Slaughtering Endangered Species with “Clean” and “Green” Energy

COMMENTS Against the Proposed Increase of Incidental Take for Maui’s Nene and Hoary Bats

March 25, 2017

Attention: Mr. Glenn Metzler,Habitat Conservation Planning Associate

Department of Land and Natural Resources

Division of Forestry and Wildlife

1151 Punchbowl Street, Room 325, Honolulu, HI 96813

Email: Glenn.M.Metzler@hawaii.gov

C.c. Mr. Mitchell Craig,

Email: mcraig@sunedison.com

C.c. Amanda Childs,

Email: achilds@swca.com

Dear Mr. Metzler, Mr. Mitchell Craig, and SWCA Consultant Amanda Childs,

The state Department of Land and Natural Resources proposes to amended Habitat Conservation Plan to increase incidental take for the Hawaiian hoary bat from 11 to 62 adults (or juveniles surviving to adult), and for nēnē from 30 to 48 adults (or juveniles surviving to adult) during the remaining 20-year permit that was issued in 2012.

The project currently has an approved (but unscientific) Habitat Conservation Plan to monitor and mitigate for take of three bird species and one bat species protected under state and federal Endangered Species laws.

This entire proposal should be rejected and the only reasonable change that is needed, is to require honest scientifically sound research around all of Maui turbines for several years before any new conditions are given.
Here is the scientific truth about wind energy research in Hawaii Wind farms statewide are NOT killing more Hawaiian hoary bats than expected, these wind farms statewide are killing far more than what has been reported. This Maui wind farm is asking the state to increase the number of endangered bats and Nene it’s allowed to “incidentally” kill probably because
people are catching on to this industry’s fraudulent research that has been deliberately designed to hide carcasses.

Had proper research been done from the start of this project, the number of reported fatalities to endangered Hoary bats and Nene would have been far greater from the very first year of operation. The number of Horay bats and Nene alredy killed by these turbines has very likely already exceed the limits set in the new proposals. The proof I am submitting proves beyond any doubt the wind turbine mortality research that has taken place in Hawaii, has been so poor that there is no way to tell how many have bats, nene or what number of other important species have been killed by Maui’s turbines.

But there is one certainty in all this. That being that many more of all these species have been killed by Maui’s turbines than what has been reported to date. The proof I am submitting also shows that this industry and all those involved with these turbines, have no reasonable excuses to have not known the information I am submitting.

I will remind the Department of Land and Natural Resources and the Division of Forestry and Wildlife that pretending to do research is not science, manipulating data is not science and being exposed to
filtered information in the media does mean it is true. But most of all changing laws and rules for a corrupt industry will NEVER benefit any of Hawaii’s these endangered species.

Hawaii’s wind turbine studies are supposed to be looking for endangered species. But Having searchers monitor these huge wind turbines just once a week and only out 65–75 meters from the base of the turbines is a disgrace, guaranteeing that most carcasses will probably be missed. This nonscientific approach should have never been allowed in the first place because search areas were 5–10 times too small, search intervals far too infrequent and nobody except honest researchers should ever be allowed to touch turbine carcasses.

Below is proof showing wind turbines the size of those installed in Maui are launching tiny bat carcasses more than 100 meters. Many of these carcasses even with limited research and flawed methodology were further than 65–75 meters from towers. Keep in mind that farming practices and rapid crop growth were also taking place during these studies this data was taken from. This flaw hid many of the carcasses falling far from turbines and researches failed to bring any of this up in mortality reports.

From the information provided in the 6 images above it is very clear that with the research to date, Hawaii has no idea how many endangered species have been and continue to be killed by their turbines. Important carcasses are being missed with poor research, others probably hidden with still others seen, but reported.

As a wildlife expert and researcher, I am aware of the fake onslaught of false research being produced by this industry. The industry has used nonscientific research since 1985 to hide their slaughter to thousands of eagles and millions of birds annually. The Interior Department allows all this and this
represents the wall of corruption the good people in the country are up against.

For their fake research, this industry has given themselves small mortality search areas and infrequent searches because it is good for business. This industry allows employees to handle, hide or move carcasses during studies because it is good for business. This industry hides and does not report
carcasses because it is good for business. This industry also rigs data in studies to produce bogus estimates because it is good for business.

Back in 1985, was when the first and only truly scientific wind industry mortality study has taken place in America place. this study used search areas around 100 ft. tall turbines (including blade top tip
height) that were 50 meters out from towers. Hawaii’s newest turbines are up to 4 times taller and their spinning blades are 7–8 times longer. But since this first study, this industry’s search areas have been proportionally reduced by approximately 90% when compared to turbine size..

At Altamont pass over a 25-year period, using ridiculous 30–90 day wind industry search methodology, only a handful of bat carcasses were ever reported being killed by turbines. This small reported number was because most all of these tiny carcasses were being eaten or carted off before they could be found. Yet with daily searches is it likely many thousands of bats would have been found over this same period. I have proof of this estimate from a hidden study conducted long ago at Altamont using 48 hour search intervals. Ignoring the obvious is not science.

Here is another example where the animals carrying off the tiny bat carcasses were actually 2 humans………….

In the mortality report for the Criterion wind turbines it was claimed that searchers systematically searched along predetermined in transects in their search plots. These search plots were limited to limited small clear areas around towers some roadways. I was told about completely different carcass searchers by an eyewitness with access to the property (written statement and phone interview). I have a written statement and interviewed this person over the phone. He said he witnessed on two occasions workers randomly picking up carcasses from the cleared areas around these turbines, that were at the time also having formal mortality surveys. On both occasions two people were seen quickly picking up carcasses from the clear areas (roads and graveled areas) around the turbines.

These areas being picked over were also the designated search areas for the study.

They were seen dumping bat carcasses in a bucket and driving off to the next turbine. They were not seen with a pen, no hand-held devices, computers and no notebooks. I was told they did nothing but grab bodies and drive off to the next turbine. This eyewitness even talked with them and did see bat carcasses in their bucket.

He also reported that these two people did not appear to be professional and barely spoke English.
He also said he would be willing to testify to what he saw. This activity as told to me was likely an organized pre-scan for carcasses ahead of formal searches.

This observed activity was nothing close to being scientific. These turbines are also located in the known habitat of the endangered Indiana bat. I contacted the Interior Department about this but was ignored.

Based upon the carcass totals actually declared in the mortality report and after compensating for the tiny search areas that missed carcasses. It is safe to assume or estimate that thousands of bats went unreported in just a 7 month period around 28 turbines.

A Long History of fraudulent Wind Industry Research

Decades before wind turbines came on to the scene wildlife biologists used daily searches when looking for carcasses around communication towers. They did this because it was proven to be the most reliable methodology to get accurate mortality data. Periodic searches were also conducted far beyond standard search areas checking for missed carcasses. Generally, standard search areas were conducted as far out from towers as the tower was tall. With periodic expanded searches were conducted as far out as 1 1/2 times tower height.

But with a wind turbine spinning at 200 mph and smashing carcasses with great directional forces, even this search methodology out to 1 ½ times blade tip height is not good enough or scientific.

The wind industry primarily uses carcass data found in their “designated” search areas to estimate mortality. I happen to have evidence that shows over 90% of bird and bats smashed by turbine blades fall past the outer reaches of turbine blade tips. In other words, if a turbine blade is 50 meters then over 90% of the carcasses will be propelled beyond 50 meters from towers. Carcasses are primarily not looked for beyond the blade tips and the industry likes to pretend they do not even exist.

Methodology from a typical wind industry study

“ The 2015 casualty study occurred during the fall (August 1 — October 15) migration period for Indiana bats. Casualty searches were completed once per week on roads and gravel pads of 118 turbines from August 3 — October 14, 2015. Personnel trained in proper search techniques conducted the carcass searches. Searchers walked at a rate of approximately 45 to 60 meters (m) per minute (about 148 to 197 feet [ft.] per minute) along each transect looking for bat carcasses. Transects were spaced at approximately 5 m (16 ft.) intervals on road and pads, and searchers scanned the area on both sides out to approximately 2.5 m (about eight ft.) for casualties as they walked each transect. Bias trials of searcher efficiency and carcass removal trials were conducted.”

This may look good on paper but this search methodology is worthless.

Casualty searches in this study were completed just once per week on roads and gravel pads. I could scan easily every one of these cleared graveled areas around these turbines at least once a day. Waiting a week allows for scavengers and wind personnel more than enough time to pick up carcasses.

Making matters worse: “Casualties found outside the formal search area by observers or by FRWF personnel were treated following the above protocol as closely as possible. Casualties found in non-search areas (e.g., near a turbine not included in the sample of search area) were coded as incidental discoveries”.

In other words, wind personnel are allowed to touch and were picking up carcasses during this study which further invalidates any scientific credibility.

The word “incidental” is important here because it is a trump card for data exclusion, being used in wind industry studies. It also allows wind industry personnel to handle, move and even hide carcasses when studies are being conducted. When studies have a week, two weeks or even a month intervals, wind personnel have reams of time to locate carcasses ahead of searchers.

These research activities produce fraudulent research data. For example, at Altamont Pass during years of formal studies, dozens of golden eagles killed by turbines were excluded from mortality estimates because they have been placed in the incidental category. How do these dead eagles get placed in the incidental category? Wind personnel go around and pick them up ahead of the people doing standardized surveys.

The truth is that wind industry’s mortality research across America has changed from bad to worse over the years. For several years now, carcass or mortality searches used in the industry’s fake studies, are generally completed about once per week on roads and gravel pads of turbines.

In order to understand the absurdity of all this, imagine a mailman pulling up to a mailbox then glancing at your driveway. In a fraction of a second a carcass sitting there in a mangled heap would be incredibly easy to spot. Now think of the hundreds of stops a mailman makes every day. It is about that easy to pre-scan for carcasses.

Yet in the wind industry’s research now being produced, the industry makes it seem so difficult to find anything from the size a bat to an eagle in their search areas. At one time, there was some truth to this it but this is no longer the case because search areas have been conveniently reduced to roads and cleared areas around turbines.

The two people I mentioned that were seen quickly picking up the bat carcasses from the Criterion turbines had little trouble finding carcasses in the clear areas and only spent a few minutes around each turbine.

It is not difficult to search a road or and the gravel pad of a turbine site as anyone can see in this image from the Wolfe island turbines. Anyone with decent eyesight could thoroughly scan around dozens of turbines in these ridiculous designated search areas (roads and gravel pads) several times a day. At these Wolfe Island turbines, an eagle, gyrfalcon or snowy owl carcass could be seen from several hundred yards away, but it still would not be included in the data because these turbines had such tiny “designated” search areas.

How important are all carcasses?

Waiting a week allows more than enough time for scavengers, lease holder or wind personnel to pick up most carcasses. Just finding a carcass and flicking a few feet away from a designated search area excludes a carcass from the data. But it gets much worse because a single carcass found 100–200 meters away from a turbine base on a narrow road, could actually represent 200 or more carcasses in an honest study that fairly calculates for carcasses missed in the proportion of a search areas not scanned by researchers.

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How many birds are being killed annually by the wind industry?

The highest annual estimated bird mortality from wind turbines in the US is estimated to be 573,000. This estimate came from this study: Smallwood, K.S.. 2013. Comparing bird and bat fatality rate estimates among North American wind energy projects. Wildlife Society Bulletin 37: 19

With this estimate the author actually lowered the bird mortality/per MW/per year/ for the industry. The old FWS numbers of 440,000 bird fatalities per year were calculated with 25,000 megawatts (MW) of installed wind-energy capacity. This new 2012 opinion of 573,000 bird fatalities/year (including 83,000 raptor fatalities) almost cuts this old per MW estimate in half.
This estimate is also outdated by 5 years and his number was based upon 51,630 MW of installed capacity. Today because of wind energy expansion, there is at least 82,171 MW of installed capacity in the US. But even though this number is 5 years old, it is still widely used by the bird conservation groups, the media and Government agencies.

Worst of all, it was created from a culmination of fake industry studies that used a variety of highly deceptive research methodologies and tricks that lowered carcass data. Below are some of the research methods that I have uncovered that are used in wind industry studies:

(1) By searching turbines that are not operational so bodies are not found.

(2) By searching for bodies in grossly undersized areas around wind turbines.

(3) By not searching turbines daily or even several times daily which allows time for carcasses to be moved or hidden by employees, more time for bodies to be consumed by predators, and more time for picked carcasses to be picked up by leaseholders wanting to protect their incomes. The author of this study had search intervals 30–90 days for one of his 5 year studies.

(4) By not using trained dogs in in daily searches which could quickly find virtually every small carcasses in a large areas around each turbine.

(5) By avoiding turbines that are known to be killing the most birds at bats at a wind farms to be included in mortality studies.

(6) By avoiding searches during periods of high usage by migrating birds.

(7) By not counting mortality wounded birds that are found still alive or have wandered away from the tiny search areas around turbines.

(8) By not counting birds taken to rehab centers which are later euthanized or permanently placed in captivity.

(9) By repeatedly hiring industry insiders to make sure that wind industry protocol is followed.

(10) By not conducting mortality searches the first year of wind farm operation.

11) By letting farming practices plow carcasses into the ground and conceal others with dense crop growth in designated search areas during mortality surveys.

(12) By rigging data input and calculations and discarding very important carcasses from the data and declaring them “incidental carcasses”.

(12) By outright lying about problematic data such as fatalities to endangered species.

(13) By restricting formal search areas to the roads and cleared areas around turbines which only take a few minutes to survey. These also happen to be the easiest of areas for wind personnel to pre-scan for carcasses ahead of formal searches, and wind personnel during studies have always been allowed to pick up carcasses.

(14 ) By not allowing 24 hour camera surveillance on turbines that would expose the truth regarding mortality. Camera surveillance on wind turbines at Altamont was suggested by well-meaning biologists over 25 years ago and to this day it has never happened.

Using nonscientific methodology to create false data from the industry’s fake studies, is how this new culmination mortality estimate of 573,000 was created.
But there is much more. The author deliberately made adjustments and accounted for just increases in the tower heights of turbines over the years, as these wind turbines still had their original 20-foot-long blades.
Spinning turbine blades smash carcasses and send them flying great distances with directional forces. Turbines during high winds and located on steep ridge lines, can send carcasses flying several hundred meters. The industry’s fraudulent research pretends this does not happen. If a 20 foot turbine blade hits a bird and sends it 150 feet from the blade tip, then a turbine blade 150 feet long will send this same bird under the same conditions 300 feet.

The author did not take into consideration the incredible increases in turbine rotor sweep, increased tip speeds and proportional massive search area adjustments were not made. All this should have been done and to not do it, absurd. These adjustments should have accounted for turbines blades up to and over 300 feet in diameter.
This is not science. It is trickery, rigging and might even be considered stupidity to some. But the pattern of terrible wind industry research has taken place for so long and is so pervasive, that any excuses of researcher stupidity, appear to be virtually impossible.
Here is another wind industry example of the impossible. A 5 year Altamont study published years later gave very similar distance locations for hundreds of bird carcasses. The industry has known for 2 decades that about 85% of fatalities can be found within a 50-meter search radius around small 100-kW turbines (approx. 100 ft tall) with blades a mere 8–9 meters long. The authors of the study did not discuss any of this important information but did suggest expanding search areas for these small turbines out to 70 meters from towers. Most carcasses were found at an average distance 2–3 times the length of the turbine blades out from tower bases.

Currently the AWEA is claiming they are only killing about an average of 2.9 birds per MW and I expect this fake number fatalities per MW number to decline with the increased rigging of wind industry studies taking place.
For the sake of comparison, I will comment on some of the recent mortality studies that have been conducted by Stantec on the East coast. This company has been paid millions for their poor research and bogus results. The Stantec studies are important because in my opinion they represent the worst of the worst, that this industry has to offer.

In the last few years the average carcass distance reported by Stantec in their mortality studies at Wolfe Island, Kibby Mountain, Laurel Mountain, and Georgia Mountain in the Northeast, is about the same distance that was reported from the smallest 65–100 kw turbines at Altamont.
But there are huge differences between the turbines studied by Stantec and these smallest turbines. The turbines they write reports for, are 40–50 times larger. They reach 250–350 feet higher into the sky, they have blades that reach out 50 meters or more in all directions, and their deadly blade tip speeds are much faster than the early wind industry turbines. In fact blade tips move at about 3 times the speed of a major league baseball bat swing.
All of these factors are important in mortality studies because they contribute to greater blade impact force, more carcass wind drift from the higher altitudes, and impact points much further out from turbine towers. In one case the blade tip impact points were as much as 47 meters further away (56 total) from turbine towers as with the early Altamont turbines. Add into the equation, that some of these the turbines are located on high ridge lines and carcasses thrown towards the downward slopes will to drift even further.
Yet every one of these Stantec’s mortality studies I looked at defy the Laws of Motion and Gravity because the industry’s own data proves that any carcass hit by a turbine blade has a much better than 50/50 odds or 1 out of 2 chance of this carcass landing at a distance beyond a turbines outer blade length.

For the hundreds of carcasses reported in the Stantec studies, only a handful have been reported past the turbine blade length and the average carcass distance disclosed is about half the distance of the turbine blade length. The odds of this reported carcass distribution to have actually occurred for all carcasses around these huge 400 ft tall turbines, is so high that it cannot be calculated. In other words, the total reported carcass distribution from these studies, is not possible.
A simple drop test off any high bridge on a windy day could also prove this carcass point the industry ignores. Or one can just accept what was reported recently with this carcass wind drift information taken from a tower erected in the North Sea. …………….”It is founded on 4 pilings with a 256 m2 working deck 20 m above sea level (a.s.l.), and has an 81 m lattice tower in its southern corner and a 164 m2 helicopter deck at 25 m a.s.l. (Fischer 2006). Modelling carcass dispersal after collision with the tall lattice tower of FINO 1 showed that up to 90% of carcasses are likely to be missed, depending on wind direction and speed (own data). Here, only those events that coincided with, or were followed by, moderate winds could be categorized as ‘mass collisions events’. Other events,when many corpses might have been blown into the sea, may have been missed.”

My additional notes…..

This study did provide some important carcass wind drift information that has been deliberately ignored by wind industry research for 40 years. Keep in mind that besides wind drift, turbine blade strike collisions launch carcasses great distances beyond this industry’s tiny search areas.

Any way you want to look at all this, with the wind industry’ voluntary rules along with the lack of Interior Department oversight, there is very little if any scientific research being conducted .

From my independent research into this industry’s bogus mortality studies, the real number of birds or bats killed by wind turbines, is many millions of each are killed annually and depending on turbine locations at least 10–50 times higher than current estimates.
Is Federal wind industry related research being rigged?

Yes, and here is one example. The Altamont Pass area reportedly has largest density of breeding Golden Eagles in the world. This myth was made up from bogus wind industry research that began around Altamont in the 1990’s

Altamont is important because this wind energy site has been slaughtering golden eagles for decades. In 2015 the USGS published a report that estimated the eagle population to be approximately 280 pairs in a 2000 square mile region around Altamont. They came to this conclusion by relying on a previous bogus study with embellished numbers dating from the Clinton Era and then rigging the methodology used for this study.

The final USGS estimate of 280 pairs is even more remarkable when it is revealed that this study could only verify 11 occupied eagle nests that produced young in the region.

Look closely at these two images. One is from the fake Federal study, the other image is from a publication put together by the Mt. Diablo chapter of the Audubon Society with the help of the Ca Department of Fish and Game and numerous other local agencies.

The Audubon golden eagle nest map makes up a geographic area that amounts to about 40 percent of the area represented in the fraudulent USGS golden Eagle Population report from 2015. This Audubon shows 6 confirmed nesting sites and 4 probable unconfirmed nesting sites.

The Audubon information was derived from a local chapter with many years of observations by a great number of qualified people. This information also is consistent with my knowledge of the golden eagles living in this region.

Using this actual occupancy ratio from Audubon, the remainder of the USGS study area probably has no more than 12- 20 additional golden eagle nest sites.

The fraudulent USGS report from 2015 states:

“We documented a total of 138 territorial pairs of golden eagles during surveys completed in the 2014 breeding season, which represented about one-half of the 280 pairs we estimated to occur in the broader 5,169-square kilometer region sampled. The study results emphasize the importance of accounting for imperfect detection and spatial heterogeneity in studies of site occupancy, breeding success, and abundance of golden eagles.”

Why is this research bogus? The reason is due to the phony methodology used in this study and by falsely assuming from another bogus eagle study, that these eagle territories in this region are about 5 square miles in size.…. This is statement is not close to being true. "As a consequence, we used a probabilistic sampling approach to infer estimates of occupancy, reproduction, and number of territorial pairs of golden eagles."

On the upside, this convenient survey approach gave the industry the fake numbers needed to hide a declining golden eagle population and fake population numbers hiding declining eagle populations allow for more turbines to be built which create additional wind industry profits.

There is no question that from my expertise, intimate knowledge of the area and my own research on the golden eagles living in this area, that the eagle population estimate of 280 pairs has been exaggerated by at least 10 times.

Bogus unscientific research like this was submitted allowing a new rule to pass In Dec. 2016 so “industry” can kill up to 7518 bald eagles annually.

A few words about “Incidental Take” permits

If it were not for groups like Audubon and the Sierra Club etc. making millions off dead eagles and endangered species through mitigation, these groups would probably have a completely different opinion about wind energy’s “incidental take” permits.

In certain locations, incidental take permits may be required before construction of a wind farm. But as I have found with this industry, fake surveys are generated beforehand in an attempt to hide habitat usage by special status species. But when special Incidental take permits from the Interior Department are needed, it allows the killing of a certain number of these important species. But as it turns out research is being produced which exaggerates population numbers, which in turn makes it appear that more of these special species can be harvested without really hurting the population.

But even with this permit, whatever the certain number of take is, this doesn’t much matter either because there is no real accountability when research is unscientific and employees are allowed to touch carcasses. No wind industry accountability is the primary reason why over 35000 eagle carcasses have been secretly shipped to the Denver Eagle Repository since 1997.

It actually is a disgrace that our government considers any eagle and endangered species killed by modern wind turbine to be incidental, when the act of installing these knowingly very deadly turbines into habitat desperately needed by rare species is not the least bit incidental. In fact, the building of these turbines is so intentional and premeditated that the industry must rig their site surveys and mortality research to keep the public from knowing the industrial devastation caused to wildlife from wind turbines.

This wind turbine destruction and habitat abandonment occurs not only to eagles, but to most species that fly, when forced to share habitat with wind turbines. This industry’s growing mortality is so devastating to species, that it if it continues, it will cause extinction to many species and many new species will eventually be added to the endangered species list.

This wind industry’s destruction also happens to be an international problem. That is why the public has not been told of the disappearing eagles in Scandinavia and Scotland from wind energy. Instead fake United Kingdom studies like those produced by our Interior Department, are fraudulently declaring increases in eagle populations.

Are any of these turbines really needed in Hawaii?

No and Hawaii needs to move on from this highly toxic source of energy. If the Department of Energy were honest the public would know that the MW’s of energy reported for wind energy in the US is grossly exaggerated. The public would also be aware that enough cheap energy is being exported from the US to other counties that could produce triple the energy production from all of America’s wind turbines. This activity will last for decades, giving engineers plenty of time to completely redesign these terrible turbines.

Currently this industry is forcing America to trade these industrial towers, that will always produce just a small portion of our energy needs, for a coming extinction of species, with no change in climate and far fewer birds living across the world.

Hawaii’s geothermal energy Lastly Hawaii has been blessed with what might be the best source for geothermal energy development in the world. Instead of investing in a wind industry slaughter, their bogus research, and the extinction of endangered species, this is where the Hawaii’s renewable energy money should be spent. In addition, unlike wind energy’s very limited potential with little net energy actually getting to end-users, Hawaii’s geothermal energy potential is spectacular and could prove to be unlimited.

If the State of Hawaii chooses to have an open hearing about any of the topics I have brought up, I will be happy to attend if I am allowed ask questions of any expert present.

Jim Wiegand -Wildlife biologist