Wind turbines: environmental damage

Wind turbines: environmental damage

Serious, permanent and irreparable damage Destruction of Habitat

140. Many species of birds such as the Greater Prairie-chicken and other animals will suffer serious, permanent and irrevocable loss of habitat no less devastating than which occurred when the original prairie was plowed.
140.1 The following photographic exhibit is a fair and accurate representation of habitat damage resulting from a relatively low local industrial wind turbine commercial electric power generation facility.

140.1 lines of industrial wind turbines

140.1 lines of industrial wind turbines

141. Predation from ground predators using the roads and trails will undoubtedly have an additional detrimental impact on the ability of local populations of ground nesting birds to sustain themselves.

Industrial wind turbines damage the quality of life

142. The industrial wind turbine commercial electric power generation facilities proposed for the Flint Hills Tallgrass Prairie Regional Ecosystem will destroy the visual amenities of the region with a Brobdignagian gothic graveyard of gigantic machines atop towers that are grossly disproportionate to the scale of the historic and environmental character of the Flint Hills and “Prairie.”
143. The industrial wind turbine commercial electric power generation facilities proposed for the Flint Hills Tallgrass Prairie Regional Ecosystem are so grossly dispropo rti onate to the scale of th e historic and environmental character of the Flint Hills and “Prairie” that they are such an imminent danger of serious, permanent and irreparable damage that they cry out for equitable relief in the nature of a provisional remedy.
144. The headlong rush of a few corporate Defendant wind energy speculators toward irrevocable destruction of a land and landscape that has been cherished and tended by indigenous peoples for millennia and by the sovereign people of the State of Kansas for generations must be stopped.
145. The question of scale is of paramount importance in determining the environmental impact of a project.
145.1 The following graphic exhibit is a fair and accurate representation of some of the scale factors involved in siting industrial wind turbine commercial electric power generation facilities.

145.1_Inustrial wind turbine scale factors

145.1_Inustrial wind turbine scale factors

146. The following photographic exhibit is a fair and accurate representation of a human worker atop the nacelle of a industrial wind turbine in the Midwest.
146. Human worker atop industrial wind turbine nacelle

146. Human worker atop industrial wind turbine nacelle

147. The following photographic exhibit is a fair and accurate representation of the impact of industrial wind turbine commercial electric power generation facilities on life in France.
147. Industrial wind turbines and the French landscape

147. Industrial wind turbines and the French landscape

147.1 The following photographic exhibit is a fair and accurate representation of the impact of industrial wind turbine commercial electric power generation facilities on life in Germany.
147. Industrial wind turbine impact on German countryside

147. Industrial wind turbine impact on German countryside

148. The inevitable network of service roads, transmission lines, substations, fences or other facilities will further fragment the habitat at or near ground level and irrevocably destroy the quality of life in the region.
148.1 Habitat fragmentation from Industrial wind turbine infrastructure

148.1 Habitat fragmentation from Industrial wind turbine infrastructure

148.1 The preceding photographic exhibit is a fair and accurate representation of the gigantic heelprint even a small industrial wind turbine commercial electric power generation facility grinds into the land and landscape.
148.2 The following photographic exhibit is a fair and accurate representation of damage associated with right-of-way maintenance for an even smaller industrial wind turbine commercial electric power generation facility in West Texas.
148.2 Industrial wind turbine right-of-way maintenance roads

148.2 Industrial wind turbine right-of-way maintenance roads

149. The necessary and ubiquitous aircraft warning lights and the blade “flicker” effects inevitably and necessarily associated with operation and maintenance of industrial wind turbine commercial electric power generation facilities will cause serious, permanent and irreparable damage to the quality of life throughout the Flint Hills Tallgrass Prairie Regional Ecosystem and substantially reduce the value of real property for residents over large areas of the region.
150. To permit the wanton destruction of a unique national and international resource treasure such as the Flint Hills Tallgrass Prairie Regional Ecosystem is an ecological atrocity of such magnitude as to be inconsistent with the values dominating the spirit of the United States Constitution and the Constitution of the State of Kansas.
150. The Flint Hills Tallgrass Prairie beneficiaries

150. The Flint Hills Tallgrass Prairie beneficiaries

Please continue to the next section of the complaint, a detailed description of Wind turbines: serious, permanent and irreparable environmental damage