FWS letter against Garden Peninsula wind energy development 

… Based on the data currently available, we must once again recommend that you not construct a commercial wind energy development on the Garden Peninsula, because of the high potential for avian mortalities and violations of Federal wildlife laws. Since 2007, our office has expressed significant concerns with this project. Our concerns are based on several factors, including the proximity of the project to a Great Lakes shoreline and Big Bay de Noc, the proximity of the project to adjacent wetland habitats, and the fact that this peninsula will tend to funnel avian migrants and serve as a point of departure or arrival for birds crossing Lake Michigan. These factors are all likely to lead to a high level of avian use on the Garden Peninsula that could result in high levels of avian mortality by wind turbines at the proposed project site.

Because of our concerns, in our early project correspondence with Dr. Paul Kerlinger on December 18, 2007, we recommended that no turbines be constructed within three miles of a Great Lakes shoreline. On June 25, 2009, in a letter to Mr. Rick Wilson, we again recommended that no turbines be sited within three miles of the shoreline and further recognized that it would be very difficult to achieve this three-mile distance at any place within the Garden Peninsula. In 2011, Heritage presented our office with data collected specifically for this project site and this data … has validated our wildlife related concerns for this proposed project.

We were in the process of finalizing additional information that you had requested concerning our bald eagle risk assessment, when we received your October 18, 2011, letter transmitting a “Comprehensive Avian Risk Assessment for the Garden Peninsula Wind Energy Project, Delta County, Michigan” (September 2011, Curry & Kerlinger, LLC-9-27-11). Your letter indicated that you accepted the conclusions of the Curry & Kerlinger Risk Assessment and intended to move forward with construction of the wind energy development, regardless of our previous recommendations and wildlife concerns.

First, we strongly disagree with the conclusions presented in the Curry & Kerlinger Risk Assessment. The data available suggests that construction of a commercial wind energy development on Garden Peninsula is likely to pose a very high risk for avian mortalities, including a high risk for bald eagle mortalities. The Service will provide you with a more detailed response related to our concerns about the Curry & Kerlinger Risk Assessment in the near future.

Second, although we have appreciated your periodic efforts to coordinate with our office as your project planning has progressed, you have failed to sufficiently collect and analyze comprehensive information concerning avian use of the project area prior to construction. The Service recommends that this information is collected and analyzed well in advance of project construction so that it is available to inform project siting. Additionally, you do not appear to be adequately considering the limited data you have collected. The proposed turbine locations are in areas where you have documented high avian use and thus are not adequately set back from the Great lakes shoreline or other important wildlife habitats. Therefore, we continue to recommend that the project be substantially reevaluated or abandoned. …

Scott Hicks
Field Supervisor
Fish and Wildlife Service
East Lansing Field Office (ES)
2651 Coolidge Road, Suite 101
East Lansing, Michigan 48823-6316

[November 4, 2011, to Ms. Xio Cordoba, Heritage Sustainable Energy, 121 East Front Street, Traverse City, MI 49684-2570]

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