In late June, HMANA formally commented for the second time on the U.S. Fish and Wildlife Service’s proposed rule to extend the lifespan of incidental eagle-take permits under the Bald and Golden Eagle Protection Act. Incidental take permits can be obtained for any development, including power distribution initiatives and communication installations, but probably will be most critical with wind-power projects. HMANA’s comments were directed primarily at permits tied to wind power projects.
HMANA’s letter restates our opposition to the new rule, which would expand the life of eagle-take permits from five to 30 years, with five-year reviews of each permit replacing the need to apply for a new permit every five years. Substituting the reapplication process for successive five-year permits with implicitly less vigorous five-year reviews of a 30-year permit effectively weakens the impact of any required public review of a project’s harm to eagles and other raptors. Further, this extension may compromise the effectiveness of post-construction mortality monitoring and may diminish the standards for a project to comply with the conditions of the take permits. Five-year reviews just aren’t going to be as rigorous as a new permit application process.
Finally, HMANA’s letter stresses that the service must adequately support periodic reviews of eagle populations. Given the recent proliferation of strategies for assessing avian populations, including those of the Raptor Population Index project undertaken by HMANA, Hawk Mountain Sanctuary, Bird Studies Canada, and HawkWatch International, several opportunities exist for the service to supplement its current methods of population assessments and these should be explored.