Newly deputized Interior Secretary Sally Jewell, best known for her work as CEO of the outdoor equipment chain REI, was also a member of the board of directors of the National Parks Conservation Association (NPCA) until her summons to the Executive Branch. Late last week, NPCA President Tom Kiernan announced he was leaving the organization to helm the American Wind Energy Association (AWEA).
In an era when many mainstream green groups seem willing to turn a blind eye to wind power development near our national parks, NPCA has been a voice for caution. Now its recent president is paid to advocate for 1,200 wind development companies and a former board member is charged with overseeing an increase in wind turbines on public lands. Will NPCA's nuanced voice be drowned out by the wind?
ReWire asked NPCA spokesperson Kati Schmidt whether the recent career moves of the group's former brass would impede NPCA's ability to oppose wind projects it felt were ill-sited or ill-planned, especially near national parks. As Schmidt told ReWire:
Our position has not wavered, given the recent news about Tom Kiernan's career move and Sally Jewell's appointment as Interior Secretary. Mark Wenzler, NPCA's Vice President for Clean Air and Climate Programs notes, "NPCA acknowledges that wind energy can be part of the solution to lowering air pollution and greenhouse gases from electricity production that degrade our national parks." However, similar to our views on solar development, we remain aware that many of the areas considered prime locations for industrial-scale wind farms are in proximity to the same landscapes protected as parklands. While we support clean, renewable wind energy, we are also committed to protecting our parks from poorly sited developments -- particularly where viewsheds and wildlife corridors are concerned.
NPCA's concerns over wind development haven't been limited to the vicinities of national parks, but also extend to broader policy questions. Take, for example, the current move by the U.S. Fish and Wildlife Service (FWS) to extend the length of take permits for bald and golden eagles under the Bald and Golden Eagle Protection Act from 5 years to 30 years, an issue ReWire has covered in some depth.
In mid-2012, NPCA submitted a firmly worded letter opposing the 30-year permit notion, which said in part;
A great deal of land near and adjacent to our desert national parks is slated to be developed with renewable energy projects, including wind turbines, which kill numerous birds each year, including eagles. In fact, wind mills kill nearly half a million birds a year and the American Bird Conservancy has projected that number could more than double in 20 years if the U.S. reaches its renewable energy goals, according to a recent Washington Post news article. The wind farm at Altamont Pass, near the city of San Francisco, kills an average of 67 eagles each year while the Los Angeles Department of Water and Power's smaller Pine Tree Wind Turbine Center killed eight eagles during the last two years.
While we understand that the proposed rule changes would provide permit holders, like renewable energy projects, with greater certainty and correspondence with the timeframe of their projects, we don't believe that this should be done at the expense of bald and golden eagle preservation. The proposed extension of programmatic eagle take permits from five to 30 years would allow eagle permit holders to disturb, injure, kill or "take" eagles on an ongoing basis and would undoubtedly adversely impact bald and golden eagle populations. The rule change should also not be implemented because it is questionable whether the Fish and Wildlife Service has the resources to conduct the accompanying mitigation and monitoring they would need to undertake as part of the rule change in a climate of ever-shrinking budgets, programs and staff. Finally, the Fish and Wildlife Service lacks the requisite baseline data and models to justify extending the take permit to 30 years, as eagle population size can be cyclic and population trend estimates have large margins of error.
In closing, out of concern for golden eagle populations in our Southwestern National Park units and their importance for local ecology and the visitor experience, the National Parks Conservation Association opposes the proposed rule change governing eagle permitting due to the potential impacts on bald and golden eagle populations; fiscal constraints on the Fish and Wildlife Service that would make it impossible to appropriately monitor and manage the rule change; and the lack of credible baseline data on eagle populations that is needed before making changes to eagle permitting.
By contrast, AWEA's comments on the proposed rule change essentially said that the six-fold extension of the length of take permits didn't go far enough to make life easy for wind developers, because FWS was planning to reserve the right to modify permits and impose mitigation requirements if wind installations killed more eagles than expected. From AWEA's July, 2012 comment letter:
[T]he Proposed Rule does little to actually ensure cost certainty and project security for developers. In other words, while the Proposed Rule contains vague language with respect to ensuring cost certainty throughout the life of the permit, the rule explicitly gives the Service broad leeway to impose additional mitigation measures and even decrease the authorized level of take or revoke the permit entirely. As a result, the rule fosters more uncertainty with respect to costs than it does certainty. Indeed, the Proposed Rule provides permit holders with no assurances that unanticipated, overly burdensome mitigation requirements will not be placed on them or that the authorized level of take will be reduced whenever the Service deems that new scientific information calls for additional conservation measures.
A number of existing and proposed wind developments are in the vicinity of National Parks in the California Desert and nearby. Aside from the sprawling San Gorgonio Pass wind area at the west end of Joshua Tree National Park, the Interior Department just green-lighted the Searchlight Wind Project wedged between the Mojave National Preserve and the Lake Mead National Recreation Area. Proposed wind projects dot the northern periphery of the Mojave Preserve, including a proposal by Oak Creek to build turbines in the Castle Mountains area and a still-active testing permit issued to Element Power in 2010 for the narrow Mountain Pass corridor. A hybrid solar-wind project is in the planning stages for the Silurian Valley between the Preserve and the southern end of Death Valley. Farther afield, the 150-megawatt Spring Valley Wind Farm occupies a spot near the northern end of Great Basin National Park. National Parks and wind development come into potential conflict as far across the country as Rhode Island, where a proposed offshore wind installation has raised concerns about the effect on its historic South East Lighthouse on Block Island.
Throughout its history, the NPCA has often advocated for defending our National Parks when it would have been either inappropriate or impolitic for the National Park Service to do so. That's been especially true in the California desert in the last few years, as NPCA staff have often found themselves raising concerns about projects like the Ivanpah Solar Electric Generating System, a massive industrial facility built on the doorstep of the Mojave National Preserve, that major environmental organizations seemed all too willing to let slide by without substantive challenges.
It's important to note that that defense of California desert national parks took place on Tom Kiernan's watch and under his management. One could reasonably argue that hiring a proven defender of protected landscapes is a step in the right direction for AWEA. "Tom has demonstrated a strong commitment to and deep love for National Parks as NPCA President for the last 15 years," says David Lamfrom, NPCA's California Desert Senior Program Manager. "I think he's very likely to bring that commitment to his work at AWEA."
Of course, there's a limit to how much environmental savvy one can expect from any trade association: they exist to promote the financial interests of their members. That's why it's important that environmental groups continue to counter the interests of business as usual.
It may well be that the new prominence in the wind industry of two former high-ranking officials of the NPCA has no effect at all on the group's trajectory. But the real issue here goes far beyond NPCA, Kiernan, and Secretary Jewell.
It's the whole "stakeholder" issue that's relevant here. Environmental groups decide that keeping a seat at the bargaining table is of consummate importance. Groups that are willing to constrain their positions to fit within official parameters are the ones deemed to have sufficient gravitas to earn a seat at that table. Advocating that wind developers strive to kill five percent fewer eagles per megawatt of wind turbine capacity is deemed a realistic and professional position. Saying that wind turbine developers should be subject to the same penalties for killing eagles as any yahoo with a sixpack and a rifle is beyond the pale.
The revolving door for staff that connects green groups and business and government is an indication that the missions of all three constituencies have converged more than they should, and that means that the green groups have become more concerned about keeping that seat at the table than they are about watchdogging the corporations and agencies with whom they're sitting.
And there's no faster way to get a watchdog to wag its tail than offering a few table scraps.
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