From CFACT
By David Wojick
Land-based wind turbines kill golden eagles, so every turbine requires an Eagle Protection Act permit from the U.S. Fish and Wildlife Service (FWS) to kill them.
These permits are predicated on a supposed mitigation strategy where turbine kills are offset by reducing the number of eagles electrocuted by power poles. Electrocution is estimated to kill about 500 golden eagles a year. The strategy calls for 12 eagles to be saved for every 10 killed by wind turbines.
My research on this strategy found that the number of golden eagles actually saved from electrocution must be very low, far lower than the number killed by wind turbines. The math is quite simple. The number of power poles being made safe is far too low to be effective.
So I set out to inform the FWS of my findings, which should be of great concern to them. They need to rethink their golden eagle wind-kill mitigation strategy.
Beginning on September 25, I sent the cautionary email shown below to over a dozen FWS people and offices. Most of the people were in the Migratory Birds Office, which oversees the Eagle Protection Act permitting. In addition, each of the eight FWS regional offices which issue the Eagle-kill permits has a specific email address for that purpose, so I sent to them.
I sent every email twice in one week and to date have not received a single reply. So, I am here publishing the email to make it in effect an open letter to the Fish and Wildlife Service.
Here is the generic body of my FWS email:
“Subject: Electrocution mitigation for wind kills does not work
Hello FWS,
I understand FWS is looking into eagle take permits for wind turbines at Secretary Burgum’s request. I just did a study on the mitigation component and my finding is that electrocution mitigation in its present form is completely ineffective. Very few, if any, electrocution deaths are being prevented, certainly not the 1.2 deaths per turbine death that is called for.
The reason is that the poles per death number FWS is using is far from what is needed. While FWS currently requires about 278 poles to be “made safe” per wind-killed eagle, the correct number may be closer to 67,000. It is no wonder the mitigation program has failed.
The national average is actually close to 370,000 poles per eagle death based on 500 kills with 185 million poles. The research literature suggests that high risk poles may be 5.5 times deadlier, which is 67,000. At this rate fixing just 278 poles per wind-kill will have little if any effect. Better data might change these numbers a bit but not enough to make a difference. This is explained in section 1 of my report which is at https://www.cfact.org/2025/06/29/cfact-report-feds-fail-to-offset-wind-turbine-eagle-kills/.
Given these numbers there should be a moratorium on permitting until an effective mitigation strategy is developed. FWS regulations call for monitoring the effectiveness of mitigation.
See my https://www.cfact.org/2025/07/28/fws-is-violating-its-own-eagle-kill-regulations/.
I will be happy to discuss this important issue.
My best regards,
David Wojick, Ph.D.
CFACT Senior Advisor and Policy Analyst
End of email to FWS.
I am now pursuing other means of communication. In addition, I invite people who object to a specific wind power project to use this data and object to that project’s eagle kill permit. Without this Federal permit, the wind project cannot operate.
The Regional Permitting Office contacts are listed here:
https://www.fws.gov/program/migratory-bird-permits/contact-us
Maybe this will get their attention.
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