Review of Pennsylvania Game Commission Protocols to Monitor Bat and Bird Mortality at Industrial Wind Sites 

Preamble: The Pennsylvania Game Commission (PGC) has a responsibility to the Commonwealth of Pennsylvania and its citizens to manage and protect the wildlife of Pennsylvania using the best science and information available at the time management decisions are made. To that end, the PGC entered into a memo of understanding with the Mammal Technical Committee (MTC) of the Pennsylvania Biological Survey (PBS, a non-profit scientific, educational, and advisory organization of professional biologists, incorporated under the laws of the Commonwealth of Pennsylvania) to act in an advisory capacity to the PGC on all matters related to management and protection of mammals within the Commonwealth that fall under PGC jurisdiction. That memo of understanding had been in effect for well over a decade. … In order to provide the most current scientific advice possible, the MTC formed the “Wind Energy and Bats” (WEB) sub-committee in October of 2006. This sub-committee is composed of MTC bat experts throughout the Commonwealth who are familiar with the biology and ecology of bats and issues concerning how they are being affected by wind power development. The WEB subcommittee advised the PGC representatives on the MTC that it was ready to assist the PGC in reviewing material related to this topic and offering the most current scientific advice possible in designing guidelines for siting wind turbines in Pennsylvania with respect to protecting wildlife, and specifically bats. In February of 2007, the PGC released a final draft of Voluntary Wind Energy Cooperative Agreement, which included guidelines for the siting of wind turbines in the Commonwealth of Pennsylvania. The MTC was not provided with draft formats of the guideline for review. … Subsequent to the publication of the final draft of the siting guidelines, the PGC informed the chairs of the MTC that in this case the normal close consultation with the MTC did “break down” somewhat but was necessary due to the time pressure that the PGC was under to complete these guidelines. Given the aforementioned events, the WEB sub-committee feels it is still imperative that we offer feedback to the PGC now, from experts in the Commonwealth, based on the most current science available, and in the spirit of the memo of understanding between the PGC and MTC.

The Wind Energy and Bats sub-committee wishes to acknowledge that the PGC deserves credit for its attempt to institute a means for systematically monitoring the wildlife collision impact of industrial wind energy development in the Commonwealth, particularly since limited information currently exists on this. In addition, we have no doubt that the PGC protocol reflects the input of many competent and well-meaning biologists who work for the PGC. Nonetheless, it appears that the PGC’s voluntary protocol is flawed, will not help avoid or effectively mitigate the harmful impacts to our natural heritage from the pending development of industrial wind energy in Pennsylvania, or even serve to adequately monitor the effects such development has on wildlife.

The greatest and most damaging flaw in the PGC protocol is a “loophole” which allows wind industry “cooperators” to block public access to research information collected under the auspices of this protocol if it is not “deemed to be in the[ir] best interest” (see section 13 of PGC protocol). …

There is widespread dissatisfaction among our sub-committee over the lack of meaningful pre-construction research, which the PGC protocol largely fails to require. Incredibly, there is no requirement that any pre-construction monitoring efforts be evaluated or otherwise used to determine whether a proposed wind energy project should go forward or be halted. No thresholds or standards for evaluating the acceptability of pre-construction study results are included in the PGC protocol. …

The PGC protocol provides very little real protection for wildlife and may help shelter the wind industry from growing criticism of environmental and wildlife impacts that can result from the development of wind energy facilities. …

The effects of energy development on wildlife and the environment must be a major point of deliberation in the development of any viable energy sources of alternative energy. Whereas wind turbines were once thought to have no adverse environmental impacts, they are now recognized to have negative impacts on wildlife and most significantly on bats and birds (USFWS 2003, US Government Accountability Office 2005, National Research Council 2007). The Government Accountability Report (2005) specifically cites Pennsylvania as one of the states in the Appalachia region of the United States where bats are being killed in the largest numbers, and populations are at greatest risk. Moreover, as bats are the primary predators of nocturnal insects in the Commonwealth, and many of these insects are considered human and crop pests, bats are considered ecological keystone species. …

The current PGC protocol is not based on the “best science available” and is not in keeping with recommendations and/or does not address concerns of the US Fish and Wildlife Service (2003), The US Government Accountability Office (2005), the National Research Council Report (2007), the position held by the Mammal Technical Committee in a previous communication to the PGC (appendix I), the position of Bat Conservation International (appendix II), recent expert testimony before the US Congress (Committee on Natural Resources, 2007) and numerous government and independent bat experts and scientists in the US and Canada. To continue to promote and use such a protocol would be to put the interest of the wind industry before the interest of the Commonwealth.

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