American Bird Conservancy Letter that Engaged Local Stakeholders: Opposes Operation of a Wind Facility along the Keweenaw Ridge

On July 11, 2022 the American Bird Conservancy released a 7-page letter that stated the Keweenaw Ridge was an inappropriate location for sighting industrial wind energy infrastructure.  

American Bird Conservancy (ABC) is a 501(c)(3), non-profit membership organization whose mission is to conserve wild birds and their habitats throughout the Americas. They work to safeguard the rarest bird species, keep common species common, and reduce prevalent threats to all birds. (https://abcbirds.org/).  

American Bird Conservancy developed their position after convening a stakeholder meeting where they gathered information from local and regional bird experts, a representative from the KBIC, and representatives of several Western U.P. environmental organizations.   Based on available information and our extensive expertise, ABC Birds has evaluated the Scotia Wind project proposal in this context.

ABC supports environmentally-responsible wind energy development as part of a broader, multifaceted approach to combat climate change. Environmentally-responsible wind energy development begins with identification of a project site that presents minimal risks to birds and other wildlife, with detailed planning then informed by robust field studies. Based on available information and our extensive expertise, we have evaluated the Scotia Wind project proposal in this context.

• The location and shape of the Keweenaw Ridge/Peninsula and its relation to Lake Superior is unique for migration of raptors, waterfowl, and passerines. Below the ground are numerous abandoned copper and iron ore mines that serve as bat hibernacula.

• The proposed site for the Scotia Wind project is in an area of high biodiversity value, including use by large numbers of migratory eagles, hawks and other raptors, as well as common loons, passerines, federally-listed bats, among other wildlife.

• Federal and state agencies have determined the proposed location is a critical area of wildlife congregation (includes bird migration corridors and bat hibernacula), presents a high potential for wildlife impacts, and is a poor choice of location for an industrial wind facility (see details regarding state and federal agency correspondence in following sections).

Of similar concern, while there is evidence that suggests the migration of numerous raptors (including eagles), waterfowl, and passerines through the proposed location, there is little wildlife survey data in the vicinity of the proposed location, creating a situation with high uncertainty in addition to substantial underlying cause for concern. Considered together, it is reasonable to conclude that this is an inappropriate location for an industrial wind facility.

As importantly, it is frequently the case that a single wind facility, even one consisting of a relatively small number of turbines, is just a starting point for additional development. We are concerned about the cumulative impacts of development in this area, given the importance of this area to wildlife.

Conclusion While we fully support environmentally responsible wind energy development as an important component of a broader strategy to combat climate change, we find that the proposed location of the Scotia Wind project has high biodiversity value, and that development and operation of a wind facility at the site along the Keweenaw Ridge poses significant risks of negative impacts to state and federally listed species and other species of conservation concern. We support statements provided earlier in this letter by U.S. FWS that the proposed site “presents a high potential for wildlife impacts” and “is what U.S. FWS Land-Based Energy Guidelines identify as “critical area of wildlife congregation (includes bird migration corridors). The Keweenaw Ridge is thus an inappropriate location for sighting industrial wind energy infrastructure.

The complete letter can be obtained by contacting the Guardians

Nature Conservancy Wind Map:  Analysis shows Keweenaw Ridge not Right Location for Industrial Wind Projects

The Nature Conservancy has released a map of Michigan for their “Site Wind Right Map” program.  The Map is presented as a screening tool for participants in the renewable energy market to identify areas where renewable energy development is unlikely to encounter wildlife-related conflict. You can access the map at: https://www.nature.org/en-us/what-we-do/our-priorities/tackle-climate-change/climate-change-stories/site-wind-right/  .  

The analysis combines the best available science on high-quality wildlife habitat and intact landscapes.  Nature Conservancy states on their web site the map analysis was based on review of existing research and discussions with key partners including local, state, and federal wildlife agencies and other conservation professionals.     

The “Site Wind Right Map” screens out the Keweenaw Ridge and most of the Upper Peninsula as a location to site utility-scale wind projects like proposed recently in Adams & Stanton Townships. 

The Guardians of the Keweenaw Ridge contacted the Nature Conservancy scientists who developed the Michigan Map.   Those scientists stated the four wildlife features that cause our area to be inappropriate for utility-scale renewable energy development are the presence of: 1) intact natural habitats, 2) water/wetlands/riparian corridors, 3) protected/managed lands and 4) areas of other biodiversity significance.   The map did not consider the Keweenaw Ridge’s importance as a major spring raptor migration route. The map also does not include the extent of the many hibernacula that support several at-risk bat species along the Ridge.

 The Guardians have consistently stated over and over that siting industrial wind infrastructure along the Keweenaw Ridge was not appropriate because of the many unique environmental attributes of the area.  The Nature Conservancy “Site Wind Right” Map supports this conclusion.