the deployment and operation of wind turbine technology. However, due to some evidence 

of risk to birds, specifically raptor species and habitat fragmentation, there have been recent 

attempts to apply ecological risk principles to the wind energy.

Around 2004, the possibility of applying risk analysis to the wind energy area was discussed 

within the National Wind Coordinating Collaborative (NWCC). This DOE-funded, consensusbased collaborative was established in 1994 originally to address the biological debate about 

the Altamont Pass raptor kills in California. A subcommittee was formed to discuss the 

relevance of risk assessment to the wind industry, and a white paper on ecological risk 

assessment was drafted, although it did not include risks to social systems (Efroymson 2007). 

At that time, a decision on the application of risk analysis was deferred for further conversation 

among the members, and the group decided ultimately to focus more narrowly on wildliferelated risks at the site level. Other NWCC workshops were held, but they continued to focus 
7

on the wildlife sector. For example, the purpose of the Probability of Impacts Workshop in 

November 2007 was “to assess strengths and weaknesses of current methods to assess wildlife 

impacts at individual sites.” In 2010, the NWCC wildlife workgroup updated its measures and 

metrics document, which addresses how to collect wildlife and habitat baseline and monitoring 

data for an individual site. The revised document incorporates ecological risk assessment 

principles for land-based pre- and post-construction site surveys. 

Alternative activities, led by NREL through a subcontract with Energetics, focused on a 

broader approach toward a better understanding of the application of risk principles. A 

workshop was held in October 2007 with the nationally-recognized risk expert Robin Gregory, 

who introduced the principles of risk assessment and structured decision making (SDM). This 

was followed by one lecture to the Fish and Wildlife Advisory Committee on how SDM might 

support decision making for wildlife guidelines. These activities led to the preparation of this 

paper (See Appendix A).

DOE stakeholder efforts have advanced understanding of the extent of wildlife risks from landbased wind deployments. However, an inherent weakness exists in the preoccupation of the 

research to arrive at a “tolerable number” for wildlife risks. As previously discussed, this goal 

cannot be resolved with more data collection since it lacks political dimension and values that 

are essential for decision making.

Similar results are expected from the Department of Interior’s (DOI’s) Federal Advisory 

Committee of the Fish and Wildlife Service (FWS). The FWS Wind Turbine Guidelines 

Advisory Committee was formed on Oct. 24, 2007. Then Secretary of the Interior Dirk 

Kempthorne appointed 22 committee members, representing a broad array of constituencies 

from wildlife biologists to wind developers. The scope and objective of the committee, as 

outlined in its charter (FWS 2009), are to provide advice and recommendations to the Secretary 

on developing effective measures to avoid or minimize impacts to wildlife and their habitats 

related to land-based wind energy facilities. After two years of deliberation, the committee 

developed a set of policy recommendations and voluntary guidelines for wind siting and 

operations to assess, avoid, minimize, and mitigate the potential impacts to wildlife and habitat 

from wind power development. The crux of the recommended guidelines is a tiered approach—

a decision framework for collecting information in increasing detail to evaluate risk and make 

siting and operational decisions. 

As the Federal Advisory Committee moves forward, its challenge lies in incorporating sciencebased decisions on risks while avoiding the political realities of clean energy deployments, 

climate change, and siting strategies. The recommended guidelines may fail to define how 

decisions will be made by developers or FWS field staff. Further, the premise of the document 

is to facilitate FWS staff and developers’ decisions on site suitability. However, the document 

does not provide a complete risk assessment methodology because it only addresses the 

wildlife sector—only one of the sector risks—and does not identify the broader scope of risks 

or provide risk comparisons. So although DOI was given the responsibility to develop 

guidelines for siting wind energy, its mission does not cover the wider array of issues needed to 

make siting or deployment decisions.
8

The outcome of this committee work resulted in a document that attempts to guide developers 

and FWS staff on a path to avoiding, minimizing, and mitigating effects from wind facilities on 

wildlife but falls short on providing a consistent risk-based methodology for proceeding. 

Finally, as the scope of the FWS is limited to wildlife protection, it is unlikely that this agency 

is capable of producing a comprehensive analysis of site suitability that addresses the full range 

of risk issues that may be present. Moreover, FWS is hamstrung by the MBTA regulations that 

do not allow any “takes” of migratory birds (Lilley & Firestone 2008)—a further barrier to the 

possibility of integrated decision making from this committee. 

A Description of the Integrated Risk Framework

An integrated risk framework is, at base, a logic structure that sets the stage for assessing a 

spectrum of potential areas of risk associated with deploying renewable energy facilities across 

the national landscape. Risk assessment informs decision making but does not in itself provide 

the sole basis for making decisions. Such decisions always involve a range of issues—such as 

siting strategies, technology developments, and industry workforce needs—that may be 

important. Beyond technical issues, the “values” placed on wildlife and habitat are complex 

issues that must be assessed across an array of stakeholders and communities. It is not a stepby-step process, and it does not reflect a linear scientific process for solving a problem. It is 

instead a set of interactive logical steps that allow for feedback loops. In fact, the interactive 

nature of this framework shows that stakeholder involvement and public perception are critical 

at every stage of assessment, deliberation, decision making, and implementation, as a number 

of National Research Council reports, particularly Understanding Risk (NRC 1996), have made 

clear. To this end, I propose an integrated framework, a graphic description of which is shown 

in Figure 2. The framework may be applied to evaluating the siting of all land-based and 

marine renewable energy options, although the sectoral impacts will, of course, vary depending 

on the specific technology deployed, the specific site considered, the scale of the deployment, 

and the stakeholder concerns at particular locations. The framework may also support a 

proactive approach to the complex issues related to siting new energy supplies as well as 

transmission lines. Of course, no risk assessment would include a detailed analysis of every box 

in the diagram, but the diagram does provide a systematic framework for the range of questions 

or potential concerns arising from siting decisions across the country.

An integrated risk framework provides federal, state, and local decision makers and their 

stakeholders a common ground for analyzing and managing risks and devising public policies 

and effective siting strategies. This approach is a “big picture” analysis of how the various 

scientific and analytical pieces fit together at any site or region—or indeed, at the national 

policy level—and how the potential environmental and social effects in one area compare with 

those at other sites and with different technologies. It provides a potentially powerful means of 

collecting and conducting research on many disparate impacts or sectoral areas and for 

comparing risks that seem quite different. By integrating fragmented research components, 

decision makers and stakeholders are better able to evaluate site decisions within a broad 

analytical context—reflecting the complex risk challenges in transforming our nation’s energy

supplies to a low-carbon portfolio operating on a smart grid. In addition, given the significant 

uncertainties surrounding many environmental and health problems, comparing the risks helps 

prioritize which uncertainties require most urgent attention and resources and how scarce 

dollars to support needed research can best be allocated.
9

Figure 2. A framework for integrated risk analysis: Gigawatt-scale wind energy deployments

An integrated risk framework can provide a comprehensive approach to renewable energy 

testing and deployments. In addition, it can assist states and local communities in moving 

toward an integrated “measure” of impacts and judge their degree of severity and likelihood 

rather than unduly focusing on what may be the most obvious and contentious impact of today. 

Without an integrated approach, we are susceptible to “risk du jour” thinking because of legal 

or regulatory drivers (e.g., MBTA), the experience at the last site of deployment (e.g., radar 

interference), or the complexities of protecting endangered species (e.g., Indiana Bats, 

Whopping Cranes). All of these issues trigger sensitivities within the communities that are 

responsible for managing these risks, but it is a reactive approach—which we argue is the 

current approach. It allocates resources in a piecemeal fashion that does not reflect the actual 

level of ecological or human risks. Our nation has invested millions of dollars in studying 
10

potential risks. These studies have substantially enlarged our knowledge base of some landbased sector risks, (e.g., bird and bat collisions, radar interference, and property values) while 

uncertainty analyses and comparative frameworks have been neglected. Without these 

additional analyses, we will not be able to produce any measurable probability of 

endangerment. Moreover, we may not be investing in understanding risks that will become the 

showstoppers of tomorrow (e.g., visual effects on the seascapes and landscapes). 

Our experience tells us that “obvious” impacts of today at particular sites may not actually be, 

and often are not, the showstoppers of tomorrow. How does the nation move toward a more 

systematic assessment and integrated measure of risks that also allows a comparison of risks 

from present and future uses of our public lands, the Great Lakes, and our coasts? How shall 

we learn from the probabilities of consequences at widely separated sites and diverse marine 

and land environments? An integrated risk framework can indicate the areas of significant 

effects (both adverse and beneficial), the principal uncertainties that surround them, and the 

major knowledge gaps that need to be filled (Morgan & Henrion 1990). It provides a systematic 

and generic approach to comparing risks, assessing priorities, and formulating management 

strategies rather than reacting to what hits us on the head or what a special interest group finds 

resonates with their constituency.

What Is the Decision Problem?

The first step in developing an integrated risk framework is to define the decision problem. In 

the wind energy case, the decision problem is multi-layered with an overriding decision (i.e., 

how to effectively site gigawatt-scale land-based and offshore wind energy across our nation 

while minimizing and, wherever possible, avoiding environmental and social impacts). It is 

important to recognize that a decision problem should be defined before specific tools to 

measure potential risks are applied and before it is determined how the risk assessment will be 

framed and scoped. In some cases, the tools for measuring probability and consequences may 

not need to assess a problem more precisely if this level of detail is not necessary. 

It is beyond the scope of this paper to frame a possible decision problem that may focus on 

global decisions regarding which energy supply choices need to be built where and with what 

level of risks and benefits—a potential challenge for international organizations. The decision 

problem we are posing would focus on our national energy portfolio and making choices 

among the range of power generation facilities and transmission siting options. A regional 

example of a decision problem is one that analyzes the options of employing offshore wind 

projects that need underwater cables to connect to coastal load centers versus supplying power 

from land-based wind projects using overland transmission lines in the Midwest and the Great 

Lakes. The final layer of decision making may focus on a specific siting choice at one location 

or multiple locations. The framework can also inform a series of other critical decisions, such 

as deciding whether a particular risk level is “tolerable,” whether public concerns can be 

mitigated in a cost-effective manner, and whether an adaptive management strategy is 

appropriate. 

Sector Risk Analysis

The concept shows important linkages between the specific sectoral environmental and socioeconomic effects of deployment, leading to a summary risk characterization and uncertainty 

analysis (see Section 3.3, below). The list of sectoral areas shown in Figure 2 is comprehensive 

but not exhaustive, and it may be expanded to reflect specific priorities of a state or a region or 
11

a community making decisions about energy choices. Some states may add in coastal zone 

management issues, for example, as a separate sectoral evaluation to address marine renewable 

conflicts with other uses of the coastal environment, such as fishing or tourism. The sectoral 

risk analysis initially involves desktop studies and/or field surveys to gather evidence on each 

of these potential effects. Even at a first survey of sectoral risk, areas of particular concern may 

become apparent, whereas others may be expected to involve only minimal risk. To develop an 

integrated risk framework, of course, research may be needed in all of these areas to understand 

the sectoral impacts of deploying the technologies, to compare the seriousness of the risks, and 

to assess related uncertainties.

At any point in time, the knowledge base of any sectoral risk, particularly at a given site, will 

be incomplete, uncertain, and need further research. The wildlife issues are good examples of

the types of issues that require sustained research to clarify the significance of the risk and the 

development of appropriate tools and metrics for enlarging the knowledge base. A balanced 

approach to risk will reveal other sectors that need similar examination and application of tools

to contribute to a broader knowledge base, whether at the site, regional, or national level. 

The first review of sector assessment using this process may reveal showstoppers or areas in 

which risk tradeoffs may be required to meet broader decision goals and societal objectives, 

such as climate change mitigation strategies, new transmission lines, or national energy 

security. (This is shown in the extended risk row in the diagram. Section 3.4 details these risks.) 

The underlying objective is to arrive at an initial balanced assessment of potential problems or 

risks by summarizing risk characterization and uncertainty analysis. As the integrated risk 

framework shows, focusing on one potential impact (or engaging in “subsystem dominance,” 

which in the technical language of systems analysis is making one subsystem the whole 

system) while neglecting other risks carries the danger of inaccurate findings and poor 

decisions. For example, sound judgments cannot be made on site suitability based on any single 

sector (e.g., habitat fragmentation) alone. A judgment can only be made on whether the site is 

“suitable” in regard to that specific issue. Such an approach runs the risk of the “risk du jour” 

problem that has ambushed other energy areas, such as hydroelectric power, which for years 

focused on fish-friendly turbines while neglecting and underestimating the broader ecological 

and social risks and benefits. 

Each sectoral analysis has its own set of tools and methods that are applied to assess potential 

effects. For each sector, the probability and magnitude of potential consequences, as well as 

associated uncertainties, must be identified and assessed. Therefore, each sector will have a 

range of specific tools that are developed and/or refined over time to attain “better 

measurements” or temporal and spatial analyses for study results. There may be hundreds of 

tools available for any specific sector. Visibility and aesthetic issues, for example, require quite 

different approaches from assessing risk to birds and wildlife. Peer-reviewed measures and 

metrics for each sectoral analysis are thus essential and are part of an ongoing assessment 

process. 

The uncertainty levels that surround these sectoral assessments need to be examined and related 

to the seriousness of the risk and the value to decision makers (not only scientists) of improved 

information and more complete data. Here, value-of-information approaches, in which the 

contribution of further data to decreasing uncertainty is assessed, may be helpful. Where data is 

inadequate, expert elicitation (in which experts provide subjective estimates of risk and 
12

probabilities) may be needed to help fill the gaps. To date, the wind community has not applied 

these techniques. Such assessment, however, needs to be conducted using state-of-the-art 

elicitation methods, such as those pioneered at Carnegie Mellon University (Morgan et al 

2001). 

The best example of risk characterization with a variety of tools in the wind area, to date, has 

been extensive work focused on measuring the impacts of bird and bat collisions, but the wind 

community has yet to determine the probability and magnitude of these potential consequences 

at a particular site or across the nation. Meta-analyses indicate that between two and three birds 

per turbine per year is the current estimated risk. For the Mid-Atlantic region, NRC has 

estimated that wind poses a risk to 0.003% of all birds affected. (See Lilley & Firestone 2008,

NWCC 2004, and NRC 2007). Fifteen years of federal and private research and debate has 

substantially enlarged our knowledge about these risks, but at the same time, the wind 

community is uncertain about “biological significance” and potential population impacts. 

Ultimately, the communities, special interests, and politicians must navigate the 

uncompromising MBTA regulations, in which one migratory bird kill is unacceptable for 

potential listed species such as the sage grouse and endangered species such as the whopping 

crane. Clearly, more precise tools or science alone cannot resolve these uncertainties or 

determine acceptable risk levels.

Some states, however, are moving forward with pre- and post-construction protocols for 

monitoring bird and bat collisions as well as curtailment policies prior to the initiation of 

careful uncertainty analysis related to “risk tolerability.” Curtailment involves the shut-down of 

the turbines during low-wind nights when higher incidences of bat kills have been documented. 

The hypothesis has been made that turbine shut-downs during low-wind periods reduce 

mortality without a “significant” reduction in power generation or revenue in certain 

geographic areas (Arnett et al 2009, Baerwald et al 2009). But nagging risk questions as to 

whether such curtailment is justifiable in risk and economic terms, particularly as compared 

with the environmental effects of other energy sources or the risk of reduction of species from 

climate change, persist. Comparing the environmental risks of wind with other energy supply 

options is essential in reaching judgments about risk “tolerability” and invoking the 

“precautionary principle.” It should be noted that some biologists and decision makers believe 

that curtailment policies are a good example of how to apply the precautionary principle to the 

wind case. On the other hand, one could argue that the risks of not deploying wind and opting 

for traditional fuel supplies also should be evaluated.

Why have the scientific and permitting communities not been able to agree on the risk 

characterization of this sector? Are more precise and costly pre- and post-construction surveys 

for estimating bird mortality essential if the level of risk has not yet been judged to dominate 

other potential risks (such as species loss from climate change) as well as potential benefits 

(Thomas 2004 and Jetz et all 2007)? Ultimately, risks from wind siting need to be compared 

with the benefits of wildlife that may be saved from climate change mitigation. What if wind 

facilities were not deployed? How shall we assess those risks of deploying less wind energy 

over the next decade? Moreover, the debate needs to assess relative net risk, not the 

significance of absolute risks, of wind in the context of other energy supply options. We have 

to better understand how reducing the potential local risks of wind deployments compare with 

the option of not deploying wind and, therefore, not reducing our carbon footprint over time. 
13

There is a wide body of literature about science and decision making in which the application 

of best available tools and methods is called upon for examining risks and uncertainties to 

arrive at a level of confidence. All sectoral risks have different but incomplete levels of data 

and analyses available, and yet decisions still must be made. Uncertainties or data gaps 

continue to haunt decision makers in various sectoral areas. The lack of data, variability in data 

sets, and prevalence of uncertainties does not mean that decisions should be delayed or 

postponed. (More than 100 nuclear power plants were deployed before the long-term, highlevel waste problem was addressed in any depth, and hundreds of hydroelectric plants were 

built before fish-friendly turbine innovations). As we learn from the integrated risk framework 

approach, decisions must be made with the best available information at the time and under 

conditions of continuing uncertainty. As new information continues to evolve, siting decisions 

are revisited and mitigation strategies and adaptive management principles are developed. 

Another important aspect is the “influence” of uncertainty in particular decisions, as different 

decision makers attach different importance to different uncertainties! 

The major types of uncertainty that enter into complex decisions (Kasperson 2008) include:

• Risk uncertainty:

Such uncertainties arise from a multitude of sources, including data inadequacies, 

model parameters, disagreements about the scope of consequences, the use of subjective 

judgment when experience is lacking, differences in perceptions of voluntary and 

involuntary risks, and inadequate scientific understanding. Routine, everyday risks must 

be compared with rare, catastrophic risks.

• Communication uncertainty:

Uncertainties arise and abound in the various communication processes, beginning with 

communication from science to decision makers. But there are numerous stakeholders, 

each with different knowledge bases, abilities to evaluate, information needs, and 

opaque value systems.

• Decision options and benefits:

Multiple options exist for any health and environmental decision. Defining and 

assessing these options are filled with uncertainties. The relative costs of various 

options must be assessed, often with questionable data provided by the entity being 

regulated. Benefits of different actions for health and environmental protection must be 

estimated and valued and sometimes compared with costs. Benefit assessments pose 

their own rich array of uncertainties that decision makers must grapple with.

Sector Risk Characterization and Uncertainty Summary

Arriving at risk characterization and decision making for offshore wind deployments, for 

example, is an ongoing scientific and collaborative process involving marine ecology, public 

perceptions, fishing, tourism, as well as wind turbines and foundation technologies. To date, 

these efforts are primarily coordinated through the NEPA process that requires the preparation 

of environmental impact statements (EIS) and environmental assessments that are central to 

evaluating sectoral risks and complying with state and federal law. Deploying wind on the 

Outer Continental Shelf triggers NEPA compliance and the EIS process because it is located in 

federal waters. In the case of the Cape Wind project in Nantucket Sound, assembled NEPA 

documentation totaled over 3500 pages. (Cape Wind actually prepared two EISs – one for the 

U.S. Army Corp of Engineers and one for the Minerals Management Service, since the federal 
14

regulatory process evolved after the passage of the Energy Policy Act of 2005). Has this 

outpouring of pages led to better decision making in the future and a more precise measure of 

potential risks from offshore deployments? The NEPA procedures, though supporting an 

important level of public involvement and agency coordination, are not sufficient for 

formulating integrated risk management strategies because there is no cross-sector measure of 

probability, magnitude, or comparison of these risks with other sectoral risks (such as visual 

effects or community impacts), to say nothing about uncertainty assessment in Nantucket 

Sound. In addition, the Cape Wind example highlights another aspect of risk analysis which is 

how to manage low level risks (consequences) that are “amplified” by specific values and 

interests of vocal minorities and the media. .

Usage of the proposed analytical processes and risk measurements has the potential to 

contribute to a more balanced and systematic approach to gigawatt scale deployments of wind 

siting at local, regional, or national levels. At best, a business-as-usual approach may replicate 

protracted permitting processes that delay any near term climate change mitigation strategies. 

Another phenomenon within sector-specific risk assessments is that any area of impact may 

become more important than another at different sites at any point in time. There are a variety 

of reasons, however, why this may not reflect the “actual risk” or impact. Two reasons are 

noted below: 

• Agency priority: An agency mandate or regulatory requirement can skew assessment of 

risk because a particular species or plant may be defined “endangered” under the law 

and the agency mission requires its protection. Protection under the law is central to 

how we evaluate whether a species is important, but this species may not be significant 

in relation to renewable energy deployments over time and space or to the overall risks

at a particular site. This has the danger of skewing the overall approach to risk and what 

is regarded as the most important issue to be addressed (sometimes called “subsystem 

dominance,” as mentioned previously).

• Uncertainty: Given the limited level of deployments at this stage on land and in the 

water, and the limited and uneven sectoral knowledge base, there are many unknowns 

and deep questions about baseline data and the range of risks in the future. These 

“uncertainties” can create a false sense of high risk that may or may not actually exist 

across sites. The pre-occupation with uncertainty and what is not known can skew the 

potential problem areas and can create a perception of “a showstopper risk.” As a recent 

National Research Council (2005) report makes clear, and as noted above, not all 

uncertainties are reducible by science. Risk management has long recognized that most 

decisions must be made under conditions of uncertainty.: Decisions cannot wait for 

perfect information and certainty. The military radar area may be a good example of 

such uncertainties. In this case, agencies and analysts must decide whether this is a 

priority risk on which to focus because the impacts are “intolerable,” or that they are 

easily reducible with advanced technologies or software applications.

While these sectoral analyses are being assessed and further research conducted, decisions 

should not be delayed regarding which risks are tolerable. An integrated risk framework can 

help to inform “risk acceptability,” or better “risk tolerability” decisions, by applying the best 

scientific judgment and peer reviewed tools and methods along with the incorporation of public 
15

values. Risk tolerability is an issue that can be raised but not answered by science since what is 

“acceptable” is not a scientific question. Inevitably, it involves the application of public values. 

If it were science based only, we would arrive at decisions in a more linear fashion and solve 

the question of “how safe is safe enough” within scientific communities. However, these 

decisions necessarily involve community and individual values at particular places, 

comparisons across other activities, and legal mandates to frame the decision broadly and 

logically, with sensitivity to community concerns. 

“How safe is safe enough” has been one of the conundrums of environmental and health 

protection. It is no less an issue for renewable energy. A comparative and integrated framework 

for risk is needed to make judgments on risk tolerability. Deep knowledge of one or two 

sectoral risks, at the expense of the full range of risks, always entails the chance that the key 

risks of concern at the next site will be different than the last, and so strategic decisions, and not 

a lopsided assessment approach, are essential. Decisions about risks are always made without a 

full suite of data or a completed methodology. There is almost always a need for more data –

the clarion call of every scientist and analyst. Risk decision making, however, must proceed 

while further research, deliberation, and analysis move forward. It is widely acknowledged, as 

in the 2008 NRC report (NRC 2008b), that critical decisions cannot be deferred because 

uncertainties still exist. 

In summary, sectoral risks must be assessed and evaluated by their own set of peer reviewed or 

collaborative tools and methods, as has occurred in the wildlife area of land-based wind 

projects. However, individual impacts must be compared within a site or a region in order to 

determine overall risk tolerability across the sectors. A skewed or single-sector view of these 

impacts, or “subsystem dominance,” carries the threat of poor or lopsided decision making. 

This can also result in endless studies and permit requirements that increase the cost of 

deployment by requiring ever more precise measurements to reduce uncertainties that cannot be 

fully removed.

The end product of this first stage of analysis is a sector risk assessment that also must be 

informed by stakeholder involvement. At the end of this, the decision problem should be well 

defined, the major sector risks identified, and the major tradeoffs and showstoppers apparent. 

The risk characterization summary gathers the evidence within and across the sector risks to 

compile a type of initial meta-analysis of risks. This summary identifies the significant risks, 

their probability and magnitude, and the base for an initial risk tolerability judgment. The 

analyses also highlights the probability of rare but catastrophic risks as well as potential major 

events or surprises possible in the wind power area.

Extended Risk Analysis

After the individual sector evaluations and their comparisons and the summary risk 

characterization, including major uncertainties, we move to decisions focusing on a more 

complex extended risk analysis. These address life cycle effects, building the necessary human 

and physical infrastructure (such as transmission lines), public perceptions and concerns, major 

benefits, and cumulative risks.

There is a need for life cycle risk assessment across all energy supply options in order to make 

clear decisions for designing the future national energy system. Such an assessment has been 

undertaken by the European Union (ExternE 2009) through a series of studies, but the U.S. has 
16

yet to conduct such an extensive comparative analysis. In the early 1990s, the U.S. Department 

of Energy combined its efforts with a similar project by the European Communities to study the 

major negative and positive externalities associated with the fuel cycles involved in electric 

power generation. This collaboration produced a multi-volume report, which chiefly focused on 

the byproducts of fossil fuels (Oak Ridge National Laboratory & Resources for the Future 

1992). Over the last two years, research initiatives from New York State Energy Research and 

Development Authority (NYSERDA), universities, and the NRC (2009a) have attempted to 

construct comparative analysis across energy options. The NYSERDA (2009) study focused on 

qualitative measurements of potential wildlife impacts across all energy supplies. A lifecycle 

assessment of the various renewable energy options, however, never has been prepared for a 

future U.S. national energy portfolio. A full life cycle assessment would conduct a cradle-tograve analysis, from securing raw materials to manufacturing components through to the 

recycling or disposal of components in the decommissioning phase. It is important to compare 

the life cycle risks of alternative energy sources with fossil fuels and nuclear power, especially 

since renewable energy supplies are likely to have fewer deleterious life cycle issues as 

compared with those alternatives. 

The life cycle analysis should assess qualitatively the potential impacts at each stage of the 

lifecycle to arrive at relative risks (but not necessarily quantitative measurements). Again the 

crux of this analysis is a comparative assessment across energy supplies (as in the ExternE 

studies mentioned earlier) and across significant risks, such as acid deposition, mercury 

contamination of fish, bioaccumulation of chemicals, and contributions to climate change 

impacts. This analysis creates a balanced framework and underpins a national debate about 

potential risks and benefits of transforming the energy system that President Obama has 

alluded to.

Infrastructure issues include the construction of energy facilities, as well as the substations and 

transmission lines, that are needed to transport energy supplies to the loads in urban and rural 

areas across the nation. Gigawatt-scale wind energy will significantly change how the existing 

electricity grid operates, adding requirements for more transmission capacity, integration costs, 

energy storage, and reliable backup generation. As such, the challenges of integrating high 

levels of renewable energy into the electrical grid are an area of major focus. The Utility Wind 

Interest Group was organized in 1989 to address the issues surrounding the integration of wind 

power into utility systems. Two unprecedented challenges are at the center of this issue: the 

need to reliably balance electrical generation over the grid when a large portion of energy is 

coming from a variable power source such as wind, and the impacts of constructing the 

thousands of miles of transmission lines that are needed to support gigawatt scale renewable 

energy deployments (DOE 2008). Uncertainties remain over the most effective means to 

integrate variable power sources, such as wind, into the national electrical grid. A full system 

analysis of cycling fossil plants and smart grid systems impacts on CO2 and NOx is needed. 

Current research priorities include developing advanced weather forecasting techniques in 

order to anticipate upcoming changes in the amount of wind energy being generated and 

investigating energy storage systems to capture wind energy generated at off-peak times for use 

later. Implementing a risk analysis of integration issues requires a team of experienced 

electrical systems engineers as well as risk analysts. 
17

Beyond the technical integration uncertainties are the siting and deployment challenges of 

building the transmission lines needed to support gigawatt scale renewable energy 

deployments. Weighing the risks of transmission siting, along with the benefits of 

“transporting” electrons with lower carbon content, are part of an integrated risk framework. 

Several recent initiatives evaluating transmission siting lack an overall risk framework (e.g., 

Texas Clean Renewable Energy Zone [CREZ] process) or focus only on some sectoral risks 

(e.g., the Western Renewable Energy Zone process addresses wildlife, habitat and cultural 

resources). 

Transitioning to a cleaner energy portfolio requires a workforce and a public that is much more 

conversant and comfortable with new, advanced energy technologies. A lack of human capital 

could limit the nation’s ability to significantly increase the penetration of clean technologies. 

The nation’s workforce development infrastructure is relatively unfamiliar with renewable 

energy technologies and unprepared to scale-up quality training. A gap analysis is needed along 

with a separate assessment of health and safety requirements to reduce the potential risks to 

workers and communities. Furthermore, knowledge of the technologies and tools that can help 

meet climate change challenges and related energy and environmental goals must permeate the 

nation’s education system at all levels. These structural and human dimensions pose another set 

of risks and benefits that will need to be incorporated into this risk framework and into 

subsequent national energy decisions.

Analyzing cumulative effects is a challenging scientific and assessment task, primarily because 

of the difficulty of defining the geographic (spatial) and time (temporal) boundaries of the 

affected area. For example, in the NEPA regulations, cumulative impacts are defined as “the

impact on the environment which results from the incremental impact of the action when added 

to other past, present, and reasonably foreseeable future actions regardless of what agency 

(Federal or non- Federal) or person undertakes such other actions.” A full cumulative 

assessment, of course, must address people as well as the ecosystem risks. A 2008 NRC report, 

as well as recent writings on vulnerability, emphasizes multiple stressors in the generation of 

risk (NRC 2008b). NEPA provides a framework for advancing environmental impact analysis 

because it addresses cumulative effects and methods for addressing coincidental effects 

(adverse or beneficial) on specific resources, ecosystems, and human communities including all 

related activities, not just the proposed project or site activity. Considering cumulative effects is 

also essential to developing appropriate mitigation and monitoring its effectiveness (CEQ 

2005). In their environmental analyses, however, state and federal agencies routinely define the 

effects too narrowly (sector by sector) so that significant issues may be missed and decision 

makers will not be completely informed about the full consequences or risks of their projects. 

In most cases, therefore, NEPA stops short of a full risk analysis because it does not compare 

projected cumulative effects of alternatives and the ability to avoid or minimize adverse 

consequences. Moreover, the analysis of current and foreseeable future activities on land, in the 

sea and along the coasts must be developed considering stakeholder perspectives. There are 

some valuable analytical insights for evaluating cumulative risks, cumulative impacts and 

community-based risk assessments based on the recent NRC report, EPA publications, and 

Council on Environmental Quality guidelines (EPA 2003). 

There is a rich literature about assessing and integrating public concerns into risk decision 

making and public policy areas (NRC 2008b, Slovic 2000, Kasemir et al 2003). The focus here 
18

highlights the importance of public involvement and agency interactions in defining the 

decision problem, the risk issues to be addressed, value concerns that may be important, 

incorporating local knowledge into the assessment, and potential social amplifications of risk 

that will need to be addressed (Pidgeon, Kasperson, Slovic 2005). The first step is identifying 

stakeholders ---who are the stakeholders and what are their concerns --- and the myriad sitespecific scenarios and issues that arise. Essentially, risks associated with wind and other 

renewable energy are highly site-specific. They vary substantially from site to site and thus 

cannot be assumed to be similar across sites. The risks which will be dominant at any site 

cannot be assumed but must be the product of analysis and interaction with stakeholders. While 

bat or raptor fatalities may be the issue at one site, visibility, aesthetics, or historical properties 

may be the major issues at other sites. How will decision makers know what is most important 

to their communities? There must be a commitment to sustain the work that is underway within 

state and regional working groups and to apply the innovative approaches in public 

participation that were recently assessed by the National Research Council (NRC 2008b). 

Climate change has emerged as a high priority area for national policy and for cooperation at 

the international level. It has been a major plank in the Obama administration, as suggested in 

numerous statements of the President and his appointment of a high level climate czar. The 

work of the Intergovernmental Panel of Climate Change (IPCC) and earlier analyses of other 

influential reports, such as the Millennium Ecosystem Assessment and the U.K.’s Stern Review 

underscore the urgency for interventions to reduce climate change over the next two decades. 

These reports have highlighted the risks to ecosystems and concerns with the ongoing 

extinction of species associated with climate change. Wind and other renewable energy sources 

offer important potential roles in meeting climate change goals and contribute to reducing 

serious further damage to ecosystems. Loss of species from climate change, for example, need 

to be weighed against what now appears to be relatively localized and small environmental 

effects from wind turbines at individual sites. Albeit greater risks to endangered species, 

species of concern, and critical habitat raise an important conundrum that requires open debate 

and decision making among stakeholders within the context of wind and other renewable 

energy benefits. What is needed is a comparative analysis of net losses or gains associated with 

particular energy generation sources. Without this analysis, an equitable evaluation of risks and 

benefits will be very difficult and research priorities and scarce resources cannot focus on the 

significant risks that have the possibility of being reduced in a cost effective way. Hopefully, 

the ongoing climate change analysis of the NRC, scheduled to appear in 2010, or other studies 

will address these issues.

Energy security is a second policy domain related to important national policy objectives. The 

international energy cartels and the geographic locations of energy supplies outside of our 

borders highlight the importance of building a diversified, domestic energy portfolio. The 

prospect for substantially enlarging wind energy in the U.S. carries significant value for 

enhancing greater political and environmental security for the nation. Again a full risk 

assessment considers this type of risk and the prospective gains or losses to national security 

which may be associated with different energy needs.

Comparative Analysis and Determining Risk Tolerability

To understand the acceptability or tolerability of risks, comparative risk assessment must be 

conducted. This comparison should occur on both the “intersectoral” level at a specific wind 
19

site and through a risk comparison across sectors against other energy supply options. It also 

should draw upon the results of an extended risk analysis because the important risks may be 

found in life cycle effects, cumulative risks, or public perceptions, rather than the more obvious 

sectoral effects. Since risks are probably never fully accepted but only tolerated to gain various 

benefits, we use the term “tolerability” here rather than the more common “acceptability.” The 

potential tolerability of risks from habitat fragmentation and/or visual landscapes, for example, 

acknowledges that these are complex matters based on values in which people will disagree. 

Once we have gauged the tolerability of risks, a sound knowledge base exists to make the 

decisions for risk reduction and management approaches. Then, these risks can be compared 

with other risks in the same option, and other energy options. to decide whether the 

“significant” risks can be reduced easily and at what cost (to the developer and society). 

Decision makers need to prepare for “unacceptable risks” that would require government 

actions and/or public consultations. Again, since “tolerability” is not primarily an issue for 

science, involvement of stakeholders is critical at this stage because tolerability requires 

analysis of public values. 

Management Options and Strategy

Selecting a risk management strategy is essential for moving wind into a gigawatt scale 

capacity. These issues go beyond technological R&D challenges, but we are not yet prepared 

for this national shift. Since wind technology, for example, is now commercially deployed, the 

challenges increasingly focus on better capacity factors and lower costs. An integrated risk 

framework begins to grapple with this range of issues and keeps the interested parties and 

policy makers current with the reality on the ground and perceptions of the communities taking 

on the risks. An integrated risk framework is valuable not only in demarcating where major 

uncertainties lie but also identifies various options for risk reduction that are open to decision 

makers. Risk assessment provides valuable analyses and data collection for the decision maker, 

though the integrated risk framework is not designed to perform a multi-objective analysis 

required for energy supply decision making. All risks involve a chain of risk evolution (or a 

causal structure) consisting of the following steps shown in Figure 3:

Figure 3: Causal Chain of Risk

The causal chain begins with the societal need for energy and then a specific choice for wind 

energy. A risk event or a stressor affects a receptor (e.g., visual impairment, habitat loss, bat 

deaths, mammal migrations) and some receptors become exposed. The receptors each have a 

different sensitivity to the exposure (e.g., aesthetic perceptions of people or endangered species 

sensitivities to habitat changes). How much exposure from this risk event and the sensitivity of 

the receptors to the exposure determines the type and magnitude of the consequences. As noted 
20

earlier, the historical application of ecological risk assessment to wind did conduct this type of 

analysis through the measure of exposure and sensitivities and made a valuable contribution to 

our understanding (Efroymson 2007). The full consequences, the probabilities, and 

uncertainties, however, were not identified or estimated. Ultimately, without these analytical 

stages along with a comparison of energy choices, neither a final metric of risk is possible nor 

decisions on priority research to reduce potential risks and uncertainties.

Each stage has a probability of occurrence and level of uncertainty associated with it as well as 

feedback loops. Each stage also involves the possibility for management intervention to reduce 

the risk. A major need in management assessment is analysis of risk reduction options in terms 

of such criteria as cost effectiveness, impacts on industry, and equity in health and 

environmental protection. For many risks, there is recognition that management strategies are 

iterative and evolutionary. They are not made once but in sequential moves over time as risk 

knowledge grows and experience is accumulated with differing risk reduction interventions. 

This paper does not advocate one particular risk management strategy but for better analysis 

and strategic thinking. In some cases, decision makers will defer risk-related decisions or opt 

for adaptive management strategies when uncertainties are large or not easily reducible. A

“mature” risk management system typically evolves over time, as various interventions are 

tried at different steps in the causal structure and an effective and efficient risk management 

approach evolves.

A risk communication program focuses on the significant risks and associated uncertainties. It 

should be formulated and undergo peer review, and public review in a sustained and deliberate 

fashion. It typically becomes integrated into a well-considered program of public engagement 

in the siting process. It is supported by a sustained effort of public perception research, how the 

public and stakeholders’ views evolve over time and why. This is the basis for identifying 

“target” audiences, discovering the nature of their knowledge and concerns, and how to educate 

them. This process begins at the first stage of development and continues throughout the 

program. Ongoing third party evaluations inform changes in the stakeholder and management 

program design. Ideally, state or federal governments could lead this effort. This understanding 

affects the planning process and results in management adjustments to address different 

evolving concerns, especially as wind facilities are deployed at a faster rate. Current wind 

research programs focus primarily on site-to-site variations. The management plan, however, 

must be able to weigh regulatory requirements, mitigation strategies, public concerns and 

ongoing risk research and be flexible and dynamic in responding to risk information and 

events. This becomes the basis for informing those with a need to know of their major risks, 

associated uncertainties, and options for risk reduction. Public involvement in a risk 

communication strategy and program, developed with leading national experts should 

incorporate (Kasperson 2008):

• An identification of stakeholders and those at potential risk who need information

• An assessment of the stakeholder’s needs which the communication program will seek 

to address

• Strategies for two-way communication with these stakeholder groups

• An ongoing evaluation of program effectiveness and needed strategy changes. This 

includes learning from experience as events occur and communication changes are 

suggested
21

• Creating links between communications and actions people can take

• Evaluating the resulting outcomes of the process with consideration of cost and time

A particularly valuable contribution of an integrated risk framework outlined in this paper is to 

shape smart siting strategies that would be designed to take advantage of where the renewable 

resources exist to minimize potential risks (and particularly those related to community 

concern) to various stakeholders (e.g., risk perception), and to select management approaches 

that mitigate potential risks in a cost-effective and publicly supported ways. This is a structure 

and process with the potential to avoid risks and stave off unnecessary conflicts. It must be 

recognized that social trust may be in short supply and that strategies to build that trust are an 

important part of a risk communication program.

Where the wind is blowing is essential information, but there is a range of potential 

environmental and human risks that need to be considered for smart siting strategies. From the 

integrated risk analysis outlined above, a sound knowledge should be in hand of what the major 

risks are, where the important uncertainties lie and an understanding of who the major 

stakeholders are along with the nature and basis of their concerns. This knowledge provides a 

valuable base for choosing sites with good wind resources and potential links to the grid, but 

also avoids significant risks and public conflicts. Siting strategies should proceed in a way that 

engages potential host and adjacent communities that may be impacted at early stages,

emphasizes communication and transparency, and responds to local concerns. A siting strategy 

should emphasize process rather than a checklist and should seek a collaborative approach with 

state and local officials and other stakeholders as well. The goal should be to build strong local 

support that addresses local concerns, to shape siting to enlarge project benefits while reducing 

risks, and to build trust and confidence among those who ultimately bear the risks and adverse 

impacts.

As yet, siting consideration in wind energy development has largely centered on technical 

issues concerning the areas of substantial wind resource availability and the potential for 

connection to the energy grid. Moving from the current 1-2% of the energy supply to a 20% 

share by 2030 requires a broader, more robust approach to wind plant siting. Fortunately, the 

nation has extensive experience with siting controversial facilities, including many (e.g., 

nuclear plants, liquefied natural gas (LNG) terminals, and increasingly, fossil fuel plants). The 

superfund program and experience with radioactive waste facility siting provides additional 

experience on which wind energy can build. What is needed is an inventory of potential sites 

for electric utilities across the U.S. that accounts for the range of factors in siting success. This 

includes potential environmental issues such as bird and bat collisions, but also issues of public 

concerns and acceptance, visibility and aesthetics, and conflicts with recreation and tourism. In 

short, development of siting strategies must go beyond narrow technical appraisals to include 

more collaborative approaches with potential host states and communities. Well developed risk 

communication and stakeholder involvement programs are essential so that a synopsis on the 

process of site identification, assessment and selection will be a sine qua non for smart siting of 

the next generation of renewable energy facilities. Fortunately, a large body of analysis 

drawing on previous siting experience in the U.S. and abroad exists to guide the formulation of 

“smart” siting strategies (Kunreuther, Fitzgerald & Aarts 1993, Shaw 1996, Lesbiril 1998, and 

Broholm & Lofstedt 2004).
22

Complete information and certainty does not exist for any environmental, health, or risk 

problem. Therefore, a major need in any area of technology deployment, including renewable 

energy, is risk research prioritization to best fill gaps in the knowledge base or to understand 

more adequately the uncertainties that surround the risk problem at stake. While expanding the 

knowledge base and filling existing gaps are major raison d’être for science, available funds 

are always scarcer than the interesting scientific problems. Therefore, prioritizing risk research 

is a continuing challenge in almost all technology development areas, including renewable 

energy. Yet, a risk prioritization program makes the most efficient use of scarce research 

dollars. Considerations include: 

• How much can the risk be reduced through further research and in what timeframe? 

• How deep are the uncertainties? – do they arise from data needs, a modeling problem, 

or do we basically not have a scientific understanding of the risk phenomena?

• Most importantly, how do the uncertainties interact with the profile of the risk – where 

will progress or reducing uncertainties most contribute to reducing overall risk? 

A hard-nosed approach to setting research priorities is needed – it is not what fascinates 

scientists but it makes for a robust knowledge base for decision makers. Risk research priorities 

need to be driven by management decisions that must be made now and in the future, in order 

to implement a sound and sustainable energy future for the nation. In May 2009, the DOE wind 

program announced a list of grants focusing on “environmental impacts,” and all 12 projects 

related to birds or bats (DOE 2009). Federal research priorities have focused to date on the 

impacts of wind development on wildlife and on radar systems for military and aviation 

applications. These priorities have arisen reactively and retrospectively, in the sense that they 

were identified as issues to consider only after projects had been halted at substantial cost to 

stakeholders. Moving to an approach that addresses siting risks in a comprehensive and 

prospective way could enable federal agencies to avoid these costly surprises. 

Minerals Management Service, on the other hand, approached offshore wind research priorities 

in a more systematic way. First they initiated a Programmatic Environmental Impact Statement 

for their alternative energy program, as required by NEPA (drawbacks in the NEPA process for 

risk decision making was addressed earlier). They also commissioned a synthesis of studies in 

Europe related to offshore wind projects, a valuable step in a developing a baseline knowledge 

of this wind area. Later, a workshop was organized with experts and stakeholders to list their 

top issues and rank priority concerns without a risk-based framework. This led the agency to 

fund several projects, including surveys related to coastal avian migrations, electromagnetic 

impacts, and visual impacts to historic properties. It is not clear whether these studies were 

based upon a risk framework and/or address the most significant risk from offshore 

deployments. 

It may be useful to consider an early example to establish program priorities in a systematic 

way. In the late 1980s, EPA’s Science Advisory Board went through an exercise to rank risks 

that EPA was confronting in its various programs. The Board first considered how the 

Agency’s experts ranked the various risks that the Agency was facing in terms of their health, 

safety and environmental importance. It then reviewed how the public ranked these various 

problems. Then, it compared these two rankings with how the Agency budget allocations 
23

correlated with public concerns more than with the assessment of its own experts. This, of 

course, raised many questions as to how allocation priorities were being made and what drives 

the decision and the priority-setting process (EPA 1990).

Research priorities in the renewable energy area need to stake out a different approach to 

setting research priorities, beyond the core technology R&D areas that have been DOE’s 

traditional focus. A balance is needed using the following principles: 

• Balancing goals and knowledge needed by various decision makers and stakeholders 

• Cost-effectiveness and the likelihood of greatest reduction of risk, given large 

uncertainties

• Investment in decisions with short-term payoffs vs. high-risk/high-gain longer term 

research

Following decisions based on comparative analysis of different energy sources and their 

tolerable risks, the legal and regulatory structures should reflect these decisions. The legal 

structure should establish priorities in order to create the climate for changing our energy 

portfolio. The current legal system was not prepared for the leap into offshore renewable 

energy, although the Energy Policy Act of 2005 required new federal rules within one year. In 

April 2009, new regulations were published for managing wind and water power technologies 

on the OCS (MMS 2009). This almost four year delay in finalizing these regulatory structures 

further postponed the planning process for offshore wind technologies. This is occurring amidst 

the recent push by East Coast and Great Lakes states to deploy offshore wind. Given the shift in 

the national political picture with the Obama Administration, the regulatory and institutional 

structures would also need to evolve in order to support the build out of low-carbon 

technologies in consideration of climate change policies (DOI 2009). The most obvious and 

significant shift would stem from the move toward a carbon price with a tax or cap and trade 

system. 

Permitting requirements for wind energy should reflect a national shift away from traditional 

fossil fuels as well. Currently, these wind permits are based on state rules and practices that

vary across the 50 states – reflecting their individual and societal values. The expected 

voluntary Fish and Wildlife Guidelines for national wildlife management at wind sites 

mentioned previously would more clearly address the broader context, if they incorporated risk 

characterization, comparative principles, and climate change. These guidelines are expected to 

expand the requirements for wildlife and habitat surveys pre- and post-construction, however, 

they do not necessarily reflect the significance of the risk. The MBTA rule is a good example 

of a legal structure that pre-determines risk tolerability. Risk tolerability decisions, then, are in 

the hands of politicians and bureaucrats rather than biologists. Thus, even legal structures and 

rules must incorporate an integrated risk analysis in order to move toward a low-carbon 

portfolio that includes gigawatt-scale wind developments.
24

Summary

1. An integrated risk framework informs decisions, but does not provide risk tolerability 

answers since this “number” necessarily stems from value-based decisions that are 

made by public officials not scientists or industry experts.

2. Integrated risk assessment is an analytical framework to better site wind facilities, to 

involve the public, to reduce those uncertainties that really matter, and to avoid or 

reduce risks.

3. Agency-specific missions and special interest groups can and have produced skewed 

frameworks of assessment where one risk is assumed to be more significant on the basis 

of incomplete or skewed analysis. This “subsystem dominance” in assessment and 

management carries a high threat to a balanced assessment and sound decision making. 

A more integrated and systematic framework is needed.

4. Specific tools and metrics for each risk area or sector are needed, but an integrated risk 

framework is essential to guide the identification of tradeoffs and priorities for risk 

research. In particular, it can provide guidance as to how scarce research resources can 

best be allocated and which uncertainties are important. It is a worse error to omit a 

major impact than to measure an impact imprecisely (Weiner 2008).

5. Judging risk tolerability is not a scientific decision process, but one that involves 

political and community interests, ongoing stakeholder involvement, and comparisons 

among risks associated with choices among energy options.

6. Ecological risk assessment is a valuable tool for evaluating wildlife and habitat risks 

from renewable energy siting, but must involve a comparison with other energy options 

and other sectoral impacts for a fair analysis of environmental consequences. In 

addition, this approach needs to be extended to human systems for a systematic 

appraisal of risk. 

7. Uncertainty analysis is essential throughout the assessment and comparison among the 

risks but should not become the basis either for premature risk judgments or constitute a 

reason for risk management inaction.

8. Stakeholder involvement is essential at all steps in the assessment and decision process, 

and should be supported by effective communication strategies and collaborative 

decision making – in short, two-way communication and decision making.

9. Identifying major uncertainties, research gaps and significant risks as well as methods 

for reducing uncertainties and catastrophic risks needs to be central to identifying the 

risk management pathway and cost effective strategies.

10. Environmental effects that involve threatened, endangered, and sensitive species and 

critical habitat must be incorporated into the policy framework and risk research agenda 

as well as through appropriate legal instruments.

11. Scoping the elements of adaptive management and enforceable principles are central to 

a successful risk management strategy. As yet, it is unclear which principles may apply, 

but this is an area where technology design and smart siting, for example, may benefit 

from experience and social learning. 
25

12. Risk management implementation has multiple objectives in a multi-faceted process 

that occurs in specific institutional arrangements, and social contexts, and requires 

sustained public involvement and collaboration with affected communities.

In conclusion, the purpose of an integrated risk framework is to identify and assess the major 

risks, avian, habitat, and human effects associated with a new technology or human activity in 

terms of potential impacts on human health and well-being and the environment. Done 

properly, it is systematic, rigorous, and comprehensive. It should be conducted in such a way 

that the potential risks of new or ongoing developments are considered and compared with each 

other. An advantage of a sound risk assessment framework is that very different risks can be 

compared with each other, can inform a prospective decision maker of concerns, and addresses 

the development of a new technology or facility. Such an assessment considers the probability 

of events or negative occurrences and their likely consequences.. A wide range of established 

methods are available for such assessments, ranging from technology assessment to exposure 

analysis, response relations, animal studies, public perception research, and consequence 

assessments.

Each risk typically entails some special methods and tools, such as assessing migration patterns 

or avoidance behavior of birds or using videos and photos for visibility concerns. Many of the 

methods are well-established and tested, but often not yet applied in a systematic way to 

particular issues or arenas. Risk assessment should include uncertainty analysis, since risks, 

unlike impacts, always refer to future states of existence and are, therefore, always subject to 

changing circumstances and animal and human behaviors. A thorough uncertainty analysis is 

an indispensable part of a sound risk assessment. Consideration of what can be done about the 

risk, whether mitigation, acceptance, or adaptation. Providing a well documented analysis of 

the options for risk research priorities, critical uncertainty analysis, risk management options, 

and communication strategies should be part of an integrated assessment and management risk 

framework.

Next Steps

This paper is only the beginning in a needed program of risk research for wind energy 

development in the U.S. Other important studies need to follow including these suggested next 

steps: 

• Establish a federal and state working group with experienced risk experts to steer future 

research and development of risk analyses related to wind energy.

• Develop a proposed pathway for realizing the industry objective set forth in the DOE 

report 20% Wind Energy by 2030 drawing upon the integrated risk framework as 

appropriate along with various other policy considerations

• Apply the framework to a well-developed, site specific case of wind (land-based or 

offshore) where substantial data already exists. This analysis would result in a risk and 

uncertainty characterization and a proposed risk management strategy at the site level. 

This will demonstrate how the integrated risk framework can inform decision making at 

the site and multi-site level. The site studies should involve a comparison of sites, such 

as a small island, a large state on the coast, the Great Plains, and an offshore location.
26

• Prepare a white paper on siting strategies for wind energy where risk will be an 

important consideration, but other factors will enter into the discussion as well (e.g., 

public perceptions and community concerns, collaborative approaches with relevant 

stakeholders).

• Design a case study focused on the Public Utility Commission perspective as they make 

important decisions on wind integration to the electric grid. Are they making decisions 

well? What data is used to make these decisions? What are the descriptive versus 

prescriptive aspects of their decisions and their regulatory constraints?
27

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31 

Appendix A: White Paper Peer Reviewers and Peer Review Workshop 

Agenda 

Name Title Organization 

Peer Reviewers

Robin Cantor Principal Exponent

Mary English

(provided 

comments via email)

Research Leader University of Tennessee

Roger Kasperson Research Professor and Distinguished 

Scientist

Clark University and Stockholm 

Environment Institute Board

Willett Kempton Professor, Marine Policy University of Delaware

Robin Gregory Senior Researcher Decision Research

Warner North President and Principal Scientist NorthWorks Inc. and Consulting 

Professor at Stanford University

Invited Observers to White Paper Peer Review Workshop

Mark Sinclair Vice President Clean Energy Group

Dave Stout

Chief, Division of Habitat and Resource 

Conservation U.S. Fish and Wildlife Service

Government and Laboratory Sponsors 

Bob Thresher Research Fellow; fmr. Director, National 

Wind Technology Center

National Renewable Energy 

Laboratory 

Karin Sinclair Senior Project Leader, National Wind 

Technology Center

National Renewable Energy 

Laboratory

Steve Lindenberg

(provided 

comments via email)

Senior Advisor, Renewable Energy U.S. Department of Energy

Patrick Gilman Presidential Management Fellow U.S. Department of Energy
32

White Paper Peer Review Meeting -- AGENDA

An Integrated Risk Framework for Gigawatt-Scale Deployments of Renewable Energy: 

The Wind Energy Case Study

June 25, 2009

10:00 a.m. – 4:00 p.m. (ET)

Location: Energetics Incorporated

901 D Street, SW, Washington, DC 20024

Overall Purpose: 

1. Introduce risk thinking and risk-informed decision making into the renewable energy 

debates, particularly relating to wind energy deployments in the U.S.

9:30 – 10:00 Breakfast

10:00 – 10:10 Welcome and Purpose of the Meeting , Bonnie Ram, Energetics 

Incorporated

10:10 – 10:30 Introductions

10:30 – 11:30 Peer Reviewers’ Comments on the White Paper

11:30 – noon Facilitated Discussion, Bonnie Ram 

12:00 – 12:15 Observers’ Comments 

12:15 – 12:30 Summary Findings for White Paper Revisions, Bonnie Ram

12:30 – 1:30 Lunch in Conference Room

1:30 – 2:45 Facilitated Discussion of Possible Next Steps:

1. Establish a working group to steer future research and development of risk 

analyses related to wind energy.

2. Develop a proposed pathway for realizing the industry objective set forth in 

the 20% Wind Energy by 2030 document.

3. Apply the framework to a well-developed, site specific wind case study (landbased or offshore) demonstrating how the framework can inform 

decision making at the site and multi-site levels.

4. Prepare a white paper on siting strategies for wind energy.

2:45 – 3:00 Break

3:00 – 3:30 U.S. Department of Energy Thoughts, Steve Lindenberg and Patrick 

Gilman

3:30 – 4:00 Wrap-up and Final Thoughts, Bonnie Ram

4:00 Adjourn
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Assessing the potential environmental and human effects of deploying renewable energy on private and public lands, 

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potential environmental and human impacts. The author argues that deployment of renewables requires a framework 

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