Related Content
- Jurisdiction
- Equitable Jurisdiction
- Venue
- Class action
- Class Representative
- Individual plaintiffs
- Defendant Scottish Power
- Defendant PacifiCorp
- Defendant PPM Energy Inc.
- Scottish Power and commercial wind power development
- Defendant Greenlight Energy Inc.
- Sale of Elk River Windfarms LLC
- Defendant The Empire District Electric Company
- The Empire District Electric Company and the Elk River Project
- The Flint Hills Ecoregion
- Flint Hills Endangered Flora & Fauna
- The Native Prairie Grasslands
- Tallgrass Prairie National Preserve
- Legislative History: Tallgrass Prairie National Preserve
- The Konza Prairie Site
- The LTER Program
- The Prairie Parkway
- The Flint Hills Scenic Byway
- Flint Hills Scenic Resources
- International recognition of the Tallgrass Prairie
- Birds of the Tallgrass Prairie
- Tourism
- Beneficial impacts of tourism
- Economic impacts of tourism
- The Blue Ridge Parkway Experience
- Serious, permanent & irreparable damage
- Wind turbines kill birds of prey
- Wind turbine development destroys habitat
- Wind turbine development damage
- Damage to quality of life
- Wind turbines: an economic catastrophe
- Tax avoidance and subsidies
- Voodoo economics of wind turbine power
- Catastrophic wind turbine failures
- The Electric Power Grid
- The prayer for relief
![127. Proposed Flint Hills Wind Turbines - Victor John Yannacone, jr 127. Proposed Flint Hills Wind Turbines](https://yannalaw.com/wp-content/uploads/VCimages_51-2c_127_proposedWindmills-824x1024.jpg)
127. Proposed Flint Hills Wind Turbines
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.
![128. Der Spiegel - Victor John Yannacone, jr 128. Der Spiegel](https://yannalaw.com/wp-content/uploads/VCimages_128_derSpiegel-774x1024.jpg)
128. Der Spiegel
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.
![133.1 Wind turbines at Altamont Pass - Victor John Yannacone, jr 133.1 Wind turbines at Altamont Pass](https://yannalaw.com/wp-content/uploads/VCimages_51-2c_133-1_AltamontPass-1024x731.jpg)
133.1 Wind turbines at Altamont Pass
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.
![135.1 Altamont Pass Raptor Kill Zone - Victor John Yannacone, jr 135.1 Altamont Pass Raptor Kill Zone](https://yannalaw.com/wp-content/uploads/VCimages_135-1_AltamontKillZone-1024x712.jpg)
135.1 Altamont Pass Raptor Kill Zone
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.
![137.1 Golden Eagle Killed by Altamont Pass wind turbines - Victor John Yannacone, jr 137.1 Golden Eagle Killed by Altamont Pass wind turbines](https://yannalaw.com/wp-content/uploads/VCimages_137-1__goldenEagleKilled-1024x768.jpg)
137.1 Golden Eagle Killed by Altamont Pass wind turbines
![137.2_American Kestrel killed by Altamont Pass wind turbines - Victor John Yannacone, jr 137.2_American Kestrel killed by Altamont Pass wind turbines](https://yannalaw.com/wp-content/uploads/VCimages_137-2_deadKestrel-1024x773.jpg)
137.2_American Kestrel killed by Altamont Pass wind turbines
![137-3 Raptor body parts from Altamont wind turbines - Victor John Yannacone, jr 137-3 Raptor body parts from Altamont wind turbines](https://yannalaw.com/wp-content/uploads/VCimages_137-3AltamontBodyParts-1024x777.jpg)
137-3 Raptor body parts from Altamont wind turbines
![137-4 Hawk killed by Altamont wind turbines - Victor John Yannacone, jr 137-4 Hawk killed by Altamont wind turbines](https://yannalaw.com/wp-content/uploads/VCimages_137-4AltamontDeadHawk-1024x782.jpg)
137-4 Hawk killed by Altamont wind turbines
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.
![139.1 Wind turbine construction - Victor John Yannacone, jr 139.1 Wind turbine construction](https://yannalaw.com/wp-content/uploads/VCimages_139-1windmillConstructiuon1-1024x617.jpg)
139.1 Wind turbine construction
![139.2 commercial wind turbines, Woodward, OK - Victor John Yannacone, jr 139.2 commercial wind turbines, Woodward, OK](https://yannalaw.com/wp-content/uploads/VCimages_139-2_WTrow1-766x1024.jpg)
139.2 commercial wind turbines, Woodward, OK
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.
![139.1 Wind turbine construction - Victor John Yannacone, jr 139.1 Wind turbine construction](https://yannalaw.com/wp-content/uploads/VCimages_139-1windmillConstructiuon1-1024x617.jpg)
139.1 Wind turbine construction
Please continue to the next section of the complaint, Wind turbines: an economic catastrophe.