Climate change threatens to increase the risk of extinction of rare wildlife species and reduce the populations of many hunted wildlife species in Michigan. To reduce the threat of climate change to Michigan wildlife species, the state has set ambitious renewable energy targets, and wind energy will be an important component of Michigan’s clean energy future. Despite its inherent benefits, wind energy development in Michigan has the potential to harm some species of wildlife, especially bats and birds, if care is not taken to minimize adverse impacts. Other best management practice (BMP) documents for wind energy and wildlife exist, but they lack a Michigan perspective and framework for weighing the relative context-specific benefits of various practices. This set of BMPs adds specificity to Michigan’s unique geography and relevant wildlife species. This set of BMPs will be updated periodically as more information becomes available. We divided our recommendations into two sets: true BMPs, which broadly represent practices in industry, and “additional considerations,” which are generally applicable but might be applied differently in different regions, contexts, or circumstances.
Best Management Practices:
Additional Considerations:
The Michigan DNR recognizes that climate change and land use change are the primary threats to wildlife in Michigan, now and for the foreseeable future. We also recognize that energy policy to address the root causes of climate change will require land use change. Wildlife are seemingly caught in a no-win situation. However, many studies (e.g., Arnett et al. 2013, Hayes et al. 2019, Friedenberg and Frick 2021) have shown that changes in how renewable energy is constructed and operated can minimize or eliminate the threats to wildlife from land use change, which changes the equation from a no-win situation to a win-win situation. Our intent in developing this set of BMPs is to encourage voluntary conservation practices in the wind energy development sector for both rare and common wildlife in Michigan.
Best practices represent a different threshold than laws and regulations; BMPs tend to be practices that may not be appropriate in the same way in all cases. This is one reason that consultation with state or federal wildlife biologists can be useful; each potential development is unique. We originally organized BMPs by priority, because not all practices have the same level of effect. However, this made it difficult to distinguish between best practices and practices to consider in certain contexts or in trade-offs with other practices. For that reason, we have simplified the list of best practices and included a section of “additional considerations,” which might be case- or site-specific. A secondary intent of this set of BMPs is to highlight some ways in which Michigan regulations regarding wind energy differ from those of other states, especially regarding concentrations of bat hibernacula in abandoned mines and state laws that protect state-listed threatened and endangered species. The regulatory environment for wind energy development in Michigan has been and continues to be dynamic. We have attempted to clearly distinguish in this document best practices, which are voluntary, from regulations, which are not voluntary.
Federal and state wildlife agencies are distinct entities. They have their own jurisdictions and enforce their own laws through different sets of regulations and policies. Wind energy developers and operators are responsible for following both sets of regulations. Michigan’s list of endangered species, for instance, has more than 400 species, and unlike the federal Endangered Species Act (ESA), Michigan’s state law protects plants and animals equally. Within their borders, state wildlife agencies have jurisdiction over wildlife, which are managed in trust for the state’s citizens. Those jurisdictions vary from state to state. WLD encourages wind energy developers and operators to become familiar with state wildlife laws and regulations, including Michigan’s endangered species law and Wildlife Conservation Order. Communication with the Michigan Department of Natural Resources (DNR) consistent with recommendations made in the Communication Framework for Wind Energy Project Proponents and State Fish and Wildlife Agencies jointly published by the Association of Fish and Wildlife Agencies and the American Clean Power Association is one way to become familiar with our state laws, native species, and their habitats.
Climate change is a major threat to wildlife and their habitats in Michigan, and the burning of fossil fuels for energy generation is increasing the severity of that threat (Sovacool 2012). Hoving et al. (2013) estimated that 54% of 400 Michigan wildlife species were vulnerable to climate change, including 61% of rare species and 17% of game species. Thus, the transition to renewable energy sources and away from energy sources that perpetuate and worsen climate change is an important wildlife conservation strategy. That said, the benefits of renewable energy also come with costs. Renewable energy in the wrong place or implemented in the wrong way can cause considerable harm to wildlife.
Michigan has set an ambitious goal for transitioning from fossil fuel energy sources to renewable energy with economy-wide clean energy by 2040. Wind energy will continue to be a major part of the new energy mix. In Michigan, the costs per energy generated for wind and solar are similar. Unlike solar energy facilities, most of the land area within a wind energy facility is not fenced; agricultural and other rural land uses, including hunting and trapping, can usually continue to occur under the turbines.
The two taxa that are most impacted by wind energy development are birds and bats (Allison et al. 2019). Among both groups, risk tends to be greatest during fall and spring migration, but impacts can occur in any season. Birds can be impacted directly by mortality caused by wind energy developments or indirectly through loss of open grassland habitat without trees or structures that some bird species need to successfully reproduce (Conkling et al. 2022). Birds tend to strike any tall structures, and the movement of the wind turbine blades seems to add little if any risk (Maio et al. 2019). Wind energy turbines, communication towers, and tall buildings of a similar height are thus a direct mortality risk to birds in the same way.
Wind energy facilities can also cause some species of birds to avoid breeding in an area (Shaffer and Buhl 2016). Many grassland bird species are already in decline because so few suitable open fields remain on the landscape. This is especially true in Michigan, where several species of grassland nesting birds are on the state threatened and endangered species list.
Bat interactions with wind facilities are very different. Bat fatality rates are generally higher and more variable than bird fatality rates (AWWI 2021), and bat activity and behavior patterns in response to wind facilities suggest that at least some species of bats are attracted to wind turbines (Guest et al. 2022). No species appear to avoid areas with wind facilities, and in the northern hemisphere, peak wind mortality coincides with the fall migration and mating seasons of most species (AWWI 2021). The rotation of turbine blades poses the primary risk to bats, as evidence suggests bats (unlike birds) rarely collide with nonmoving blades or stationary turbine components (Horn et al. 2008, Cryan and Barclay 2014). Another important difference between bat and bird impacts is that bats breed very slowly; thus bat populations can be sent into decline more easily than most bird populations.
Several sets of best management practices or guidance documents now exist to inform wind energy development relative to wildlife impacts. What is still needed is guidance that is specific to Michigan’s unique geography and the distribution of wildlife in this state. Another need is a framework for prioritizing or combining various best management practices based on context-specific factors and impact potential. Finally, there is a need for Michigan-specific siting guidance that developers can use in the earliest phases of development, before significant resources have been invested in a given potential project area.
Our objectives in developing these BMPs for wind energy and Michigan wildlife are to:
These BMPs are intended to be used primarily by wind energy developers, operators, and their consultants to incorporate wildlife conservation values into projects. WLD recognizes that these audiences are attempting to optimize across many values, including energy generation and revenue, local community needs and interests, and other environmental considerations. Our goal in developing these BMPs is to provide information that will help developers prioritize voluntary measures to minimize adverse impacts to Michigan wildlife and provide a framework by which developers can highlight the beneficial practices they are voluntarily implementing. We also recognize that these BMPs will be used by many others with an interest in wind energy development or wildlife conservation, including wildlife advocates, local governments, and researchers.
All Michigan bat species are susceptible to injury and death associated with wind energy facilities. Estimated bat fatality rates at wind facilities in the Midwest are variable but high in comparison with other regions of the U.S. and Canada, ranging from 0.4 to 32 bats per megawatt annually (Arnett et al. 2008, Hein et al. 2013, AWWI 2018, AWWI 2020). The median bat fatality rate among studies contained in the American Wind Wildlife Information Center for the Midwest was 8.4 bats per MW per year (AWWI 2020a, as reported in AWWI 2021). Bats are relatively long-lived, with some individuals living 30 years or more in the wild, and they have extremely low reproductive rates (Barclay and Harder 2003, Brunet-Rossinni and Austad 2004). As such, high levels of adult mortality can have significant effects on the long-term sustainability of local populations (Schorcht et al. 2009). In this, bats are similar to much larger mammals that live relatively long lifespans and reproduce slowly, such as elephants and primates. Relatively small increases in adult mortality rates can cause population declines.
Although recent population declines in cave hibernating bats are primarily due to the fungal disease white-nose syndrome (WNS), wind related fatality has been reported for all five species of bats listed as state threatened or endangered in Michigan: Indiana bat (Myotis sodalis), northern long-eared bat (M. septentrionalis), tricolored bat (Perimyotis subflavus), little brown bat (M. lucifugus), and evening bat (Nycticeius humeralis). In addition to their state protected status, the Indiana bat and northern long-eared bat are also federally endangered, the tricolored bat is proposed for listing as federally endangered (as of December 2024), and the U.S. Fish and Wildlife Service (USFWS) is conducting a discretionary status review to determine if listing the little brown bat as endangered or threatened is warranted.
The USFWS species status assessment (SSA) reports for the northern long-eared bat (USFWS 2022; Docket FWS-R3-ES-2021-0140) and tricolored bat (USFWS 2021; Docket FWS-R5-ES-2021-0163) suggest that the impact of wind related mortality is discernible in the ongoing decline of both species. Based on data from Wiens et al. (2022) comparing a no wind energy baseline scenario to current and future wind energy development scenarios, projected abundance of northern long-eared bats decreases 24–33% by 2030 under the current scenario and up to 83% by 2060 under the future high impact scenario. In support of the SSAs for northern long-eared bat, tricolored bat, and little brown bat, Whitby et al. (2022) found declines in the predicted relative abundance of all three species with an increasing wind energy risk index.
Throughout most of Michigan and North America, the bat species most commonly killed by wind turbines are migratory “tree bats,” including hoary bats (Lasiurus cinereus), Eastern red bats (Lasiurus borealis), and silver-haired bats (Lasionycteris noctivagans). These species are not currently protected by state or federal endangered species laws, and there is no international treaty comparable to the Migratory Bird Treaty Act to protect migratory bats. The number of bats of these species being killed at wind facilities far exceeds any other documented natural or human-caused sources of mortality. Basic demographic information for these species is lacking, making it difficult to assess population-level impacts. However, recent studies suggest that the population viability of hoary bats may be threatened by wind turbine fatalities (Pylant et al. 2016, Frick et al. 2017), with recent models predicting that the species could decline by as much as 90% by 2062 (Frick et al. 2017) and at least 50% by 2028 (Friedenberg and Frick 2021) compared to a 2012 baseline if no action is taken to curb wind-related mortality. Based on the 2024 National Listing Workplan, the USFWS plans to conduct a discretionary status review to evaluate the need to list the hoary bat as federally threatened or endangered in fiscal year 2028. Voluntary guidelines such as these BMPs may be the best tool for conserving species like these that lack protection under state or federal endangered species laws.
In addition to the dynamic influence of WNS, species composition of bat fatalities at Michigan wind facilities may be influenced by the recent northward and/or eastward-westward range expansion of several species. Michigan is at the northern edge of the respective ranges of the Indiana bat, tricolored bat, and evening bat. The first Indiana bat maternity colony was reported in 1978, and the only known Michigan hibernaculum (Tippy Dam) was discovered in 1994. Maternity roost trees for Indiana bats in Michigan tend to have a larger degree of solar exposure than elsewhere in the species’ range, and the species seem to have a prolonged growth period in Michigan compared to more southerly locations, presumably due to the cooler climate (Kurta et al. 1993). Kurta et al. (1993) speculated that if Indiana bats roosted much farther north, they would not be able to compress a prolonged growth period and extended migration into the available warm weather months. However, with warming climates, the species may continue to shift northward and utilize new hibernacula.
The tricolored bat is speculated to be a relatively recent resident of the central Great Lakes Basin, most likely colonizing Michigan during the mid-twentieth century (Burt 1957, Kurta et al. 2007, Brown and Kurta 2013). The species was first observed in Michigan in 1965, and until the local invasion of WNS, it was regularly reported in or near Michigan hibernacula during the winter and fall migration period. The consistent presence of both males and females and the species’ typically short migration range suggests a breeding population may have occurred and may still occur year-round in parts of the state; however, with very few exceptions, the species has not been observed in Michigan in the summer and no maternity colonies have been documented. The tricolored bat has been uncommon since it was first detected in Michigan. Although WNS has reduced the range-wide Indiana bat population by 19% (USFWS 2019) and Michigan’s hibernating tricolored bat population has declined by nearly 94% (Kurta and Smith 2020), recent or ongoing range expansion may still be influencing the local distribution of both the tricolored bat and the Indiana bat.
Although not affected by WNS, the evening bat is historically rare in Michigan and is state listed as threatened. Prior to the discovery of a maternity colony in Lenawee County in 2004, representing the northernmost known colony in North America, there were only three records of evening bats in Michigan (Kurta et al. 2005). Although still rare in the state, climate change may be altering the species’ local phenology and distribution (Munzer 2008). Increasing observations in recent years suggest the species is becoming more common in Michigan or advancing its range northward (Auteri and Kurta 2015, Auteri and Mies 2016). Evening bats have now been detected in seven southern Michigan counties, with wind-related fatalities first reported at a Michigan wind facility in 2021 (Consumers Energy Company 2022, USFWS unpublished data).
The Seminole bat (Lasiurus seminolus) is another southern migratory species whose range has been shifting rapidly northward and westward in recent years (Wilhide et al. 1998; Lacki et al. 2014, Perry et al. 2018). Based on museum records and mist net data from 1970 through 2018, the northern edge of the species’ range advanced by 521 km, with a northward expansion rate of 11 km per year (Perry 2018). Like other tree bats, Seminole bats engage in widespread, long-distance migrations in the fall and remain largely active year-round, occasionally hibernating under leaf litter in colder temperatures (Hein et al. 2005). Although still most abundant in the southeastern United States, they have been reported in unexpected locations, including the Caribbean, Wisconsin, and New York (Perry et al. 2018). Previously undocumented in Michigan, multiple Seminole bats fatalities have been reported at Michigan wind facilities since 2013 (Consumers Energy Company 2022, USFWS unpublished data), suggesting that their migratory range now includes Michigan. According to Perry and Thill (2008), range expansion in Seminole bats seems to follow a pattern of increasing autumn (migration season) observations followed by maternity period observations (suggesting colonization). To date, reported Seminole bat fatalities in Michigan have occurred between late August and October (USFWS, unpublished data).
Wind energy collisions present a proportionally higher risk to longer lived bird species like eagles due to their low reproductive rates. Even low rates of collision can equate to dozens of birds killed each year. Placement of turbines is the best way to reduce collisions and should take into account local wildlife attractants like migration routes and food sources.
Eagles are not listed as a state threatened or endangered species, but they are tracked as a species of greatest conservation need and they have special values to Michigan citizens. People enjoy seeing these large birds in the wild, they are a national symbol, and they have special cultural values to several tribes in Michigan. Additionally, the federal Bald and Golden Eagle Protection Act prohibits anyone, without a permit issued by the Secretary of the Interior, from taking bald or golden eagles, including their parts (including feathers), nests, or eggs. The USFWS issues and maintains permits for eagle take and provides additional information on eagle take permitting, as well as eagle conservation, through the Eagle Management Program.
These BMPs are intended to exist alongside and independent Michigan’s wildlife regulations. Following the BMPs does not replace the need for renewable energy companies to consult with state and federal wildlife agencies to comply with state and federal endangered species laws and other wildlife laws, rules, and harvest regulations. These BMPs are intended to be used as voluntary practices to minimize risk and leverage benefits for a wide range of wildlife species, which may or may not be otherwise regulated.
Formal consultation on the impacts of wind energy facilities tends to focus on bats and eagles because state and federal laws regulate the take of eagles and endangered species. These voluntary best practices are much broader in that they consider impacts to wildlife species that have other values to Michigan’s citizens. For example, large blocks of public land, especially forested public land, are important stopover habitat for migrating neotropical songbirds. People value seeing and hearing those songbirds, and for birders, those species are a key part of a recreational activity that gives them a relationship with nature and natural places. Most of those neotropical migrating songbirds are not endangered. Even if facilities do not have an impact that would trigger federal regulations, the state has public trust responsibility for all wildlife within its borders, including neotropical migrating songbirds. Voluntary guidelines convey and make explicit the importance of wildlife conservation beyond the relatively small number of wildlife species that are regulated.
Not all best practices are equal, and many are context-specific. Some will have a broader impact on a wide array of species, benefitting many wildlife beyond regulated bats and eagles. These BMPs are for addressing impacts to all Michigan wildlife. We organize these BMPs in two tiers to communicate which are of the highest priority to Michigan’s wildlife. Our intent is to encourage a company to voluntarily follow all of the BMPs, and as many as practical of the “Additional Considerations,” to be able to say that they are following Voluntary BMPs for Wind Energy and Wildlife in Michigan.
The Michigan DNR and USFWS strongly encourage all wind energy operators in Michigan to implement voluntary measures to conserve bats, such as siting away from high-risk areas, such as bat hibernacula, feathering blades to slow rotation speeds when not generating electricity, and raising turbine cut-in speeds in areas, during times of year, and at temperatures and weather conditions with potential risk.
Wildlife consultation in particular is usually centered on state threatened and endangered species, but it can include other wildlife topics such as wildlife-friendly fencing, avoiding deer entrapment, and important local wildlife corridors. The state agency maintains a separate, longer list of endangered species and a separate permitting program from the USFWS. The state list is updated periodically. In 2023, the list was updated to include many new species, including the northern long-eared bat, tri-colored bat, and little brown bat.
There are usually two components to consultation: a desktop environmental review and permitting. The first component is requesting a review for recent records of state threatened or endangered species within the project area. The DNR program to do these reviews was defunded over a decade ago. These reviews can be requested of the Michigan Natural Features Inventory (MNFI) or consultants with access to the state’s Natural Heritage database that is maintained by MNFI.
The second component is determination if the proposed action risks take of a state threatened or endangered species, and if so, whether the proposed action can be modified to reduce the risk of take or if a state threatened or endangered species permit is necessary. The developer sends the desktop review of the natural heritage database to the DNR, and the DNR responds with a finding that there is or that there is not a risk to state threatened or endangered species. If avoidance is not possible, we recommend applying for a state threatened and endangered species permit. Because a small number of state threatened little brown bats have been taken at wind energy facilities across the state, we recommend all wind energy companies in the state operate under a state threatened and endangered species permit, which would define mitigation strategies such as cut-in speeds, allowable take, and reporting requirements. The risk that any one facility will take a state listed bat in a given year is low, but because there are many wind energy facilities, the risk that one of those facilities will experience take is high.
If a developer chooses to seek siting approval via the Michigan Public Service Commission, the MPSC application will require (among other things) proof of consultation with the Michigan DNR, including the review of the natural heritage database and the DNR determination of whether a permit was necessary.
While most state listed species are not federally listed, all federally listed species are also protected by state endangered species laws. Thus, we recommend as a best practice to consult with state wildlife agencies whenever consulting with the USFWS on issues related to take of threatened and endangered species.
In addition to formal threatened and endangered species consultation, the Michigan DNR is available to provide insight and informal advice on wildlife and wildlife-related concerns outside of the purview of state threatened and endangered species. Local communities are often concerned about impacts of development to common wildlife such as songbirds, waterfowl, or deer, and the DNR has expertise on the status and needs of these wildlife populations.
Identifying areas of risk and informing site selection and operation can be achieved through detailed pre-construction studies assessing local species composition and activity trends, as well as post-construction fatality monitoring. However, several broadscale landscape features are known to be generally predictive of bat (particularly Myotis and Perimyotis spp.) activity in Michigan, prior to collecting relevant site-specific data. Thus, evaluating and minimizing a proposed facility’s proximity to key landscape features is the recommended first step in reducing impacts to vulnerable bats.
Several studies (Kurta and Smith 2014, Heist et al. 2018, Kurta et al. 2018) have documented landscape features that pose greater risk to bats and birds. Particular geographies that pose higher risk are known from other studies and from post-construction monitoring at existing facilities. At the broadest scale, bats and birds are most common in and around forested landscapes in the northern part of the state, near Great Lakes shorelines, and near caves or cave-like structures. Areas with all three of these features, such as the Keweenaw Peninsula (and other peninsulas in Michigan Upper Peninsula) have especially high populations of bats and migratory birds.
In addition to siting wind turbines away from sensitive areas for bats, the only broadly proven and accepted method for reducing wind related bat fatality is to “feather” turbine blades (i.e., pitch turbine blades parallel with the prevailing wind direction to slow rotation speeds) during low wind speeds when bats are most at risk (Whitby et al. 2021). The wind speed at which turbine blades begin to generate electricity, known as the “cut-in speed,” can be set at the manufacturer’s recommended cut-in speed (typically between 3.0 and 4.0 m/s for contemporary turbines; Saint-Drenan et al. 2020) or at a higher threshold, typically referred to as operational curtailment. Even when turbine blades are not generating electricity, they continue to spin and pose a risk to wildlife unless they are feathered below the cut-in speed. The effectiveness of feathering below various cut-in speeds differs among sites and years (Arnett et al. 2013, Berthinussen et al. 2021); however, most studies have demonstrated all-bat fatality reductions of >50% associated with feathering below cut-in speeds raised 1.0–3.0 m/s above the manufacturer’s recommendation (Arnett et al. 2013, Adams et al. 2021, USFWS, unpublished data). A recent meta-analysis demonstrated that operational curtailment reduced fatalities, on average, by 33% (95% CI: 21%–43%) for each 1.0 m/s increase in cut-in speed (Whitby et al. 2021). Incorporating weather, time of day, and time of year into operational mitigation can protect bats while reducing energy losses and associated costs. For instance, Martin et al. (2017) found that raising cut-in speeds from 4.0 to 6.0 m/s whenever nightly wind speeds were <6.0 m/s and temperatures were >9.5 °C (49 °F) reduced fatality by 1.52–4.45 times and incorporating temperature decreased energy losses by 18%.
Wind energy did not cause them to become endangered, but cave-hibernating bats have recently experienced populations crashes that have caused their populations to decrease to the point that they will likely go extinct if other threats are not reduced. Wind energy is one of those threats. The little brown bat and tri-colored bat were added to the state threatened and endangered species list in 2023. The best practice is to use a combination of siting and feathering thresholds based on the relative risk of harming these species. Using a combination of bat survey data and known dispersal distances of different bats species, we mapped three levels of rare bat activity (Figure 1): high, medium, and low. High activity areas are areas within 10 miles of known hibernacula for state and threatened bats. Medium activity areas are high activity areas plus a 62-mile (100 km) buffer around hibernacula with historic maximum counts greater than 10,000 bats and an 55-mile (89 km) buffer around hibernacula with historic maximum counts of at least 1,000 bats. (The buffers were derived from little brown bat and northern long-eared bat migration distances and populations sizes used in the US Fish and Wildlife Service Species Status Assessments.) Best practices are to avoid siting wind energy facilities in high activity areas, i.e., within 10 miles of significant bat hibernacula (Figure 1). In medium activity areas (between 10 miles and 100 miles of major bat hibernacula), we recommend feathering turbine blades between 6.9 m/s and 5 m/s, depending on risk (e.g., nearer 6.9 in the 10 to 55 mile range and nearer 5 in the 55 to 100 mile range). Endangered little brown bats have been detected at low numbers statewide. Thus, the remainder of the state is a low bat activity area. We recommend feathering turbine blades below cut-in speeds of 5 m/s in areas with low activity (i.e., statewide, outside high or medium bat activity areas; Figure 1). The best times to implement feathering (e.g., “cut-in speeds”) are April 1 through October 31, when temperatures are above 50 °F, between sunset and sunrise.
An alternative BMP to seasonal cut-in speeds is Acoustic Based Informed Curtailments (ABIC; i.e., “smart curtailment”). We recommend that ABIC be implemented such that risk to bats is similar or lower than the seasonal cut-in speed BMPs (i.e., avoidance of risk in medium activity areas). ABIC is an experimental approach that is an alternative to blanket curtailment (Peterson et al. 2021, Rabie et al. 2022). Available technologies use acoustic activity (i.e., recorded bat echolocation calls) and/or other local variables (e.g., weather data) to minimize risk to bats while allowing more electricity generation when bats are not acoustically detected or unlikely to be present based on site-specific algorithms. We encourage wind energy operators to consider locally testing available technologies and/or implementing those demonstrated to be equally or more protective of bats than blanket curtailment. Smart curtailment is a rapidly developing conservation measure, and we recommend that those considering it consult the most recent peer reviewed literature or other guidance, such as recent avoidance guidance for tricolored bat.
Bat and bird density in Michigan is higher in areas where wildlife habitat management intentionally draws in large numbers of migrating and nesting birds, especially waterfowl. These areas represent some of the best waterfowl hunting and birding opportunities in the state and development nearby would likely trigger opposition from local and regional stakeholders. To minimize risks to wildlife from collision and from avoidance during nesting season, we recommend siting wind energy facilities 2 miles from parcels of state and federal land managed for large wetlands and waterfowl hunting (e.g., federal wildlife refuges and state managed waterfowl hunting areas). This recommendation is based on 1) local land manager knowledge of flight patterns of waterfowl near large wetlands and 2) concern that wind energy towers and turbines could change if and how waterfowl use large wetlands as critical stopover sites on migration or during breeding.
Great Lakes shorelines are used disproportionately by wildlife, especially migrating birds and bats. Because these species often roost near the lakeshore, the birds and bats fly at altitudes that match wind turbine rotor swept areas twice per day, as they take off in the morning and land in the evening. Radar studies have documented that this shoreline area of use extends as far as 12 miles inland, with areas nearer the lakeshore receiving even more intense use. For this reason, we recommend siting wind turbines at least 3 miles from Great Lakes shoreline, but we note that there are potentially benefits to siting even further from the shoreline, up to 12 miles.
We recommend that wind energy facilities not site individual turbines within 0.5 miles of known bald eagle nests to minimize the risk of bald eagle strikes from wind energy turbines.
As a best practice, we recommend that wind energy facilities avoid siting developments on or near important wildlife corridors that serve as concentrated movement corridors for wildlife that are impacted by wind energy (e.g., bats, eagles, and certain other species of birds). We also recommend avoiding siting wind energy facilities in large contiguous forested landscapes. These wildlife corridors and large, intact forests are relatively rare on the landscape, but they do sometimes coincide with geographies with high wind energy, such as peninsulas on the Great Lakes, shorelines, and forested ridges. The Keweenaw Peninsula is the definitive example: a peninsula with abundant shoreline and a prominent ridge that runs parallel to shoreline. It is used extensively by migrating birds, including eagles and hawks, and it has one of the highest concentrations of bat hibernacula in the state.
Corridors occur at two scales relevant to the siting of wind energy facilities. At the broad-scale, certain features tend to funnel birds and bats, especially while they are migrating through certain landscapes. At a finer scale, birds and bats will use hedgerows, less prominent ridges, and linear hydrology (rivers, streams, chains of wetlands) on daily movements between roosting and feeding areas. We recommend avoiding siting individual turbines in ways that fragment movement corridors. Several maps exist of wildlife corridors, including the Midwest Landscape Initiative Conservation Blueprint and The Nature Conservancy’s Connected and Resilient Lands map.
Bats and many rare birds are associated with large contiguous blocks of forest. Furthermore, many birds and bats focus their activity within non-forested openings within forested landscapes. For this reason, we recommend avoiding developing wind energy facilities within forested landscapes that have relatively low levels of fragmentation. That includes developments that break large, forested landscapes into smaller blocks and developments that are focused in open areas within forest landscapes.
We recommend siting in landscapes in which the matrix surrounding the facility (e.g., buffered by 5 miles) is less than 75% forested, and ideally no more than 50% forested.
Important Bird Areas (IBAs), state game areas, and national wildlife refuges are often protected and managed specifically for birds and bird conservation. These are areas of the landscape that likely have higher migratory bird (and bat) populations; thus, nearby wind developments pose a higher risk of harming or displacing wildlife. Like shoreline areas, these bird conservation areas often see increased bird use in morning and evenings during the migratory seasons. We recommend siting at least 1 mile from bird conservation areas.
Post-construction monitoring is important to document the wildlife impacts of specific projects. Often post-construction monitoring is a condition of state or federal permits. This section is intended to encourage post construction monitoring as a best practice even in conditions or for species where it is not explicitly required in a regulatory framework.
The number and species of wildlife that are affected by wind energy varies from site to site. Although we can assess risk based on geographic features, such as distance to hibernacula or distance from shoreline, individual sites can have higher or lower impacts than expected. Thus, it is important to conduct post-construction monitoring.
Specific methods vary by location and species of concern. However, we do recommend that post-construction monitoring:
Regional trend data is especially important for species such as hoary bat, which research suggests may face serious population level challenges from wind energy mortality (Frick et al. 2017, Friedenberg and Frick 2021). A range-wide effort to keep common species from ending up on the endangered species list is most likely to be effective and economical if all parties are engaged and sharing data (Conkling et al. 2020).
Certain human and natural features on the landscape attract wildlife. We recommend that turbine layout take into consideration higher wildlife use near (within ~200 m) of local attractants such as woodlots, wetlands, ponds, and commercial dairy/cattle operations. (Dairy/cattle operations attract scavengers, including eagles.)
Wires from the ground to meteorological (met) towers can harm birds. We recommend free-standing met towers rather than towers with guy wires to reduce this risk. If met towers cannot be free-standing, we recommend installing bird deterrents to guyed wires. Similarly, security lights that remain on all night attract insects, which can attract bats. We recommend using motion-sensor, down-shielded security lights to avoid attracting bats to an area. Finally, steady (not flashing) lights on towers can attract birds or disrupt their migratory patterns. We recommend using flashing tower lights.
Many efforts are underway to improve our understanding of bat interactions with wind turbines and explore additional strategies for reducing bat mortality at wind facilities. For example, acoustic-activated “smart” curtailment aims to focus operational curtailment when bat activity is detected in real time (e.g., Hayes et al. 2019, Berthinussen et al. 2021, Hein and Straw 2021). Additionally, researchers are exploring whether illuminating turbines with dim ultraviolet light may deter bats from approaching them (Cryan et al. 2016, Berthinussen et al. 2021, Hein and Straw 2021, Cryan et al. 2022). Further, researchers have tested applying a textured coating to the surface of the turbine to alter bats’ perception of the turbine (Bennett and Hale 2019, Berthinussen et al. 2021, Hein and Straw 2021). However, more research is needed to determine the broad efficacy of fatality reduction technologies beyond various operational (feathering) strategies. We recommend that facilities incorporate emerging deterrence technologies, and where possible, work with researchers to evaluate the effectiveness of such technologies.
There are several maps that can be used to inform wildlife risk in broad-scale project siting. We provide maps that outline high, medium, and low bat activity areas: high activity areas within 10 miles of major bat hibernacula; medium activity areas within 100 miles of major bat hibernacula; the entire state outside the high and medium bat activity areas as a low bat activity area. Zones are determined by surveys at bat hibernacula that detected state or federally threatened or endangered bats, as well as relative numbers of bat mortalities detected at existing wind energy facilities (Figure 1). Maps are up to date as of 2025.
Maps maintained by other entities may also be relevant to preliminary site assessments. For example, The Nature Conservancy has developed a Site Renewables Right tool that provides geographic information on risk to wildlife, communities, and ecosystem services. Similarly, the USFWS developed a Great Lakes Airspace Map Decision Support Tool, which maps concentrations of bird and bat use using radar and acoustic monitors. Audubon maintains a map of Important Bird Areas. We encourage developers to use these tools and others listed in the next section to support and supplement voluntary BMP considerations.
[Bat hibernacula zone map coming soon]
This set of BMPs was developed by DNR Wildlife Division staff, with input from the USFWS, over the course of four years (2022–2025). We also sought review of previous drafts from DNR staff in 2022. In 2023, we solicited review from external reviewers including public utilities, researchers, developers, wildlife organizations, other states, and American Clean Power. Several reviewers suggested substantive reorganization of the document, and the need for another round of review. During the time we were reorganizing this document, the regulatory environment underwent considerable changes. The state threatened and endangered species list was revised, and new laws were passed regarding siting of renewable energy and storage, which required further revisions. Two additional rounds of review occurred in 2025.
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Cryan, P.M., P.M. Gorresen, C.D. Hein, M.R. Schirmacher, R.H. Diehl, M.M. Huso, D.T. Hayman, P.D. Fricker, F.J. Bonaccorso, D.H. Johnson, and K. Heist. 2014. Behavior of bats at wind turbines. Proceedings of the National Academy of Sciences 111(42):15126–15131.
Cryan, P.M., P.M. Gorresen, D. Dalton, S. Wolf, and F. Bonaccorso. 2016. Ultraviolet illumination as a means of reducing bat activity at wind turbines. Presented at the Wind Wildlife Research Meeting XI in Broomfield, Colorado. 2 December 2016. Available at https://www.nationalwind.org/wp-content/uploads/2017/04/83_Cryan.pdf.
Cryan, P.M., P.M. Gorresen, B.R. Straw, S. Thao, and E. DeGeorge. 2022. Influencing activity of bats by dimly lighting wind turbine surfaces with ultraviolet light. Animals 12(1):9. https://doi.org/10.3390/ani12010009
Frick, W.F., E.F. Baerwald, J.F. Pollock, R.M.R. Barclay, J.A. Szymanski, T.J. Weller, A.L. Russell, S.C. Loeb, R.A. Medellín, and L.P. McGuire. 2017. Fatalities at wind turbines may threaten population viability of a migratory bat. Biological Conservation 209:172–177. https://doi.org/10.1016/j.biocon.2017.02.023
Friedenberg, N.A., and W.F. Frick. 2021. Assessing fatality minimization efforts for hoary bats amid continued wind energy development. Biological Conservation 262:109309. https://doi.org/10.1016/j.biocon.2021.109309
Guest, E.E., B.F. Stamps, N.D. Durish, A.M. Hale, C.D. Hein, B.P. Morton, S.P. Weaver, and S.R. Fritts. 2022. An updated review of hypotheses regarding bat attraction to wind turbines. Animals 12(3):343. https://doi.org/10.3390/ani12030343
Hayes, M.A., L.A. Hooton, K.L. Gilland, C. Grandgent, R.L. Smith, S.R. Lindsay, J.D. Collins, S.M. Schumacher, P.A. Rabie, J.C. Gruver, and J. Goodrich-Mahoney. 2019. A smart curtailment approach for reducing bat fatalities and curtailment time at wind energy facilities. Ecological Applications 29(1):e01881.
Hein, C.D., S.B. Castleberry, and K.V. Miller. 2005. Winter roost-site selection by Seminole bats in the lower coastal plain of South Carolina. Southeastern Naturalist 4:473–478.
Hein, C.D., J. Gruver, and E.B. Arnett. 2013. Relating pre-construction bat activity and post-construction bat fatality to predict risk at wind energy facilities: a synthesis. A report submitted to the National Renewable Energy Laboratory. Bat Conservation International, Austin, Texas.
Hein, C., and B. Straw. 2021. Proceedings from the State of the Science and Technology for Minimizing Impacts to Bats from Wind Energy. 80 pp. Available at https://tethys.pnnl.gov/publications/proceedings-state-science-technology-minimizing-impactsbats-wind-energy.
Heist, K.W., T.S. Bowden, J. Ferguson, N.A. Rathbun, E.C. Olson, D.C. Nolfi, R. Horton, J.C. Gosse, D.H. Johnson, and M.T. Wells. 2018. Radar quantifies migrant concentration and dawn reorientation at a Great Lakes shoreline. Movement Ecology 6:15. https://doi.org/10.1186/s40462-018-0135-3
Horn, J.W., E.B. Arnett, and T.H. Kunz. 2008. Behavioral responses of bats to operating wind turbines. Journal of Wildlife Management 72(1):123–132.
Hoving, C.L., Y.M. Lee, P.J. Badra, and B.J. Klatt. 2013. Changing climate, changing wildlife: a vulnerability assessment of 400 species of greatest conservation need and game species in Michigan. Wildlife Division Report 3564. Lansing, Michigan.
Kurta, A., D. King, J. Teramino, J. Stribley, and K. Williams. 1993. Summer roosts of the endangered Indiana bat (Myotis sodalis) on the northern edge of its range. American Midland Naturalist 129:132–138.
Kurta, A., R. Foster, E. Hough, and L. Winhold. 2005. The evening bat (Nycticeius humeralis) on the northern edge of its range—a maternity colony in Michigan. American Midland Naturalist 154:264–267.
Kurta, A., L. Winhold, J.O. Whitaker, and R. Foster. 2007. Range expansion and changing abundance of the eastern pipistrelle (Chiroptera: Vespertilionidae) in the central Great Lakes region. American Midland Naturalist 157:404–411.
Kurta, A., and S.M. Smith. 2014. Hibernating bats and abandoned mines in the Upper Peninsula of Michigan. Northeastern Naturalist 21:587–605.
Kurta, A., G.G. Auteri, J.E. Hofman, J.M. Mengelkoch, J.P. White, J.O. Whitaker, T. Cooley, and J. Melotti. 2018. Influence of a large lake on the winter range of a small mammal: Lake Michigan and the silver-haired bat (Lasionycteris noctivagans). Diversity 10(2):45. https://doi.org/10.3390/d10020024
Kurta, A., and S.M. Smith. 2020. Changes in population size and clustering behavior of hibernating bats in the Upper Peninsula of Michigan after arrival of white-nose syndrome. Northeastern Naturalist 27(4):763–772. https://doi.org/10.1656/045.027.0415
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Many Michigan wind developers may be familiar with the USFWS Voluntary Land-Based Wind Energy Guidelines (WEG; USFWS 2012). The WEG provide a structured, scientific process for addressing wildlife conservation concerns at all stages of land-based wind energy development. They also promote effective communication among wind energy developers and federal, state, tribal, and local conservation agencies. In addition, the WEG provide best management practices for site development, construction, retrofitting, repowering, and decommissioning.
The WEG emphasize the importance of consulting with the USFWS and state agencies early in the development of a wind energy project. Early consultation offers the greatest opportunity for avoiding areas where development is precluded or where wildlife impacts are likely to be high and difficult or costly to remedy or mitigate at a later stage. By consulting early, project developers can also incorporate appropriate wildlife conservation measures and monitoring into their decisions about project siting, design, and operation.
The WEG use a “tiered approach” for assessing potential adverse effects to species of concern and their habitats. The tiered approach is an iterative decision-making process for collecting information in increasing detail; quantifying the possible risks of proposed wind energy projects to species of concern and habitats; and evaluating those risks to make siting, construction, and operation decisions.
During the pre-construction tiers (Tiers 1, 2, and 3), developers work with the USFWS and state DNR to identify and avoid and minimize risks to species of concern. During post-construction tiers (Tiers 4 and 5), developers assess whether actions taken in earlier tiers to avoid and minimize impacts are successfully achieving the goals and, when necessary, taking additional steps to reduce impacts. Subsequent tiers refine and build upon issues raised and efforts undertaken in previous tiers. Each tier offers a set of questions to help the developer evaluate the potential risk associated with developing a project at the given location.
Adherence to the WEG is voluntary and does not relieve any individual, company, or agency of the responsibility to comply with laws and regulations. However, if a violation occurs the USFWS can consider a developer’s documented efforts to communicate with the Service and adhere to the WEG.
Similar to the WEG, the Association of Fish and Wildlife Agencies (AFWA) and the American Clean Power Association (ACP) have developed a set of voluntary communication guidelines to clarify expectations about when and how state agencies desire to be included in discussions about wind energy developments. Each state has different laws and regulations, but the framework outlines some common themes around relationship building, preliminary site evaluation, site characterization, field studies and impact prediction, post construction studies, and other post-construction studies and research. As discussed elsewhere in this document, the Michigan DNR encourages early consultation and joint meetings with the USFWS Michigan Ecological Services Field Office and Migratory Birds Program Office.
In 1984, Michigan received authorization from the federal government to administer Section 404 of the federal Clean Water Act (CWA) in most areas of the state. A state-administered 404 program must be consistent with the requirements of the federal CWA and associated regulations set forth in the Section 404(b)(1) guidelines. In other states, an applicant must apply to the U.S. Army Corps of Engineers (USACE) and a state agency for wetland, lakes, and streams permits; whereas applicants in Michigan generally submit only one wetland permit application to the Michigan Department of Environment, Great Lakes, and Energy (EGLE) and receive both federal and state authorization with a wetland permit.
Federal oversight of state-administered 404 programs is primarily the responsibility of the U.S. Environmental Protection Agency (USEPA). The department’s 1983 Memorandum of Agreement (as amended) with USEPA Region 5 outlines the procedures to be followed in program administration. This agreement waives federal review of the vast majority of applications in areas under Michigan’s 404 jurisdiction. However, federal agencies must review projects which impact critical environmental areas, or which involve major discharges. These projects are identified in the Memorandum of Agreement and include:
These above projects are called “Red Files” and require concurrent review by federal partners such as USACE and USFWS. Red Files may result in additional permit processing time depending on the complexity of the project. At the present time, USEPA reviews about one percent of all applications received. If EGLE determines that an application under Michigan’s 404 program is subject to federal review, copies of the public notice are sent to USEPA Region 5, Detroit District Corps, and USFWS. The USEPA is responsible for compiling all federal comments and submitting comments on the federal position to EGLE. These files do not require additional fees beyond those defined by EGLE. These types of projects do not include those also requiring authorization by the USACE under Section 10 of the CWA, which do contain additional fees and requirements as set forth by that agency. These projects utilize the same joint permit application but require separate review processes by the state and federal government, resulting in separate permit authorizations.
EGLE may not issue a permit which carries Section 404 authority if the USEPA objects to the project. This is true even if the applicant successfully appeals the state’s denial of a permit at the administrative level or through a state court. Section 404 provides for a reversion to USACE processing if a state and the USEPA reach an impasse on a project (that is, if the state is prepared to issue a permit, but USEPA continues to object).
Because of the high potential for federally protected birds and bats to be impacted by wind energy development, the USFWS and EGLE have an agreement that all wetland permits associated with a utility-scale wind development should be Red-Filed for federal review. However, the agencies have also developed a screening tool to exempt certain developments from Red-Filing on the basis of impacts to federally protected birds and bats if they can apply certain specified conservation measures as permit conditions. If EGLE staff determine that a proposed wind development project does not need to be Red-Filed for federally protected bats and birds, they follow additional normal screening processes for all other species.
If an applicant does not agree to the specified permit conditions for birds and bats, the USFWS will review the permit application under the Red File review process and provide project specific recommendations to USEPA. In some cases, the USFWS may provide a wind developer a letter prior to a wetland permit application submission documenting that the proposed development has adequately addressed the potential for adverse effects to federally protected birds and bats using alternative site-specific measures for incorporation as permit conditions. In such cases, the letter will clearly indicate that the coordination with USFWS is complete, and the application does not need to be Red Filed provided the permit conditions are incorporated into any EGLE permit.
Per Section 10 of the ESA, incidental take permits (ITPs) may be sought whenever a non-federal entity believes their otherwise lawful activities are likely to result in take of federally threatened or endangered wildlife. A habitat conservation plan (HCP) must accompany an application for an ITP. HCPs describe the anticipated effects of the proposed taking; how those impacts will be minimized and/or mitigated; and how the HCP is to be funded. HCPs can apply to both listed and non-listed species, including those that are candidates or have been proposed for listing. Conserving species before they are in danger of extinction or are likely to become so can also provide early benefits and prevent the need for listing.
Early and frequent coordination with the USFWS can help determine whether a proposed wind development is likely to result in incidental take of listed species and whether an HCP is needed. Wind developers seeking an ITP are encouraged to work closely with the USFWS during the development of an HCP to ensure conservation measures are sufficient to avoid jeopardizing the survival or recovery of listed species and that impacts of the proposed taking are minimized and mitigated to the maximum extent practicable.
While wind developments in Michigan typically do not include a federal nexus, proposed developments initiated, authorized, or funded by a federal agency must evaluate potential effects and/or receive incidental take authorization for listed species through Section 7 of the ESA.
In addition to ITPs for ESA-listed species, eagle take permits (ETPs) are available to individuals, agencies, businesses, and other organizations under the Bald and Golden Eagle Protection Act (BGEPA) when take of eagles may result from, but is not the purpose of, an otherwise lawful activity. Incidental take includes disturbing eagles as well as killing and injuring them. ETPs do not authorize possession of any eagle, eagle parts, or eagle nests.
The USFWS’s Eagle Conservation Plan Guidance (ECPG) provides specific in-depth guidance for conserving bald and golden eagles during siting, construction, and operation of wind energy facilities, and supplements the WEG. Like the WEG, the ECPG calls for wind project developers to take a staged approach to siting new projects. Both guidance documents call for preliminary landscape-level assessments to assess potential wildlife interactions and proceed to site-specific surveys and risk assessments prior to construction. They also call for monitoring project operations and reporting eagle fatalities to the USFWS and state and tribal wildlife agencies.
Compliance with the ECPG is voluntary, but the guidance is intended to help project operators in complying with regulatory requirements and avoiding unintentional take of eagles at wind energy facilities, while assisting the wind energy industry in providing the biological data necessary to support permit applications for facilities that may pose a risk to eagles.
The Midwest Conservation Blueprint is a map of priority land and waters for conservation. It was developed by the Midwest Landscape Initiative, a collaborative of fish and wildlife organizations, including the Michigan Department of Natural Resources. The tool reflects over 20 social and environmental values, which can be mapped separately or in aggregate.
Formerly called Site Wind Right, this online mapping tool synthesizes over 100 geographic datasets and displays them as over a dozen map layers of key conservation and wildlife habitat features on the landscape, such as important bird areas or important habitats for big game. The geographic area mapped was expanded to include the upper Great Lakes states, including Michigan, in 2022.
A USFWS mapping tool that allows users to overlay bird and bat activity maps over other publicly available maps. Activity maps for birds and bats were derived from radar and bat acoustic data collected from many sites across the Great Lakes Basin in spring and fall from 2011 through 2018.
A comprehensive guide to the wind energy and wildlife issues. It includes sections on statutory and regulatory frameworks, the state of the science on wind–wildlife interactions, and strategies to avoid, minimize, and compensate for negative impacts to wildlife and their habitats.
