Wind Turbines: serious, permanent damage

127. Upon information and belief, since the renewal of certain tax advantages and subsidies for wind energy speculators and their “Wind Industry,” a number of industrial wind turbine commercial electric power generation facilities have been proposed to be located throughout the Flint Hills Tallgrass Prairie Regional Ecosystem as can be seen from the following graphic exhibit.
129. Upon information and belief, Greenlight Energy admits that significant development of industrial wind turbine commercial electric power generation facilities in the Flint Hills Tallgrass Prairie Regional Ecosystem will cause serious permanent and irreparable damage.
130. The industrial wind turbine commercial electric power generation facilities proposed by the corporate Defendant wind energy speculators will cause serious, permanent and irreparable damage to the unique national and international resource treasure that is the Flint Hills Tallgrass Prairie Regional Ecosystem by becoming an irreconcilable environmental system determinant irrevocably committing the entire Regional Environ­ mental System and all its myriad elements, processes and systems to a future dominated by industrial wind turbine towers where once there was a sea of grass over which magnificent birds soared.
128. The following photographic exhibit is a fair and accurate representation of the scene of large scale industrial wind turbine commercial electric power generation facilities in Germany and the public reaction to those facilities.

Killing Birds

131. Upon information and belief, Greenlight Energy admits that significant bird collision problems have occurred with existing wind turbine generators, particularly at flyway sites such as Altamont Pass in California.
132. Upon information and belief, Greenlight Energy admits that responsible wind development should avoid certain migratory bird routes or dense avian habitats, but insists on siting a number of large scale industrial wind turbine commercial electric power generation facilities in some of the most ecologically sensitive areas of the Flint Hills Tallgrass Prairie Regional Ecosystem.
133. Soaring birds such as hawks, eagles and vultures, and other birds that migrate at night within two to four hundred feet of the ground are vulnerable to kills from collisions with the turbine blades, or from flying into the gigantic turbine towers. Certain weather conditions and events may dramatically increase the occurrence of bird strikes and may result in massive bird kills.
133.1 The following photographic exhibit is a fair and accurate representation of the relatively low industrial wind turbines located at Altamont Pass in California near San Francisco.

134. Industrial wind turbine commercial electric power generation facilities should avoid locations where there is a large prey base for raptors such as the Flint Hills Tallgrass Prairie Regional Ecosystem where wintering and migratory populations of raptors are attracted to the native grasslands because of the availability of prey and the topography.
135. Construction, operation and maintenance of industrial wind turbine commercial electric power generation facilities in the Flint Hills Tallgrass Prairie Regional Ecosystem with scores of industrial turbines installed at a height of 350 feet or greater will create a killing zone for local and migrating birds of such size and duration that serious, permanent and irreparable damage will be done to species whose future is already threatened.
135.1 The following photographic exhibit is a fair and accurate representation of the kill zone associated with the relatively low industrial wind turbines located at Altamont Pass in California near San Francisco.
136. The Turkey Vulture which is one of the most visible large soaring birds gracing the sky over the prairie hills of Kansas from mid March thru October will suffer serious, permanent and irreparable damage from the industrial wind turbine commercial electric power generation facilities proposed for the Flint Hills Tallgrass Prairie Regional Ecosystem as they take advantage of the updrafts over the hills and glide back and forth over the ridges and out over the plateaus usually from 50 to several hundred feet over the ground.
137. Locating industrial wind turbine commercial electric power generation facilities in the Flint Hills Tallgrass Prairie Ecosystem will cause serious, permanent and irreparable damage to migratory and resident breeding populations of Turkey Vultures, Red-tailed Hawks, American Kestrals, Rough-legged Hawks, Peregrine Falcons, Prairie Falcons, Northern Harrriers, Short-eared Owls and Loggerhead Shrikes as they search the grasslands for food and are attracted to the other dead birds, bats and insects, including dragonflies, buttereflies and moths that have been killed by the turbine blades.
137.1 The following photographic exhibit is a fair and accurate representation of a Golden Eagle killed by the relatively low industrial wind turbine commercial electric power generation facility at Altamont Pass.
137.2 The following photographic exhibit is a fair and accurate representation of an American Kestral killed by the relatively low industrial wind turbine commercial electric power generation facility at Altamont Pass.
137.3 The following photographic exhibit is a fair and accurate representation of some body parts of a bird on the ground after an encounter with the relatively low industrial wind turbine commercial electric power generation facility at Altamont Pass.
137.4 The following photographic exhibit is a fair and accurate representation of a hawk killed by the relatively low industrial wind turbine commercial electric power generation facility at Altamont Pass.

Destruction of Habitat

138. “Industrialization” of the Flint Hills by industrial wind turbine commercial electric power generation facilities with extensive networks of gigantic wind turbines, service roads and high voltage transmission power lines as well as the security fences required now as an element of homeland security, together with the strobe or other lights needed to alert aircraft to the danger, the overhead movement and noise of the gigantic propeller blades and the associated distribution of those sounds through the earth, will fragment the Flint Hills Tallgrass Prairie Regional Ecosystem and endanger the entire Regional Environmental System of which the Flint Hills Tallgrass Prairie Regional Ecosystem is a vital element.
139. The construction activities associated with development of industrial wind turbine commercial electric power generation facilities cause serious, permanent and irreparable damage to the region in which they take place.
139.1 The following photographic exhibit is a fair and accurate representation of construction activities associated with development of a ridgeline industrial wind turbine commercial electric power generation facilities in West Virginia.

139.2 The preceding photographic exhibit is a fair and accurate representation of an industrial wind turbine commercial electric power generation facility at Woodward, Oklahoma.
139.3 The following photograhic exhibit is a fair and accurate representation of the kind of right-of-way that must be maintained at industrial wind turbine commercial electric power generation facilities. This right-of-way is located in the hills of West Virginia.