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Wind Turbine Project proposed near Horicon NWR in Wisconsin Visit the Refuge Action Network web page on this issue to learn more, including how you can submit comments.
Comments Regarding Forward Energy LLC Draft Wind Power Environmental Impact Statement 15 June 2005 Docket
9300-CE-100 Our organizations are taking an interest in this since Horicon National Wildlife Refuge is located approximately 1.2 miles west of the project area boundary, and since the site is within a few miles of the state-managed Horicon Marsh State Wildlife Area. Together, these sites comprise a designated Ramsar Wetland of International Importance. We found the final EIS to be thoughtful and thorough. Our organizations, however, wish to emphasize a few points, especially concerning the placing of turbines close to a delicate wildlife area. First, the initial proposal by Forward placed turbines over four miles from the refuge, but then the plan increased the number of proposed turbines and placed them closer - within 1.2 miles. (The change in placement resulted in 70 percent of the proposed turbines located within five miles of Horicon Marsh, compared to 58 percent, prior to the 2 December 2004 redesign.) Such a shift in plans has significantly increased the potential hazard to birds posed by the turbines. A 1999 study done for the Wisconsin Department of Natural Resources (by Robert W. Howe and Ryan Atwater from the Richter Museum of Natural History at the University of Wisconsin-Green Bay) stated that bird activity is much reduced at distances of 8km (approximately five miles) of the edge of Horicon Marsh, and the placement of "generators at distances 8km or greater will have significantly lower impacts than generators closer to the marsh." Unfortunately, the current re-design clearly runs counter to this recommendation. In addition, in late April, the Dodge County Planning, Development and Parks Committee approved restrictions to push the wind-turbines to three miles from the Marsh perimeter, approaching the company's original four-mile setback. At minimum, moves to increase the distance between the turbines and Horicon Marsh are required. Second, we understand that the total elimination of avian mortality under these circumstances is impossible, but the risk to some species of concern is particularly troubling. For example, Sandhill Cranes at Horicon National Wildlife Refuge use not only the marsh itself but also surrounding farmland for feeding and assembling (a majority using areas within three miles from the refuge boundary). Concern for this operating buffer is important. Not surprisingly, more Sandhill Cranes have been observed in the western portions of the current turbine zone. Indeed, hundreds of Sandhill Cranes use a few of the same fields (in the fall) where turbines are planned. It is unknown how they will adjust, if at all. The status of experimental Whooping Cranes should also be considered. If cranes from the Wisconsin experimental flock become established at or near Horicon Marsh, the site will become the focus of intense national and international conservation efforts. The largest gathering of migrating Canada Geese in the world (200,000 to 300,000 in the fall) may be secure, but close placement of turbines to Horicon Marsh does not make them more secure. Also unknown is the impact on other waterfowl. And each year, very large numbers of shorebirds, waders, raptors (especially in winter), and other birds move in and out of Horicon to forage in nearby farm fields, moving at relatively low altitude between resource areas. Third, the impact on four cave-dwelling bat species at the abandoned Neda Mine, 10 miles south of the project area, bats which fly in and out of the marsh as they feed on insects, is unknown. Horicon Marsh provides a regionally important wetland for foraging bats, and conservation agencies have concluded that without studies to prove otherwise, the project area is likely to have greater bat abundance than other areas of east-central Wisconsin. Here is another case -- with proximity to the marsh an issue -- where extra care is advised. Fourth, as the EIS has noted, the study methodology used by Forward was less rigorous than in other wind farm studies. Most importantly, the bird and bat surveys did not sufficiently address the importance of Horicon Marsh's effect on wildlife use within the westernmost project area. Under guidance recommended by the U.S. Fish and Wildlife Service, pre-construction data should be collected over multiple seasons and years, including a project site and a reference site. While the guidance assumes that multiple sites will be evaluated and the results will be used to select the final site, what we have here approaches the opposite. Modest surveys were made, and then a larger and more expansive site was selected, one closer to Horicon Marsh. This only confirms the need to be exacting in approving the location for the wind-turbines. Because of these reasons, we are particularly concerned that the plans of Forward have not sufficiently addressed wildlife, land-management, and environmental concerns. Reverting back to the originally proposed four-mile setback is a minimum restriction that we would favor. The five-mile figure, cited by Howe and Atwater, would be even safer. If ongoing and post-construction studies would justify expansion of the units closer to the marsh without untoward damage to natural resources, that could still be considered for the future. We appreciate that unlike power plants that use fossil fuels to generate electricity, the proposed wind-project would not emit air pollutants. Nor would the project require water for cooling purposes. While this is admirable, and while we look forward to a time when wind technology will generate considerable electricity for America, the close placement of these units near Horicon Marsh is currently unwise. At the same time, we stand ready to assist the industry and regulators to help accelerate a major role for wind power in America, but not at the expense of appropriate land and wildlife management. Sincerely, Evan
Hirsche Gregory
S. Butcher David
Fischer Thomas
M. Franklin Sean
McMahon |
