February 18, 2014

Secretary Sally Jewell Department of the Interior 1849 C Street NW Washington, DC 20240 We, the undersigned organizations working to protect and preserve the ecological integrity of the St. Lawrence River, its watershed and the species dependent upon the health and vitality of the River, are writing on behalf of our many members and supporters to voice strong objection to the Department of Interiors decision to issue permits for up to thirty years to developers of renewable energy projects to take (injure, kill or otherwise disturb) bald and golden eagles. While we agree with the Department that renewable energy development is vitally important to our nations future, we do not agree with your assertion that extending the period during which it is permissible to kill eagles and making the permitted entity the wind project owners responsible for self-reporting kills, is the right way to develop any project, much less renewable energy. We simply cannot support trading species protection for energy development. The Upper St. Lawrence River valley is a home and critical seasonal foraging habitat for a variety of winter raptors, including a growing number of over-wintering bald eagles. In addition the northeastern portion of Lake Ontario and the St. Lawrence River is an important migratory flyway for a large number of waterfowl and songbird species that pass through en route to and from northern breeding grounds. Through the diligent efforts of state agencies and the cooperation of our groups, bald eagles are again establishing nesting pairs in our region, a region threatened by massive industrial scale wind farms by developers who have been less than forthcoming and cooperative on a range of environmental and conservation issues throughout the application process. The Departments thirty year permit provision will likely become a license to kill these majestic and iconic birds.

Despite the Departments claims to the contrary, this rule change will provide no insurance that eagle populations will be safeguarded. The federal government must enforce existing laws that protect birds and other wildlife, including the Endangered Species Act, the Bald and Golden Eagle Protection Act, and the Migratory Bird Treaty Act. We urge the Department to withdraw this rule and develop measures that will ensure meaningful, enforceable protections for eagles.

Sincerely,

Lee Willbanks Upper St. Lawrence Riverkeeper, Executive Director Save The River Clayton, New York

Jake R. Tibbles, Executive Director Thousand Islands Land Trust Clayton, New York

Emily Conger President A2A, Algonquin to Adirondacks Collaborative Lansdowne, Ontario