By David Wojick
Land-based wind turbines kill golden eagles, so every turbine requires an Eagle Protection Act permit from the U.S. Fish and Wildlife Service (FWS) to kill them.
These permits are predicated on a supposed mitigation strategy where turbine kills are offset by reducing the number of eagles electrocuted by power poles. Electrocution is estimated to kill about 500 golden eagles a year. The strategy calls for 12 eagles to be saved for every 10 killed by wind turbines.
My research on this strategy found that the number of golden eagles actually saved from electrocution must be very low, far lower than the number killed by wind turbines. The math is quite simple. The number of power poles being made safe is far too low to be effective.
So I set out to inform the FWS of my findings, which should be of great concern to them. They need to rethink their golden eagle wind-kill mitigation strategy.
Beginning on September 25, I sent the cautionary email shown below to over a dozen FWS people and offices. Most of the people were in the Migratory Birds Office, which oversees the Eagle Protection Act permitting. In addition, each of the eight FWS regional offices which issue the Eagle-kill permits has a specific email address for that purpose, so I sent to them.
I sent every email twice in one week and to date have not received a single reply. So, I am here publishing the email to make it in effect an open letter to the Fish and Wildlife Service.
Here is the generic body of my FWS email:

“Subject: Electrocution mitigation for wind kills does not work
Hello FWS,
I understand FWS is looking into eagle take permits for wind turbines at Secretary Burgum’s request. I just did a study on the mitigation component and my finding is that electrocution mitigation in its present form is completely ineffective. Very few, if any, electrocution deaths are being prevented, certainly not the 1.2 deaths per turbine death that is called for.
The reason is that the poles per death number FWS is using is far from what is needed. While FWS currently requires about 278 poles to be “made safe” per wind-killed eagle, the correct number may be closer to 67,000. It is no wonder the mitigation program has failed.
The national average is actually close to 370,000 poles per eagle death based on 500 kills with 185 million poles. The research literature suggests that high risk poles may be 5.5 times deadlier, which is 67,000. At this rate fixing just 278 poles per wind-kill will have little if any effect. Better data might change these numbers a bit but not enough to make a difference. This is explained in section 1 of my report which is at https://www.cfact.org/2025/06/29/cfact-report-feds-fail-to-offset-wind-turbine-eagle-kills/.
Given these numbers there should be a moratorium on permitting until an effective mitigation strategy is developed. FWS regulations call for monitoring the effectiveness of mitigation.
See my https://www.cfact.org/2025/07/28/fws-is-violating-its-own-eagle-kill-regulations/.
I will be happy to discuss this important issue.
My best regards,
David Wojick, Ph.D.
CFACT Senior Advisor and Policy Analyst
End of email to FWS.
I am now pursuing other means of communication. In addition, I invite people who object to a specific wind power project to use this data and object to that project’s eagle kill permit. Without this Federal permit, the wind project cannot operate.
The Regional Permitting Office contacts are listed here:
https://www.fws.gov/program/migratory-bird-permits/contact-us
Maybe this will get their attention.
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In Trump’s first term I sent Zinke tweets asking him to rescind the allowance given to wind mills to kill eagles. He did nothing
What are the chances the wind mills under count the actual eagle kills? Dito for other rapter kills.
I understand that for certain endangered raptors, if you or I killed one, even accidentally and without being at fault (say one flies into your windshield as you’re driving down the highway) is $250,000. So I think those “permits” should be charging the same amount per “permitted” kill.
That would go a long way to ending the stupidity of wind ‘power.’
And that “cost” would not be tax deductible.
The current shut down is ideal to fire everyone of them, for cause
I only hear about Golden Eagles being killed by wind farms. What about Bald Eagles? How many of those are being killed? …and that’s our national bird!!
My focus is Goldens because their numbers are small and dwindling plus they are concentrated in the West where most wind development is. The Bald Eagle population is huge in comparison and largely Eastern. But yes the electrocution scam applies to both.
The strategy calls for 12 eagles to be saved for every 10 killed by wind turbines.
I’m sorry, but this sounds completely unhinged. Besides, they seem to be somewhat in the dark on the numbers to begin with:
we can estimate that there are roughly 30,000 golden eagles across the United States. However, golden eagle populations are believed to undergo a roughly 10 year cycle. That said, having only four years of data from the survey years of 2006 to 2009, limits our ability to assess the long-term population trend. – USFWS
I cannot think of any other cause or industry that behaves in such a cavalier fashion
Mad Ed and his political friends?
Their consensus is falling apart…
Reform made the political weather all through the summer and Kemi Badenoch is catching up:
Kemi Badenoch vows to repeal Climate Change Act
Tory leader says she would replace it with ‘cheap energy’ strategy, ending decades-long consensus on climate
…
Ed Miliband, the energy secretary, said: “This desperate policy from Kemi Badenoch, if ever implemented, would be an economic disaster and a total betrayal of future generations. – Guess Who
Ed knows had he won in 2015 he could have done it all, but now…. well, it’s over bar the shouting.
That should read: Ed knows had he won in 2015 he could have wrecked it all, but now…. well, it’s over bar the shouting.
The strategy was implemented under Obama to get wind around the Eagle Protection Act.
It’s still mental, David; especially now we know…
The really odd thing is that, while you could certainly count a dead eagle, there’s no good way to say how many eagles were not killed.
Models can tell how many eagles were not killed . Duh!
(sarc)
My math is a simple model that shows few if any eagles were not killed. We have a reasonable estimate of the average death rate per power pole and at that rate so few poles are being altered that almost no eagles are saved.
They are doing fewer than 300 poles per wind death while the average says it should be around 350,000.
Yes it is an offset program that cannot be verified to work. But the math shows that it cannot work as presently done.
“The strategy calls for 12 eagles to be saved for every 10 killed by wind turbines.”
I struggled with Algebra and Calculus in school. (Did great with Geometry! I could “see” the shapes and the formulas made sense.)
But it seems to this sometimes mathematically challenged Layman, if they saved the 12 eagles but didn’t kill the 10 then there’d be 22 eagles.
What did I miss?
True but the official point is to exempt wind from the Eagle Protection Act not to maximize saved lives. And since wind is paying to do the poles that would not happen if no wind payments. So the best you can do is not kill the ten by banning wind. Works for me.
And that is my goal, to give Trump what he needs to kill wind.
The whole idea of “offsetting” is morally repulsive. Perhaps the FWS swamp needs draining.
That FWS mini swamp needs to be wiped out during the shutdown.
Lock all existing wind mills and dismantle them.
No more permits for new ones
Obama, the repulsive one, approved it!
Offsetting is a common practice in environmental law but not with lives. Under the Clean Water Act you can drain a wetland if you build a new one someplace else.
You should write to Secretary Burgum and President Trump directly, and tell Burgum you sent the same to the president.
President Trump hates windmills. Your letter might give him the impetus to do something about it.
Trump said “no more windmills!”. Maybe we can get him to cancel all the current operating windmills over the eagle issue (one can dream:).
How is a pole made safe from eagle kills? Is the cost for that paid by the windmill owners or the utility (i.e. the people?)
Utilities are cost plus entities. Any increase in their costs gets reflected in rates, to ensure they make at least 9%/y on their rate base. Elementary stuff.
So you are saying that utilities pay the cost of the eagle safety improvements and not the windmill owners whose machines impose such cost? Seems unfair to me but then little is fair regarding wind and solar power.
Basic economics, all costs get passed on to the consumer, eventually.
The last guy in the chain pays – the consumer.
The owners pay as part of their permit. It is called “compensatory mitigation”. The pole is made safer by changing the spacing between the wires and in other ways. There is a literature on this. Start with a search on “Eagle electrocution”.
If the program were realistic the cost would kill wind. I will settle for that.
So, just curious, but eagles have great eyesight- how do they not see the wind turbine blades? Are eagles killed by wind turbines documented?
They cannot see the turbulence coming off the blades, feel it is thermal to rise on, but are quickly turned upside down by the turbulence and fall to the ground, without hitting a blade, according to videos.
Often, they are eaten by wild life, before being counted, meaning any count is too low.
The FWS folks are well aware of all of this, but not sharing with the public, as found by Wojick.
I believe it is the reduced air pressure on the back side of the blade which causes hemorrhages in the birds passing close to a blade. Had the bird flown a few feet higher or lower it would not be killed.
Videos show the turbulence coming off blade rear edges is enormous compared to the size of the birds
That turbulence tossed them around like dolls and likely fractures their wings, well before they tumble to the ground.
Differences in pressure could cause lung damage/bleeding as well.
An eagle’s field of view is approximately 340 degrees, not 270 degrees, and this vision is a result of their eyes being fixed in place, requiring them to turn their heads to a near-full circle to achieve this wide range.
This exceptional visual capability is thanks to several factors, including a large number of light-sensitive cells in the retina, unique adaptations like two foveae for simultaneous forward and side focus, and the ability to see ultraviolet light
Eagles are looking straight ahead, the blades of the windmills come at them from the side.
If you notice the flying eagle picture above, the eye is set on the side of the skull, like most birds, giving them a monocular field of vision of something like 270 degrees. They would certainly be aware of motion “from the side”, but unfamiliar with the tip speed. Sort of like the early days of the railroad when a man, familiar with the horse and buggy, attempted to cross the tracks ahead of an oncoming train — he made it halfway!
Birds of prey seldom if ever look up. They mostly peer downward to scan for prey. Remember, a blade has considerable velocity at the end of the blade. Birds of prey have no inherited sense of something moving that will hit (or nearly so) them during flight.
Imagine streets and roads with no stop signs and drivers having blinders that only allow them to see the directly ahead of them.
Yes but most of the data is secret. Every death found by a wind facility is required to be reported to FWS but this data is not publicly available. My report has a section on this. There are some short term public reports and in the West the Golden Eagle is the most killed raptor. A recent modeling study estimates the Golden deaths from wind at 200 per year which is double ten years ago. The real numbers might be much higher.
Let’s face it David, who actually cares about all those chopped eagles…
… when you are trying to save the planet from a 0.01% increase in atmospheric CO2 ! /sarc !!!!!
Certainly not the green/left “environmentalists”.!
Something must be wrong with my math. Seems to me they will have to issue enough permits to kill every eagle long before we get “clean” energy.
Well, couldn’t they just buy “eagle offsets”?
Which is pretty close to the fact!
Incredible. They just as well might say “but we’re saving eagles in a parallel universe”.
I see it coming. Eagle cap and trade.
That is, sort-of, the point of placing a limit on the number of permits available.
Why can’t traffic camera technology be used to monitor the eagle killers?
It should be required.
Realize that the reasoning used above means the more eagles they kill, the more other eagles benefit!
Instead, the turbine should be shut down when they reach their quota of dead eagles, similar to how some hunting seasons close.
Editing snafu. Correct capitalization (only) – “you’ve already said that”.
David, great article.
I am going to summarize a couple of points of which I am sure you are well aware, but which need broader dissemination. First, the FWS has revised population numbers for Bald Eagles in all flyways, but the Central flyway (encompassing the Mountain West) had the biggest adjustment. It went from about 1,200 birds in 2010 to some 26,000 birds recently. Allegedly all these adjustments were the result of population growth, with the smaller adjustments being justified by those populations having been closer to their carrying capacity during the decade, and the enormous adjustment in the Central flyway being justified by its 2010 population being closer to the exponential toe of the logistic curve.
Even so a population growing by nearly 22 times in a decade is nigh impossible as it suggests each breeding pair raising more than a fledgling each year. So, if we are to believe these numbers there must be migration from neighboring flyways into the Central flyway. Why this matters is that the Central flyway has been viewed as especially important because of it being relatively clean from a hazards standpoint. Now, however, we are busy putting up wind plants, solar plants and transmission lines. What goes for Bald Eagles likely applies to Golden eagles too. In fact, I am aware of data showing that the present number of Golden Eagle strikes in a portion of the Central flyway is dominated by turbine hits — more than automobiles, rifle shots, and power lines combined.
Second, because of population growth the number of bird kill permits has gone from 70 to just shy of 1,600. So, there are plenty of permits available, but the rising number of birds at the same time raises the probability of a deadly strike. Just because there are allegedly more eagles doesn’t unprotect these birds. They are still the focus of the Bald and Golden Eagle Protection Act of 1940.
Third, the FWS itself is internally conflicted over why it is that what has always been a conservation effort is now being driven by industry needs. This conflict is apparent upon full reading of this document; Deborah Shearwater et al v. Dan Ashe, et al 2015.
This conflict extends, however, throughout the wildlife services at the state level too. The biologists tend to be climate anxious and want wind/solar to displace coal/gas, but they recognize the risks inherent to wind/solar. They are also under pressure from higher state officials to “not push back on wind/solar” as someone in the game and fish department here told me. I’d say that continuing pressure in favor of wind/solar, which may take a while for the new paradigm to sweep away, along with these internal conflicts probably explain why they don’t answer to any of us.
Very nice David thank you for your work. My concern is that no eagle kill forgiveness should be allowed for a power generation system that does not work in the first place. Wind can’t sustain the grid, wind can’t sustain a modern society, wind is expensive, wind is a threat to the grid, wind is short lived, wind needs 24 hour backup, wind can’t be recycled. To hell with wind, the loss of even one eagle can’t be justified especially by such a poor performer. Remove all wind from the grid and all wind mills, we have already lost too many eagles for no good reason.
Great comment.
In 2024 there was an offshore wind craze, fueled by the left wing, woke, autopen clique
Negotiated cost to the utility was 15 c/kWh, after 50% subsidies
But, you have to add about 11 c/kWh to cover all the cost that comes after you connect to the expanded/reinforced grid and finally for a hazardous waste landfill no one wants to talk about, for a total of 26 c/kWh, or 41 c/kWh, if no subsidies.
The totally awful scam is how effective the real numbers are fudged by means of juggling the numbers and brainwashing the public, so many folks have no idea about the real numbers, including almost all politicians, journalists, etc., who endlessly spout rosy talking points provided by lobbyists.
Put the basics of the article above and the named bureaucrats your forwarded emails to into an X post.
X gets results because when enough people retweet it, the number of people aware of the problems start getting noisy.
Government likes it quiet.
Every few weeks, we can retweet the storm and raise hell again.
With government individuals are ignored. Until they become crowds!
The pseudo-greenies can kill endangered raptors with government permission yet if I pick up the molted Peregrine Falcon feathers I routinely find in my yard I would face a $10k federal fine and possible imprisonment. Make it make sense!