Bobby Jindal Governor State of Louisiana Robert J Barham .pdf

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					Bobby Jindal                             State of Lou isiana                                 Robert J. Barham
 Governor                                                                                       Secretary
                                 Departme nt of Wildlife and Fisheries                        Jimmy L. Anthony
                                        Office of Wildlife                                   Assistant Secretary

 May 18, 2011

 ATTN: Wind Energy Guidelines
 Division of Fisheries and Habitat Conservation
 U.S. Fish and Wildlife Service
 4401 North Fairfax Drive
 Mail Stop 4107
 Arlington, VA 22203-1610

 RE:	   Draft Land-Based Wind Energy Guidelines
        Public Notice Date: February 9, 2011

 To Whom It May Concern:

 The Louisiana Department of Wildlife and Fisheries, as the agency exercising administration
 over the wildlife resources of the State, submits these recommendations to the U. S. Fish and
 Wildlife Service (USFWS) in accordance with, but not limited to, the provisions of the Fish and
 Wildlife Coordination Act (16 U.S.C. 661 et seq .). These recommendations shall require
 thorough consideration and be adequately addressed in the final version of the Land-Based Wind
 Energy Guidelines.

 C ha pte r one

 Whereas the Department applauds your decision to make these guidelines voluntary, we do see a
 limited opportunity where mandatory use of the guidelines may be warranted - if projects require
 federal funding, developers should be required to implement some or all of the guidelines.
 Simi larly, should the federal government advise proponents of wind turbine installations to
 perform surveys or enact these guidelines, some federal grant monies should be made available
 to those performing said surveys or enacted guidelines, particularly where those benefit the
 mission of USFWS to protect our natural heritage, or where data may assist in development of
 future guidelines.

 Cha pte r two

 The inclusion of a monitoring component, both pre-planning and post-construction, is reassuring
 and will likely assist with adaptive management in later stages. The document should, perhaps,
 include discussion of use of weather towers or other weather logging devices frequently the

                  P.O. BOX 98000' BATON ROUGE. LOUISIANA 70898-9000 ' PHONE (225) 765-2800
                                     AN EQUAL OPPORTUNITY EMPLOY ER
Page 2
Draft Land-Based Wind Energy Guidelines
May 18,2011

very first step in the process; disturbance to sites may be caused by such construction no matter
how temporary. Also, although, the Department recognizes the distinction between the
reconnaissance visit and follow-up surveys, others may not immediately understand such. We
recommend that in Tier 2, the mention of at least one "reconnaissance" visit be eliminated in
favor of placing distinction and emphasis on the critical multiple survey visits. Please also note
that surveys should be completed not simply year round, but throughout the day, as well.
Currently, the document stresses the importance of seasons, while only mentioning the
importance of times of day in passing. Surveying during all hours of the day (especially
daybreak and sunset) would allow for detection of commuter flights of wading birds and other
colonial birds. On page 27, please change "appropriate times of the year" to "appropriate times
of the year and appropriate times of the day" and maintain this spirit throughout.

General comments

Throughout the document, state's input, in addition to federal and tribal, is often highlighted.
The Department appreciates your cooperation and thoughtfulness regarding this inclusion. We
would, however, like to see this phrasing other times in the document. Please be mindful of
these oversights. For example, on page 30, the phrase           developer should consider the
Service's input " should be changed to        developer should consider both the Service's and
the states' inputs " Also, understand that should additional burdens be placed on the states, as
will likely be the case with these new guidelines (whether voluntary or mandatory), the
Department believes federal funds should be made available to the states for the additional

Wind energy facilities construction and operation have the potential to adversely affect species
and habitats of conservation concern; therefore, biological surveys should be conducted to
determine the nature of impacts and how best to avoid, minimize, and/or mitigate such impacts.
In Louisiana, suitable habitat for rare, threatened, and endangered species may be affected by a
proposed wind farm. Also, critical habitats, state and federal parks, wildlife refuges, scenic
streams, and wildlife management areas may be found within the specified boundary of a wind
farm. The wind farm developer should consult with the state agencies during the site selection

The quantity and quality of jurisdictional wetlands at the wind farm site should be documented.
A U.S. Army Corps of Engineers approved wetland determination should be provided. Actions
must be taken to avoid and/or minimize adverse impacts to such resources (e.g. not locating
turbines, access roads, transmission and gathering lines and substations in wetlands). Those
actions and other measures designed to fully compensate for unavoidable wetland impacts must
be addressed in a mitigation plan and approved by the state wildlife agency.

The authors of the guidelines recognize that wind energy facilities have the same potential as any
other type of facility to disrupt hydrology, enhance sedimentation, and isolate portions of
watersheds if they are not planned and constructed correctly. The Department would urge that
guidelines ensure that the safeguards in place to protect watersheds are also in place for wind
energy facilities.
Page 3
Draft Land-Based Wind Energy Guidelines
May 18,2011

The frequent direction of readers to the USFWS Wind Energy website , although understandable
given the magnitude of information and scenarios with wind energy siting and impacts to
wildlife and habitats, we believe would be unacceptable in the final draft . There will probably be
a large proportion of interested readers who will not bother visiting a website for further
information , Instead, we urge the USFWS to make the document more inclusive.

The Louisiana Department of Wildlife and Fisheries greatly appreciates the opportunity to
provide comments regarding the Draft Land-based Wind Turbine Guidelines. Please do not
hesitate to contact Natural Heritage biologist Beau Gregory at 225-765-2820 should you need
further assistance.

Ji   Y L. A     ny
Assistant Secretary


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