The document that Laura addresses can be found at http://www.pgc.state.pa.us/pgc/cwp/view.asp?a=483&Q=175703&PM=1

Also, locate the attached Allegheny Ridge Map of 75 Industrial Wind Turbines and their Impacts.

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Dear Tracey,

I recently read the Wind Energy Annual Report and would like to express my appreciation to the PA Game Commission for making the report easily accessible to the public. The document reflects a significant investment by the Game Commission and wind energy companies in addressing wildlife issues in Pennsylvania, and I would like to thank you for your role in its development.

I do have a number of comments and questions regarding the report. I know you are busy, but I hope you have time to address my concerns. As the chairperson of SOAR, I represent many people across our Commonwealth who are concerned about the impact of industrial wind on our state's wildlife. I will share your responses with scientists, educators, environmentalists, and others who understand the significant role of wildlife and the importance of protecting undeveloped habitats. My questions are in blue, to facilitate your response.

First, the discoveries of Indiana bat and silver-haired bat maternity colonies are quite significant, as we know that bats are at high risk when in the vicinity of turbines. The 2007 data that you reported from the one site shows even greater mortality estimates than those generated at Meyersdale by Ed Arnett. Since bat reproduction rates are very limited, it is hoped that effective measures will be taken to reduce mortality. When do you anticipate that you will be able to publish data, which show effective mitigation methods have been implemented for wind projects? The Casselman Wind project has received media attention for experimenting with turbine cut-in speeds, but no data has been published. It is hoped that this data will be included in the next Annual Report.

On page 30, the report includes post-construction comments from "May 1, 2007 through September 30, 2008". This is confusing because it was stated earlier in the report that no data were available for 2008. It appears that all the post-construction data in this report is based on just one site using 10 turbines, where data was collected in 2007. Is this correct?

The report also states that 4 sites were surveyed in 2008. When will the report from these sites be available?

I strongly encourage more specific information be included regarding the three sites that were abandoned due to wildlife issues, as described on page 31. The public needs to know the general area where projects have been cancelled due to wildlife concerns, as well as any Important Bird Areas or Important Mammal Areas that are spared from industrial wind development. Can future reports include a state map illustrating the general areas that are no longer being considered for wind development?

Page 30, under Successes, states that "no eagle fatalities have been reported during the period of May 1, 2007 and September 30, 2008." Can you clarify that this summary is for only one wind project site with limited survey time? Again, such a statement is confusing as the report stated no post-construction data was available for 2008.

Many wildlife biologists agree that habitat degradation is the number one reason for species decline. In order to understand the impact of industrial wind development on our wildlife, we need to determine industrial wind impacts on habitat, especially our forests. Limited reference was made to this in the report when discussing the impact of wind development to the Allegheny woodrat on page 24 of the report. Since woodrats depend on forested travel corridors for dispersal and genetic diversity, contiguous forest is essential to woodrat survival. How do the present and proposed wind projects affect woodrat travel corridors? Since the massive road building for wind development does impact woodrat habitat, is anyone assessing how these roads will negatively impact woodrat travel corridors?

Perhaps the most disturbing aspect of the report is the absence of any data on forest fragmentation. While the report states that "avoidance of existing forested landscape to the maximum extent possible" has occurred, I would strongly encourage that data be included in the report to show forest impact. This data should show:

• Acres of forest habitat lost to wind development

• Acres of forest-interior habitat lost to wind development

• Miles of new roads constructed through forest habitat for wind projects

• Miles of existing roads widened through forest habitat for wind projects

Furthermore, data showing the impact of wind projects on state game lands and state forest lands should be presented. Additionally, the miles of right of way that were granted should be calculated, as well as the amount of acres of forest-interior that were lost to wind development in state game lands and in state forest lands.

Many people are concerned about the impact of wind development on our forested mountains. Dan Boone, a wildlife biologist who lives in Maryland, analyzed the amount of impact from the 75 turbines in the Allegheny Ridge Wind Project on forest acreage cleared and forest-interior acreage "lost". He used high-resolution digital aerial photos from USDA taken in 2008, 2005, and 2004.

To quote from Boone's work:

" My analysis determined that over 300 acres of forest habitat was

cleared to make way for the 75 wind turbines and for the project's

very wide and extensive road/utility-line network. The clearing of

forest for this windplant and the widening of the relatively narrow

openings in forest canopy along the pre-existing forest roads

(resulting in linear openings through the forest that are over 30 feet

in width) caused extensive fragmentation of the formerly large blocks

of contiguous forest which comprised this area. The cumulative loss

of ecologically significant forest-interior habitat totaled more than

2,360 acres - nearly 4 square miles! On a "per turbine" basis, the

forest "loss" averaged over 4.1 acres and the forest-interior "loss"

averaged nearly 31.5 acres. I relied on the Maryland Department of Natural Resources' land-use planning criteria for determining forest-interior and linear

"edge" habitats - i.e., "edges" created by roads through forest which

create a canopy opening that is 30 feet or wider (see:

http://www.dnr.state.md.us/education/envirothon/wildlife/criticalareareg_FIDS.pdf)

I also did not include as "non-forest" habitat any isolated

clearings/openings within the forest that are 1/2 acre or smaller in

size (there were very few instances). Openings within forest that

are 1/2 acre or less in size are much less likely to cause many of the

deleterious "edge effects" which may cause harm to forest interior

dwelling birds and other species."

I am attaching a copy of a map that Dan Boone created, using GIS, to show the impact of these turbines on the Allegheny Front, an Important Bird Area, which is being severely impacted by wind development. I received permission from Dan Boone to share this data with you, to emphasize that the PGC should include a summary of habitat impacts in the Annual Report.

Will the PGC include this type of data in future reports?

Finally, it is hoped that the flawed survey times and flawed data collection protocols will be reduced in number as the wind developers gain experience working with the PGC. Lack of valid data due to flawed studies is a significant issue that needs to be addressed decisively, so that wind developers understand how crucial this data is to managing the impact of wind development on our wildlife. What safeguards are being addressed to lessen the likelihood of this occurring in future surveys?

Again, I would like to express my appreciation to the PGC for releasing this report on the voluntary agreement. I would urge you to add a forest impact component to future reports, to show the impact of wind projects on our state's forests, on both private and public lands. As Carl Roe noted in his comments, the information in this report will allow the PGC and wind companies to make more informed decisions in siting wind projects, as well as mitigation techniques to reduce wildlife mortality. While this report is a first step toward those goals, there is still a lot of impact on habitats that needs to be analyzed.

Sincerely,
Laura Jackson
SOAR Chairperson