If wind blows, will fish grow? – Part 1

The GLC-sponsored Offshore Wind – Understanding Impacts on Great Lakes Fishery and Other Aquatic Resources Workshop* was held on Nov. 28-29, 2012, at NOAA’s Great Lakes Environmental Research Laboratory in Ann Arbor, MI. The workshop was well attended by roughly 50 participants representing resource management agencies, utilities, universities and policy experts.

The first workshop session was devoted to presentations by European experts on wind farm development and impact on marine and freshwater resources. Two of the three invited speakers, Åke Petterson Frikberg and Tore Wizelius, representing Sweden’s Rewind Offshore utility company, gave an informative presentation on development of the first operational wind farm in a freshwater environment. They highlighted how and where in Lake Vanern the wind farm was constructed, and discussed potential impacts of the farm on bird and bats, fishery habitat and fish populations.

Much of their presentation was devoted to issues of construction and cost as they represented the private sector. Åke and Tore discussed tradeoffs between developing wind in freshwater versus salt water. In marine waters, wind farms have stronger, more sustained winds and less interaction with birds or bats, and no ice, but must deal with salt erosion and difficulties in siting farms in deeper depths. They emphasized lowering construction costs as much as possible, which they accomplished by building forms for the pylons onshore and then towing them out to the site by reconverted barge.  Their company also received support of 7% of total costs from the Swedish government. The wind farm was located in shallow waters (4-12 m depth) and over bedrock, which is likely different than where wind farms likely will be sited in the Great Lakes. Construction of wind farms in Lake Vanern was halted during spawning season of the vendace, a member of the coregonid family which includes lake whitefish and cisco.  Åke and Tore noted no significant impacts of wind farms on birds or bats, as these animals do not normally fly at wind speeds > 4m/sec which are most optimal for powering the turbines.

Dr. Erwin Winter, a fisheries scientist from Wageningen University, The Netherlands, reviewed studies of potential impacts of wind farms on marine resources (birds, marine mammals, fish, benthos) in coastal waters of the Netherlands.  He noted there were impacts on bottom fauna and vegetation while construction took place, but not afterward. He noted impacts on phytoplankton biomass due to sediment disturbance, although effects on zooplankton were negligible.  Fish and marine mammals tended to move away from the area during wind farm construction, and returned after construction was completed. In one extensive study, Dr. Winter compared fish abundance, species composition, length and behavior outside and inside of wind farms, and used hydroacoustics to study fish behavior around the wind farm. Results indicated some fish species, principally demersal flatfish, avoided scour bed habitats created by currents swirling around the pylons, while other species such as cod and edible crabs were attracted to the scour beds. There were no detectable effects of the wind farm on the fish community, in fact most species appeared indifferent to its presence. Although the studies described by Dr. Winter were well designed, and used a before/after/control/ impact (BACI) design, they had relatively low statistical power of detecting an impact of wind farms. 

I felt that the presentations by the European visitors addressed several concerns of the Great Lakes community about wind farms. The European studies indicated there were few significant impacts of wind farms on birds, bats, or benthos. Fears about electromagnetic fields generated by power cables were unfounded as the cables were shielded which minimized the electric field. Dr. Winter did note some significant impacts on fauna from underwater sound and habitat disturbance from construction activity, and collision with rotor blades from birds. Potential beneficial impacts of wind farm construction included increase in new reef habitat, and closing areas to fishing near the wind farms.

  

Dr. Edward Rutherford

Research Fishery Biologist

NOAA / GLERL

Part - 2 coming next week!

* The main financial partners were the Great Lakes Commission, Great Lakes Wind Collaborative, Great Lakes Fishery Trust, Great Lakes Fishery Commission, DT Energy and National Wildlife Federation.

Offshore Wind in Illinois Waters of Lake Michigan: The Path Forward

2012 was a big year for offshore wind in Illinois.  While there are no wind turbines in the Illinois waters of Lake Michigan, the concept of installing turbines in Lake Michigan was discussed and debated. This conversation then became a report by the Lake Michigan Offshore Wind Energy Advisory Council (“Council”). The Council, chaired by the Illinois Department of Natural Resources, convened a series of meetings over the ensuing 11 months to explore the potential for wind power installations in Lake Michigan.  Issues discussed by the Council included identifying areas suitable for offshore wind installations, what lessons can Illinois learn from other domestic or foreign offshore wind projects, and how the state should be compensated for offshore wind turbine installations.  In June 2012 the Council issued a report outlining a permitting process for the installation of offshore wind turbines and identifying turbine siting factors.  The report is entitled the Lake Michigan Offshore Wind Energy Report and a copy can be found at http://www.dnr.illinois.gov/councils/LMOWEAC/Documents/LMOWEFinalReport62012.pdf.

Illinois identified many of the same factors common to other jurisdictions considering the possibility of siting wind turbines.  Factors like the possibility of adverse impacts to bird and bat species, fish or other aquatic species, scenic views and commercial shipping and recreational boating were all discussed and included in the final Report.  The Council found that several comprehensive studies of avian impacts from European offshore wind installations provided a more nuanced picture of avian interactions with wind turbines than previously understood.  In many cases individual avian species will exhibit completely different behaviors when faced with a wind turbine array.  Some species will fly between turbines, some above or around turbines, and others may avoid areas altogether.  Every type of impact will need to be considered if wind turbines are proposed for installation in the Illinois waters of Lake Michigan.  What some Council members may have found surprising was the level of winter-time use of offshore areas of Lake Michigan by waterfowl. 

Illinois has experienced significant levels of investment in land-based wind turbines.  According to the American Wind Energy Association Illinois is ranked 4^th in comparison to other states in current generating capacity of installed wind turbines.  Only California, Texas and Iowa have seen greater levels of wind turbine installation.  While no turbines have yet been installed in Lake Michigan, the southern end of Lake Michigan may be an attractive location for offshore wind siting in the future because of the proximity of Chicago, northwest Indiana and surrounding load centers.  As Illinois and other jurisdictions continue to move towards creation of offshore wind generating capacity, efforts like the Lake Michigan Offshore Wind Energy Report will be important steps in ensuring the correct balance between economic development, domestic energy production and the protection of human values and the environment.

Todd Rettig

Acting Director

Office of Realty and Environmental Planning

Illinois Department of Natural Resources

New Co-chair of the GLWC Offshore Workgroup

Offshore Wind: The Sum of its Parts & People

Offshore wind advocates cite emissions reduction, water quality, diversity of energy portfolio, and economic development as all part of the rationale for developing in U.S. waters. While much of the rationale is straightforward, I see a weakness in the argument used to support the economic development angle. As industry representatives, we must ask ourselves if we are fully delivering a comprehensive, yet easy-to-understand argument for economic development.

Consider this. “The electrical and grid infrastructure, foundations and support structures, offshore logistics and installation, and O&M represent the highest percentage of the total project cost, ranging from 57% to 71%” (NREL 2010). Based on this statement, it’s clear the scope of services involved in offshore wind is much broader than the turbine, certainly broader than most people tend to think about. Better yet, are we doing our best to make it easy for them to think about it more broadly?

People understand the connection between manufacturing and jobs at a high level. They recognize it requires a labor force to create the wind turbine components and then to install and maintain them. All-in-all, the term “supply chain” isn’t a foreign language. But the offshore wind supply chain isn’t just the “sum of its parts.” The turbine and its thousands of tangible components is only a portion of the opportunity. What about the cables, vessels, people, port infrastructure, research, etc…?  The Europeans use the term “value chain” to acknowledge the other term’s shortcoming.

Using the “value chain” terminology allows for the full spectrum of goods and services to be considered as the cost-benefit matrix is developed. After all, when all of these are factored into the cost of a project, do we want to short-change ourselves by using a generic term like supply-chain? I’d venture to say, not at offshore wind’s current cost-per-kilowatt hour.

One full-service project management firm called PMSS is acutely aware of how important it is to communicate this. While they do it to fully detail their “line card” as a service provider, it clearly spells out the scope of the offshore wind value chain. Accordingly, PMSS has a publication called “The Life of an Offshore Wind Farm” which fully describes and delineates the cradle-to-grave project activities undertaken while also listing corresponding job titles for each task.

Another favorite resource to better communicate the value chain was published by the United Kingdom’s Crown Estate, “Your Career in Offshore Wind Energy.”  The document has visualizations of offshore wind’s lifecycle and interviews with professionals like a hydrographic surveyor. For reference, the Crown Estate manages the U.K. government’s property portfolio which includes the zone leases for offshore projects.

From wind assessment and permitting to decommissioning, it should come as no surprise Europe is currently employing over 45,000 people directly in offshore wind; up to 134,000 by 2020. The value-chain is long and the scale is tremendous. As stewards of the impending offshore wind industry in the United States, I propose we instill this term among stakeholders and policy makers in order to strengthen the argument and properly acknowledge the spectrum of economic and employment opportunities. 

Donny Davis

Research & Communications Manager
Lake Erie Energy Development Corporation (LEEDCo) 

Wildlife for future generations

While visiting my parents this past weekend my dad reminded me about my interest in wildlife.  He recalled an incident from about 25 years ago when my older brother and I captured a “dead” bat in the barn with one of our butterfly nets.  We were so excited we took it inside the house to show him.  We found dad napping and notified him of our catch.  He sleepily told us not to bring butterflies into the house and I excitedly informed him that it wasn’t a butterfly—it was a bat!  Well, Dad kind of shrieked which woke up the “dead” bat, which started flapping in the net.  The bat flapping in the net scared my brother who promptly dropped the net onto Dad’s chest.  Dad flipped off the couch, ran out the door, and somehow flung the bat out of the net like a slingshot.  My brother and I spent the next two hours learning about what was and was not appropriate to play with or bring in the house.

As we were reminiscing about the bat adventures of our old farmhouse he stated that it was not as funny as I make it sound.  He smiled and pointed to my two young boys who were drawing on my car with sidewalk chalk and then broke into laughter as I tried to explain to my kids what they can and cannot draw on.  Afterwards, he just smiled to me and said he cannot wait to hear about what my kids bring into my house.

I thought about this statement during the drive home on Sunday night.  I currently live in an old farmhouse, similar to the one I lived in when I was a kid.  I know it has some bats in the attic, and there were definitely some in the barn and outbuildings because I swept out the guano.  But in five years when my kids are out exploring the farm like I used to, will there be bats in those buildings for them to discover?

In Pennsylvania, bat species are encountering several direct threats.  White nosed syndrome has devastated residential hibernating bats in Pennsylvania.  White nosed syndrome was first documented in New York during the winter of 2006-2007 and has now been documented in 19 states and four Canadian provinces.  It was first detected in Pennsylvania in 2008.    Hibernacula surveys by the Pennsylvania Game Commission revealed a 98 to 99 percent decline in little brown, tri-colored, and Northern long-eared bats.  Before white nosed syndrome, little brown bats were one of the most commonly observed bats in Pennsylvania.

Wind energy development is another threat to bat species.  Unlike many other development projects such as power lines or pipelines which have initial wildlife impacts, wind turbines have large moving blades that can impact wildlife for the life of the project.  In 2007, the Pennsylvania Game Commission created the Wind Energy Voluntary Cooperative Agreement.  This is an agreement between the Game Commission, which has jurisdiction over Pennsylvania birds and mammals, and wind energy developers to study the effects of wind energy on wildlife and develop ways to avoid, minimize, and mitigate for negative impacts.  Data collected via the Voluntary Cooperative Agreement shows an average mortality of 25 bats per turbine per year for wind sites in Pennsylvania.  There are currently over 500 turbines in operation in Pennsylvania which means over 12,500 bats are killed by wind turbines in Pennsylvania each year.  With more wind farms planned in Pennsylvania, the yearly bat mortality will continue to increase unless some minimization methods are implemented.  Three quarters of the bats killed in Pennsylvania are migratory tree bats such as the hoary, eastern red, and silver-haired bats.  These bats migrate south through Pennsylvania in the fall and north through Pennsylvania again in the spring.  Meaning that these bats essentially run a gauntlet of wind farms up and down through Appalachia.  Since bats are relatively long lived and have low reproduction rates, generally one young per year, mortality from wind farms could have serious implications on these migratory bat populations. 

There are other threats that bats face.  Bats can be killed by automobiles driving on roadways.  Bats can be killed by feral pets such as cats.  Bats can be killed by homeowners when they inadvertently seal them in because people do not want bats in the attic.  There are also indirect threats such as habitat loss and pesticide use.  Residential and industrial development threatens historical foraging and roosting sites.   Increased pesticide use reduces potential prey for bats.  So not only is their original foraging area no longer suitable, but their food was also removed.  Recreational activities such as caving can disturb bats while hibernating.  Dumping trash into caves and mines can close entrances used by bats, eliminating suitable hibernacula. 

Bats appear to be facing a stacked deck.  Hopefully, as a society, we can recognize the implications our actions have on wildlife, and avoid and minimize these impacts for the benefit of all wildlife.  While there are many threats to bats, we should identify the major threats to bats, such as white nosed syndrome, and develop ways to minimize the spread of this disease while protecting the species most at risk.  For direct threats such as wind energy, we should identify ways to avoid potential impacts and minimize the existing impacts through adjusting cut-in speeds, deterrents, or other methods.  We should be aware of the various impacts on bat species and avoid and minimize them to the greatest extent possible.

Maybe this will allow my kids the great experience of watching their mother screaming hysterically at the dinner table because a wayward bat emerged via the kitchen instead of exiting the attic through the eaves. 

John Taucher

WIldlife Biologist/Wind Energy Project Coordinator

Pennsylvania Game Commission

Beyond Coal: advancing a vision of clean energy for the Great Lakes

After spending the past couple of days at the Great Lakes Wind Collaborative annual meeting, I remain very optimistic about the future of wind in the Great Lakes region.   Participants in this year’s meeting painted a clear picture: the development of clean, renewable wind power—both onshore and offshore—brings incredible benefits to our region and is essential to the long term health of both our economy and our environment. 

Our states are already experiencing job growth, community renewal and affordable energy from on-shore wind development.   And if we invest in the development of an offshore wind industry here, to capitalize on the outstanding wind resource that exists in close proximity to major load centers, we could generate tens of thousands of new jobs in manufacturing, construction, and long term operations and maintenance.

But economic development aside, we cannot afford to wait.  We must move quickly to dramatically increase our reliance on clean, renewable, home-grown energy sources.  Our region currently gets three-quarters of its electricity from coal, which is all too often burned in old, inefficient power plants with limited or no modern pollution controls.  Our reliance on coal is leaving us with a legacy of mercury-contaminated lakes, asthma-inducing bad-air days, toxic ash spills and—worst of all—a rapidly changing climate that is already wreaking havoc on communities and ecosystems around the world.

A flood of inexpensive natural gas is challenging the dominance of coal.  But while burning natural gas emits less pollution than coal, its extraction can cause major environmental problems and it is not a long-term solution.  Eventually, the price will go up as supplies go down.  Like all fossil fuels, it is a limited resource.

Wind, on the other hand, is not.  It offers an unlimited supply of local clean energy and the potential to renew our cities and manufacturing centers across the region.  There is more than enough on-shore and offshore wind capacity to power our entire region and then some.  And as I learned at the Great Lakes Wind Collaborative meeting, it is aggressive but possible to generate as much as 80 percent of our power from renewable energy sources, while maintaining the integrity of the grid (for more information check out the report from NREL).

One key to realizing those benefits is to develop the resource appropriately, siting wind farms in a way that minimizes environmental and social impacts and that is acceptable to local communities.  I am honored to be working with the Collaborative’s Siting and Mapping workgroup to develop a regional, GIS-based siting tool that will help us more effectively engage local communities and make smart, sustainable decisions on the siting of onshore and offshore wind farms.  We invite all interested parties to join us in developing a tool that will be useful to and used by key stakeholders across the region.

In addition, we must determine how to spread the cost and the risk of launching a new industry in order to bring offshore wind to the Great Lakes.  I urge the Collaborative to engage on this challenging question.  There are tremendous benefits of building an offshore industry here, but it will not happen unless the early costs associated with being the “first mover” are shared regionally or even nationally. 

The Collaborative should seriously investigate and debate the options for spreading the costs, and we should be creative and think big.  While the obstacles may seem large, we must consider innovative options such as a renewable energy power authority or regional integrated resource planning in order to achieve a meaningful shift toward a clean energy future in this region. 

The potential benefits of this vision are huge and the cost of doing nothing is too high.   I want to leave a better world to my boys—one that includes clean air, clean water and a strong economic future.  Getting off of coal and developing a more sustainable clean energy future is a key part of developing that legacy.  Let’s work together to figure out how to make that vision a reality, in a way that works for the region’s communities, businesses, industries, utilities and others. 

We are all in this together and I believe that, together, we can solve this problem and address this challenge—I am an optimist.

Emily Green

Great Lakes Program Director

Sierra Club

A Story of Three Figures

The wind energy world seems to be dominated by discussions of the Production Tax Credit (PTC), and one cannot help but be concerned about how the uncertainty over the future of this policy is resulting in job losses across our country and especially in the Great Lakes region. But it may be helpful to take a broader look at the wind industry and recently released analyses that provide us with a few sunbeams in the long-range forecast: the Renewable Energy Futures Study, A Systematic Review and Harmonization of Life Cycle GHG Emission Estimates for Electricity Generation Technologies, and two analyses that examine the future of U.S. natural gas markets. It is important to note that most of these works were funded by U.S. Energy Department, which also helps support the Great Lakes Wind Collaborative.

Although each analysis is significant, in combination these three studies paint a picture that I think everyone in the wind industry should remember as we look to a very uncertain next few years, both in the wind industry and the energy industry as a whole.

The Renewable Energy Futures Study (http://www.nrel.gov/analysis/re_futures/) examines the electrical energy market until 2050 and is the most comprehensive and complete projection of how our electric market sector could look if renewables provided a larger percentage of the nation’s electrical energy needs. The study also includes a robust assessment of the nation’s grid infrastructure and considers only technologies that are available today, so it does not include any assumptions of huge efficiency improvements that may never be realized. The report clearly indicates that a future in which more than 80% of the nation’s electrical energy comes from renewables (including wind, solar, hydro, and bio-power) is very possible, from technical and economic standpoints. In this analysis, wind provides the largest portion of the nation’s energy portfolio expansion (almost 450 gigawatts by 2050), while fast-acting natural gas plants provide much of the stability and power back-up. The website for the study (provided above) portrays not only how the power system changes over time but also the expected flow of power across the nation each year until 2050.

The breakthrough work on the Harmonization of Life Cycle GHG Emission Estimates for Electricity Generation Technologies study examines more than 2,000 analyses of carbon emissions of greenhouse gasses from across the electric sector (http://en.openei.org/apps/LCA/) and provides an international consensus of the emissions of different electrical energy technologies. It should be no surprise to anyone that wind is one of the lowest lifecycle emitters of greenhouse gasses, slightly higher than hydropower and ocean energy technologies and lower than all of the other renewables and nuclear. On the website, turn off the markers on the interactive chart for coal and natural gas to see the differences among all technologies.

The last analysis comes from a series of reports discussed at the 2012 Wind Powering America All States Summit and highlights the understanding that the convergence where natural gas overtakes coal as the prime producer of electric power in the U.S. is near, if not already passed (some say it happened last month). With natural gas becoming the new dominant provider of electrical energy, the nation becomes much more dependent on a fuel source that is tied to international pricing and has historically demonstrated price volatility due to a variety of market pressures. In presentations by Mark Bolinger of Lawrence Berkeley National Laboratory and Jeffrey Logan of the National Renewable Energy Laboratory, we see that the cost of natural gas in the near future ranges greatly. Bolinger’s figures (soon to be released as part of the 2011 Wind Technologies Market Report) show the cost of energy from natural gas within the next 5 years ranging from below $40 per megawatt-hour to more than $100 per megawatt-hour. This clearly lies in a range where wind, even without the PTC, can play a strong hedge against potential market fluctuations. Logan’s upcoming report also shows that without the PTC, wind at good sites is economic when compared to natural gas at within the $5 to $6 per MMBtu range. This is well within the range of predicted natural gas prices given the market uncertainties, including expected continuing retiring of coal plants, liquefied natural gas export infrastructure development, expanded industrial usage, and expanding use of natural gas as a transportation fuel.

Everyone who has worked in the wind industry for at least the past 5 years knows that the energy industries can be turbulent from year to year. To many energy industry workers facing a potential pink slip, whether a coal miner in Pennsylvania or a manufacturer of roller bearings for wind turbines in Michigan, my words will ring with a decidedly hollow tone, but I have to say that the long-term prospects for the wind industry are very bright. The results of these studies -- wind can play a strong role in any renewable energy electricity future, wind technologies are one of the best energy options to address the ongoing climate crisis, and the truly critical need to hedge the industry’s headlong rush into a power sector dominated by natural gas -- add to the long list of wind energy’s positive attributes. For the long term, the wind industry is one of the few in which success is as guaranteed as the power industry currently allows.

Ian Baring-Gould

National Technical Director

Wind Powering America

National Renewable Energy Laboratory

To know more about the GLWC, visit http://www.glc.org/energy/wind/

Welcoming the new U.S. Fish and Wildlife Service’s Voluntary Land-Based Wind Energy Guidelines:

By Amanda Sweetman, Sea Grant Fellow

Great Lakes Commission

Prior to joining the Great Lakes Commission as the 2012-2013 Sea Grant-Great Lakes Commission Fellow, my thoughts on wind power revolved (pun intended) around my awe of the size and majesty of the turbines. Since taking the position however, I’ve been working hard to get up to speed (another pun) on the current state of wind power in the U.S., and more specifically on the role of the Great Lakes Wind Collaborative in the development of wind power in the Great Lakes region. One of the first tasks I was given was to educate myself on the ins and outs of the new U.S. Fish and Wildlife Service Voluntary Land-based Wind Energy Guidelines: what are they, how will they impact wind energy development, and how will they be implemented? Below I attempt to answer these questions:

What are the USFWS Guidelines? The Guidelines are a voluntary, tier-based scientific process for “addressing wildlife conservation concerns at all stages of land-based wind energy development” (USFWS). More specifically these guidelines are designed to limit impacts on species of concern.  Species of concern are those that that U.S. Fish and Wildlife Service are responsible for protecting as part of the Endangered Species Act, the Migratory Bird Treaty Act, and the Bald and Golden Eagle Protection Act. Although these guidelines are voluntary, the Service has said that a developer’s adherence to the process will reduce, not eliminate, the likelihood of legal action if an incidental take of a species of concern occurs.

The tiers are laid out in an easily understood, logical manner that, hopefully, will lead to greater protections for species of concern in the development of wind farms. Each tier is designed to build off the previous one and collect information in increasing detail to assess and evaluate potential risks to species of concern and their habitats. (See the full document for more information.)

Tier 1: Preliminary site evaluation

Tier 2: Site characterization

Tier 3: Field studies and impact prediction

Tier 4: Post construction studies to estimate impacts

Tier 5: Other post-construction studies and research

According to the Guidelines, the most important part of this process is to communicate early and often with the Service. In the document, the Service promises quick turnaround (no more than 60 days) of all communications.

How will they impact wind development? The Guidelines may increase development time due to the iterative process and communication with the Service. However, I believe they will encourage environmental stewardship, promote the ideas of adaptive management, and create a nationwide database with standardized data. The Guidelines were also developed by a wide range of stakeholders including people from federal, state, tribal, non-profit, and business organizations. Hopefully, the collaborative spirit of the document will continue as the number of wind farms increase and we, as a nation, come to terms with the associated impacts of these developments.

Let’s not forget the assurances the Services has made about the reduced likelihood of legal prosecution in case of an incidental take of a species of concern! The Guidelines are akin to looking both ways before crossing the street. Following them is no guarantee that you’ll be safe, but it’s a lot better than just stepping off the curb.

How will the Guidelines be implemented? The need for contact with the Service early and often suggests the need for regional offices of the Service to have an understanding of the Guidelines and an intimate knowledge of the areas in which there are species of concern. It will also take time and training for Service staff and wind developers to fully understand how to follow the Guidelines. The Guidelines promise the “Service will make every effort to offer an in-depth course [on the implementation of the Guidelines] within six months of the final Guidelines being published” (USFWS). However, it is unclear who will be invited to this course, how often the course will be held, and who will be doing the training.

My thinking is that the Service could and should take advantage of existing groups, such as the Great Lakes Wind Collaborative (GLWC), to help with the implementation of the Guidelines. The GLWC has a broad network with more than 700 stakeholders across the binational Great Lakes region and is led by a multi-stakeholder Steering Committee. The GLWC can facilitate integration of the Guidelines with state and local rules and ordinances to reduce redundancy and promote the environmentally-conscious growth of the wind industry in the Great Lakes. 

Concluding Thoughts: Overall, I find the Guidelines a positive, encouraging tool for the responsible development of wind power in this country. As a scientist, I am encouraged by the scientific approach these guidelines take as well as the inclusion of well thought-out best management practices at the end of the document. Recommendations about using native seed for replanting struck particularly close to home due to my past research on native plant restoration.

Personally, the voluntary nature of the Guidelines is a little troubling. There are laws that dictate when individuals can and cannot cross the street. So, why is it that when industry wants to develop wind farms that the Service can only take action after a negative outcome? At which point the damage may already have been done. Also, I would like to see more proactive mechanisms for avoiding impacts on wildlife initiated by government agencies.  One possibility is to provide incentives for redeveloping brownfields and old industrial areas. Not only would this reduce impacts on wildlife and green areas, but it would also bring energy production closer to areas of energy use.

Amanda Sweetman

To know more about the GLWC, visit http://www.glc.org/energy/wind/