The height as measured from water's surface to the tip of the blade at its tallest point is 951 ft. However, the mast is extends below the water's surface all the way to the sea bed (another 75 to 100 feet in our region) and also extends beyond that to well below the sea floor. Each mast requires roughly 2,400 tons of refined steel to make, and is 11 meters wide at the base. Steel refinement requires the burning of fossil fuels and greenhouse gas emissions. The wind turbine power plants slated to be built up and down the Atlantic Outer Continental shelf each will contain hundreds of such gargantuan turbines.
There is currently no solution for energy storage that can accommodate all the power that is expected to be produced by the power plants of the planned U.S. Offshore Wind Program. This means much of it will not be able to be stored and will be wasted if it is not used timely. Although extremely large battery storage systems are in development, as are other experimental forms of energy storage, and even though there has been much planning to change the energy grid to accommodate them, no such systems exist today. However, it is conceivable that extremely large battery systems may become available, installed, and utilized by the time the U.S. Offshore Wind Program gains traction. However, these extremely large battery storage systems come with their own very large carbon footprint. If the power produced by wind turbine power plants cannot be stored, fossil fuels will need to be burned to meet peak electricity demand. Unfortunately, the carbon footprint of such large battery systems (which are required to utilize wind-derived power to avoid burning fossil fuels to meet peak electricity demand) have been ignored in almost all carbon footprint analyses of wind power projects and programs.
One mast weighs as much as 1,684 Mazda CX-3 SUVs.
Wind Power Plants being planned for the U.S. Offshore Wind Program typically have 160 or more turbines. Just one U.S. Offshore Wind Power Plant alone will require (in its masts alone) steel refinement in a quantity roughly equivalent to that required to make 269,440 Mazda CX-3 SUVs. For the U.S. program, five million acres of offshore area is being put under consideration for such power plants with turbines between 0.7 and 1.7 nautical miles apart
CLIMATE CHANGE IS SERIOUS GLOBAL ISSUE, A PROPER ACCOUNTING IS NEEDED
It is disingenuous to look at the carbon footprint of one energy source, offshore wind, for only a part of its lifecycle (construction, operation, and decommissioning) and compare it to the carbon footprint of other energy sources for the entirety of their lifecycles (resource extraction, mining, steel refinement and other materials formation, trans-oceanic transportation, assembly, construction, operation, and decommissioning). If we are serious about fighting climate change, the consequences in terms of carbon emissions of our energy policy decisions (nationwide and regional programs) as well as individual decisions to approve and permit power plants, must be counted and evaluated in a standardized way and must be transparent.
Sea Life Conservation has requested The Bureau of Ocean Energy Management account for all Carbon Emissions of each of the projects the agency is tasked with approving or denying. The agency responded, in essence, that it is the EPA's responsibility to tally this; Impliedly Carbon Emission contribution to air quality for only a 25-mile radius from the project site and staging sites (as is required by the Clean Air Act) is required to be performed but emissions during materials sourcing, refinement, assembly, or trans-oceanic transport need not be counted, according to the agency response.
Graph Data Source: IPCC Report 2014
Median "Lifecycle" CO2 emissions for wind power. Figures shown in graph for renewable energy (Solar=yellow and Wind=lightpink) do not include C02 emissions required for mining and manufacture of consumable large-scale battery systems that would need to be installed to the energy grid, in order for renewable energy sources to become independent of fossil-fuel burning to satisfy peak demand. Shown are median values. Actual CO2 emissions of any given power plant depends on its characteristics and the quality of the source of energy it uses.
HARM TO LAND FROM MINING
In addition to iron-ore required for steel refinement for the mast and nacelle of the turbines in a wind turbine power plant, a giant magnet made out of a rare earth mineral called neodymium is required to be placed in the machinery within each of the nacelles in order for the turbines to function. The mining of iron-ore and the mining of the rare earth mineral neodymium produce serious adverse environmental impacts on land, degrading the land so severely that it can no longer serve as wildlife habitat. The difference between mining to build and operate a wind-turbine power plant and mining to build and operate other types of power plants is that wind turbine power plants require so much more material, and thus more mining. This is true even compared with power plants whose fuel needs to be mined. More surface mining means more habitat destruction and more environmental contamination. Take a deeper dive in this article by the Yale School of the Environment. Mines cause soil and water contamination, including of streams and wetlands. Beyond the mines themselves, infrastructure built to support the mines, such as roads, ports, rails, and power lines, all require clear cutting or habitat destruction, and also cause habitat fragmentation. Nearly all infrastructure requires mining, but the more materials a particular type of power plant requires for its construction, the more mining is needed as well. Habitat fragmentation makes populations of wildlife more susceptible to high rates of localized extinction events (called "extirpation") even in the undisturbed portions (or fragments) of habitat. Animals can have lower survival when crossing between fragments, or possess behavioral adaptations that prevent them from crossing. Localized extinction can result because remaining fragments of unspoiled land which have sufficient populations do not result in re-migration to (and thus repopulation of) those fragments in which the local population has died out. Eventually, large tracts of land comprised of fragments can become devoid of animals and localized extinction can occur over larger areas. This results in overall declines in wildlife populations. In a mere four decades, there has been a staggering 70% decrease in the population abundance of over 20,000 species of animals and plants tracked. The second biggest cause of severely declining wildlife population is habitat destruction and fragmentation, (second only to direct over-use for commodity). Four to seven tons of earth need to be processed per one ton of primary ore that is procured. For some of the rarer earth metals that wind power plants require, acquiring just one ton of this rare metal can require the movement and grinding of hundreds of tons of earth.
MARINE MAMMALS
Construction of wind turbine power plants in the ocean requires pile driving which severely harms marine mammals such as whales, seals, and dolphins if they are within a certain range. The Natural Resource Defense Council and other organizations recommend to stop work when a marine mammal is detected within 500 meters of the vessel about to conduct an activity known to injure or harrass them, and recommend a bigger, 1000-meter, clearance zone in which no critically endangered species of whale are detected before beginning or continuing work. The recommendation was signed by Francine Kershaw, Ph.D. Senior Scientist at the Natural Resources Defense Council; Erica Fuller of the Conservation Law Foundation; CT Harry of the Environmental Investigation Agency; James Murphy of the National Wildlife Federation; and Michael Stocker Founding Director of Ocean Conservation Research. The sound of pile driving, or the hammering into the sea bed of the large masts, is known to cause injury to large whales and other sea mammals. A look at the construction and operations plan and applications by wind power plant developers show developers are planning to rely only on human observers on the ships near where the construction noise will be cast, even though the probability that a marine mammal would be visually detected if it was actually present can be as low as 1 in 100. Visual detection alone is extremely unreliable, even under conditions of good visibility, and is for all purposes useless under poor-visibility conditions such as fog or mist. The U.S. federal agency BOEM (Bureau of Ocean Energy Management) has thusfar flatly refused to require the use of underwater microphones ("passive acoustic monitoring") to listen for endangered whales in the vicinity when construction activities are about to begin, or impose any other sensible condition for the agency's approval of the developer's harm-causing construction activities.
BOEM (the Bureau of Ocean Energy Management) has also sorely failed to issue regulation that could protect marine mammals during both sea floor exploration and operation. BOEM has approved for offshore wind development ocean lease location areas that are essential migratory corridors for an endangered whale species to reach its birthing and nursing grounds. BOEM has sold ocean leases for power plant development and given approval for ocean power plants to be constructed in areas where such power plants would interfere with feeding by a species of large filter-feeding endangered whales by mixing the ocean strata layers that otherwise would permit the known prey of the endangered whale species NARW (or North Atlantic Right Whale) to occur in sufficient densities for the whales to be able to begin filter-feeding, according to scientists at the National Marine Fisheries Service, a subsidiary of the Department of Commerce. Filter-feeding whales have long bristles, like broom bristles, instead of teeth. Filter-feeding whales only engage in filter-feeding (taking large gulps, then filtering most of the water out) when prey are of a sufficient density to make it energetically worthwhile to execute the gulp-and-sieve motions. Ocean currents, as they pass the masts of offshore wind turbines in a power plant, become turbulent. This mixes different layers of ocean and dilutes the prey on which the whales feed, by scattering the prey, which normally only exist in a certain stratum.
North Atlantic Right Whale. There are only 340 individuals left.
HARM TO FISH POPULATIONS
BOEM (the Bureau of Ocean Energy Management) has also approved construction during cod spawning season during which it has been determined by experts that construction of the South Fork Wind Power Plant will seriously impair cod reproduction, risking substantial reduction in the number of cod, an important food resource. Bloomberg News broke the story (SEE: Story) that the agency BOEM (the federal agency responsible for determining the environmental impact of proposed ocean wind power plant projects), in its unconditional approval of construction of the 132-MW South Fork wind turbine power plant is ignoring the findings of the government's own scientists that say the population of Atlantic Cod is likely to suffer substantial impacts from the wind power plant. Essentially BOEM declined to regulate pile driving (pounding of the turbine masts into the sea floor) where and during the months when cod are known to spawn. BOEM's explaination that cod will not be harmed because the cod spawn in the early evening but the pile driving would occur during the day suffers from a glaringly obvious flaw - one the government scientists pointed out - that animals are not likely to perceive an area safe for reproduction (or for any use) in an area where only a little earlier, deafeningly-loud sonic blasts occurred repeatedly.
Photo: Atlantic Cod
WIND POWER DEVELOPMENT REQUIRES MAPPING LARGE AREAS OF OCEAN FLOOR WHICH CAN BE HARMFUL
Use of sound-blasting equiment mounted to the underside of boats, mounted to roving underwater vehicles, or to submerged buoys tethered to the sea floor are used for "site-characterization" or recording the detailed contours and sediment density of the sea floor over wide areas into which construction-developers consider installing turbine masts into. Experiments using sounds that are similar to those used in the surveys were shown to have harmful effects on many, many different types of marine life. Take a deeper dive.
Ocean water in most places is full of tiny animals, phytoplankton, and minerals. For this reason, except for extremely short distances (a few meters to a few tens of meters), vision is very unreliable. So, many different types of marine animals normally use sound (not light) to form an image of their surroundings. Sound or vibration is essential for most marine animals' very ability to perceive what is around them. The intensity, or loudness, of sound underwater dissipates far less over a distance underwater than sound in air would over that same distance. This means that a sound stays loud much further away from the sound source than it would if it were being transmitted through air. Try holding your breath underwater in a large swimming pool and have a friend knock two small rocks together on the other side of the pool. Can you hear it? Do you think you would be able to hear it if the sound were transmitted through air instead of water? Try it in air too.The surface of the water, which is the boundary between the water and the air, reflects sound. So sounds can bounce off the water's surface. Sound travels about four times faster underwater than through air.
Paths followed by sound waves as they travel away from the sound source at a constant sound speed. Very little sound travels from water through the surface to air.
Graph Courtesy of: D.O.S.I.T.S. (Discovery Of Sound In The Sea). Take a deeper dive.
Notice that sounds reflect off the underside of the water at different angles. 1 kilometer (1 km) is equal to 3,281 feet. The intensity, or loudness, of sound decreases with distance. However, it does not decrease by as much in water compared to over air.
Wind turbines produce sound and vibration for their 30 year operation. The sound wind turbines emit underwater is transmitted from the machinery inside the "gear box" down the mast and into the water. Although wind turbines are spaced pretty far apart, they are still so close together that the sound emitted from one wind turbine overlaps with the sound emitted by the most nearby turbines in the same power plant. This means animals travelling through the power plant (or animals whose habitat the power plant was built upon) who can hear at great distances cannot escape the sound of turbine operations anywhere within the wind-turbine power plant. These power plants can be 80,000 acres or more in size and comprise a "sound field" that covers and extends beyond the physical footprint of the power plant.
TROPHIC FOOTPRINT OF WIND POWER PRODUCTION - IMPAIRING NATURE'S OWN CARBON CAPTURE
The surface area of offshore wind-turbine power plant infrastructure planned for the U.S. Atlantic Ocean presents an enormous increase in widespread availability of new metal and concrete surface area on which sessile invertebrates (filter-feeding attached squishy animals, a subset of which have shells) will grow. This inevitable population explosion of filter-feeding attached animals as well as ocean shading from the weather changes (clouding) brought on by the
Photo: Abundance of heterotrophic filter-feeding attachable animals will skyrocket upon industrialization of the Atlantic, and affect phytoplankton balance
massive structures drawing air moisture, and directly by the structures themselves is expected to reduce the amount of phytoplankton in the waters over the outer-continental shelf. Phytoplankton pull dissolved carbon out of ocean water in order to proliferate, or make more of themselves. The collective action of a myriad of tiny photosynthetic planktonic organisms removes unfathomable quantities of carbon out of the ocean, which allows the ocean, in turn, to absorb more Carbon Dioxide from the atmosphere, mitigating global warming. Take a deeper dive.
The strong potential for ocean wind power plants to produce these adverse effects to our oceans are receiving little attention. The stated purpose of each wind-turbine power plant project is now to help achieve the policy goal benchmarks that have been set (for what quantity of power derived from renewable energy will be acheived by a certain date) rather than reduction of greenhouse gas ('GHG') emissions. This regulatory 'decoupling' of actual project GHG emissions and environmental benefit from whether a project receives approval gives industry carte blanche for unlimited mining, pollution, and burning of fossil fuels to acquire and refine the necessary materials and then build and transport materials and parts the massive infrastructure of each project requires. Relieving commercial energy developer applicants from having to show reasonable estimates of greenhouse gas emissions except for within only a 25-mile radius from the construction site means only a small fraction of the environmental impacts of such projects ever is brought up for review by agency officials or for transparency to the public. Suggestions for mitigation of the extent of environmental harms by modified project plans have been dismissed out-of-hand as "not satisfy[ing] the project purpose" which under new U.S. regulation isn't reduction in greenhouse gas emissions, and isn't net benefit to the environment, but rather is to the aid in the achievement of benchmarks set for power production derived from renewable sources. Ignoring the trophic footprint effects of wind turbine power plants, ignoring the habitat devastation caused by mining, and decoupling wind project approval from any requirement that the project actually substantially reduce greenhouse gas emission quantities relative to the existing weighted mix of sources from which the power is today derived (nuclear, coal, and natural gas) means approval of such projects can neither be assumed to be per se good for the environment nor necessarily helpful in averting climate change.
read more.
Given the scope, scale, and rapidity of planned U.S. Offshore Wind Development, we urgently need better baseline data than has already been supplied for aves, sea mammals, and fisheries, as well as studies of major ecosystem dependencies in the U.S. Atlantic, prior to installation and operation of the first two large-scale power plants. Without robust baseline data and a monitoring plan to collect information to be compared to baseline, an understanding of what are the adverse environmental effects of the first two large-scale power plants may never become known or only after adverse effects have already become irreversibly manifest. The issuance of numerous, large, ocean area leases for wind power plant development have proliferated in the last two years, and are rising still. Under this new, sharply accelerated, rate of ocean leasing, even if federal agency BOEM requires robust pre-installation baseline data for the first two power plants and a monitoring plan as a contingency for their approval, it will not be possible for agency BOEM to adequately understand the effects of installation and operation of these two plants before the authorizing of additional ones: Due to the accelerated schedules, BOEM will be deciding whether to authorize subsequent power plants in the areas recently leased before the known effects of these experimental first two large-scale large-turbine plant are even discovered. Ocean wind power in the U.S. Atlantic differs from existing, installed wind power plants in the North Sea in Europe which countries collectively have only 700 much-smaller turbines spread over the waters of several nations, each of which, in most cases, have been very carefully sited, before being built, to avoid bird migration and other conflicts.
European North Sea existing turbines are installed in quite shallow water where, unlike the Atlantic Ocean, there are no discrete (temperature, salinity) strata to mix. Stratified ocean layers support phytoplankton biodiversity and also enable "blooms" or areas where phytoplankton proliferate quickly, and consequently enable their predators (also tiny creatures) called zooplankton and their predators to proliferate quickly to form areas of high density that large filter-feeding animals can use for energy. Turbulent mixing of the sea strata caused by water wakes forming around mast obstacles of wind farms make former sea strata more uniform in temperature or salinity, and blur or even eliminate the boundries between strata. Turbines, based on current research, are expected to disrupt and lessen the frequency of these naturally-ocurring chains of events that require ocean layers for their occurrence, because the masts mix ocean layers.
Cartoon of Copepod courtesy of Lalite Sitta
TURBINE-CLOUDING ALTERS PHOTOSYNTHETIC CAPACITY OF THE OCEAN OVER THE OUTER CONTINENTAL SHELF
In contrast to the few thousand acres of (collectively) hundreds of turbines in Europe's North Sea, on the U.S. Atlantic, the United States seeks to use over three million acres for many thousands of turbines. More than half the turbines being of such immense size that it is proper to classify them as experimental. The the first sample of only two GE HaliadeX are only just now are debuting in Scotland, and other than that, turbines of this size currently exist installed only in a power plant in China. Such widespread development on the U.S. Atlantic with the immense turbine sizes planned is expected to affect the weather.
Turbines create water vapor condensation in conditions under which it would not naturally be produced [take a deeper dive: cloud trails], which condensation shades the ocean a larger proportion of the time (when such conditions exist), and alters photosynthesis rates, thus altering the natural processes of phytoplankton proliferation in our ocean over the outer continental shelf. As phytoplankton both represents the base of the entire ocean food web and also the single biggest means of directly removing dissolved carbon from the ocean, this is a large concern.
weather affected by Horns Rev wind farm, Denmark
Offshore wind farms also alter ocean currents and the turbulence of water interacting with the masts kicks up a large amount of sediment, which presents challenges for many different kinds of filter-feeding organisms. To partially reduce the amount of sediment kicked up, large concrete scour pads are proposed to be constructed at the base of each turbine, for many of the power plants whose masts will be hammered into the sea bed. This will irrevocably and permanently modify the benthic (ocean floor) habitat within the power plant, now that complete decommissioning is no longer being proposed, but instead decomissioning only "to the extent practicable" is now being proposed in U.S. Offshore Wind COPS (Construction and Operations Plans). This means that the seabed will have been permanently modified after decommissioning of the power plant.
The train was carrying vinyl chloride, a chemical used to make a hard plastic called PVC commonly used to make plumbing pipes and structural elements inside furniture. Vinyl Chloride remains a gas even under winter temperatures, but it is put under high pressure to make it a liquid for transport. When the container is breeched, the gas spreads out along the ground because it is heavier than air. Contact with the chemical causes liver cancer, it was learned by studying workers who make pvc pipes. When ignited, it combusts into hydrogen chloride, carbon monoxide, and phosgene. Phosgene is a highly toxic gas with a strong odor that can cause vomiting and breathing trouble and was used as a weapon in World War I. Phosgene is not safe unless it is below infinitesimally small level of one part in ten million, for an eight hour exposure. James R. Justice of the Health and Ecological Criteria Division, Ecological Risk Assessment Branch of the EPA stated that readings from monitoring stations inside and outside of the evacuation zone show there is nothing to be concerned about. However, the stations may have been set up after the poison gas had already dissipated from higher levels to which the residents were likely exposed. “Vinyl chloride has a short half-life,” said chemist Matt Hartings of American University in Washington, D.C. “After a day and a half, it’s likely gone from the air anyway. I’m not surprised they’re not finding it now.” Air monitoring after-the-fact doesn’t answer questions about whether there were high levels of exposure that first night and next day following the derailment, Hartings indicated. On the first night, temperatures in the teens and very low winds would have kept airborne contaminants close to the ground all over the town, he said. Other chemicals the train cars were carrying were: ethylhexyl acrylate, which causes cancer when swallowed and is toxic to aquatic life, with long lasting effects, and butyl acrylate, which is an eye, nose, and throat irritant, and can causes coma or death at high levels of exposure. Some residents who were initially evacuated, but have been permitted to return to their homes have complained of headaches and feeling sick since returning, many are out of work, and are experiencing chest pain, coughing, burning feeling in airways, phlegm, tightness in the chest, burning feeling in the eyes, sore throat, rashes, nausea, headaches. Many are being diagnosed with chemically-induced bronchitis according to one local business who has seen half its workforce out sick. and residents report sickness among pets and sickness and death in other animals. Found dead in the creeks were: american bullfrog, green frog, american water frog, two-lined salamanders, northern dusky salamanders, rock crayfish, allegheny crayfish, and many species of fish including greenside darters, faintail darters, rainbow darters, sucker fish, central stone rollers, sunfish, mottled sculpin, true minnows, bluntnose minnows, common shiner, rosy-faced shiner, creek chub, carp, loaches, and western blacknose dace. Dead minnows alone number in the 38,000-43,000 range.
The soil is also contaminated. Norfolk Southern rail company began removing contaminated soil from the crash site in mid-February 2023 under EPA supervision. As of March 1st, 4,850 cubic yards have been removed. This is about how much could be carried by 350 dump trucks.
In March 2011, a massive earthquake and tsunami damaged all of the Fukushima daiichi power plant’s cooling backup systems, causing meltdown of three reactors and the release of a large amount of radiation due to a rapid release of steam from depressurization, which steam expanded outward, carrying nuclear material with it. This accident was caused by the Tohoku earthquake and tsunami - the most powerful earthquake ever recorded in Japan’s history. Though 40 to 50 people were injured onsite, some from impact (indeed, wall panels and a roof blew off), and some from radiation burns, none died. No one died in the short term as a direct result of radiation or from any other direct cause related to the disaster. However, seven years later, a person in charge of measuring radiation levels who had to frequent the disaster site to take the measurements, died of lung cancer (likely from cumulative radiation exposure). It is estimated that up to 1,400 people experienced problems evacuating that contributed to their deaths. Roughly 600 others died as in indirect result of the disaster from such causes as stress-induced heart attacks, traffic accidents, and interruption of ordinary medical care. Most of those who died from interruption of medical care were the elderly or the ill. Except for areas very close to the plant, radiation levels were not high enough to cause health effects. The areas close to the plant were evacuated. More people were harmed in the evacuation than was expected because even though only 40,000 people were in the evacuation zone, an additional 120,000 people in surrounding areas of measurably safe radiation levels also elected to evacuate themselves, but there were not support systems for temporary housing for so many people. Although every one of the 1,400 deaths caused by the evacuation were tragic, the natural disaster that caused the incident took far more lives: over 15,000 lives were lost to the Tsunami. Afterward, ocean water near the plant was discovered to have been contaminated with high levels of iodine-131, which resulted from leakage of radioactive water through cracks in trenches and tunnels between the plant and the ocean. This likely harmed some ocean life. These cracks were repaired within a few weeks.
Fast forward to 2023, the most harmful and heavier radionuclides have now been removed from the water that came in contact with the reactor. Tritium, a less radioactive molecule, which is difficult to remove owing to its ability to form a molecule that closely resembles water, is left behind in the wastewater. After now having been treated at its current location to below releasable levels, the water, which had been in contact with the damaged reactors, will be sent through a pipeline that leads from the tanks to a coastal site, where the water will be machine-diluted by adding seawater. From there, the water will enter an undersea tunnel built specifically to discharged it from a point only roughly 1 kilometre (0.6 miles) from the coast. The tritiated water will be diluted to 1500 becquerels per liter, which is 1/ 40th of the concentration considered safe under Japanese safety standards and which is less than one seventh of the concentration that World Health Organization's (WHO's) guidelines consider safe for drinking water.
The radiation dose from drinking one quart of this diluted water is equivalent to that obtained by eating four bananas, according to James Conca, a scientist in the field of the earth and environmental sciences for 33 years, specializing in geologic disposal of nuclear waste, energy-related research, radiobiology and shielding, subsurface transport and environmental clean-up of heavy metals. James Conca is a Trustee of the Herbert M. Parker Foundation, Adjunct Professor at Washington State University, an Affiliate Scientist at LANL and consult on strategic planning for the Environmental Protection Agency and state environmental agencies, as well as a 25-year member of the NRDC, Sierra Club, the Environmental Defense Fund, and other environmental organizations.
It is physically impossible for an accident like that of Fukushima Dai-ichi to ever happen again for nuclear plants with advanced design modern nuclear reactors because these new types are not operated under high pressure (so there is no highly-pressurized container to "blow") and secondly, the safety system which renders continuance of the nuclear reaction impossible is self-correcting and emerges from the very nature of its physical characteristics. That is, it is not contingent upon any act by a human, by A.I., or by a computer; is not dependent upon the proper functioning of any mechanical system; and does not require the availability of electricity. The name for this type of self-correcting physical system is known as 'passive safety'. In these passively safe molten salt reactors, the hotter the reaction gets, the more it slows down, which makes the temperature and reaction self-correcting. So it is impossible for a reaction in such a reactor to go out of control. Also, it is designed with a solid salt plug at the reactor drain whose natural melting point would turn it to liquid if it heated above a certain level, which would cause the nuclear material (a liquid) to drain an underground tank where it is impossible for the reaction to continue because the tank has no moderator which is needed to keep a reaction going.
Decommissioning of any nuclear reactor requires great care. Sea Life Conservation has begun to monitor the decommissioning of Indian Point Nuclear Power Plant in Buchanan, New York. This power plant is located on the Hudson River in New York, about 40 miles north of New York City. The Hudson River is 315 miles long and runs north-south through New York, opening out into the ocean at New York City's harbors. The Hudson River holds perhaps the largest contemporary populations of Atlantic Sturgeon, a species at risk from historical over-fishing which has been severely depleted and has not recovered even to a modest fraction of its former population.
Sturgeon, Image by: Максим Яковлєв
In addition to the (prehistoric-looking) Sturgeon, the Hudson River is habitat for a variety of important coastal wildlife and aquatic animals, including Shad and Menhaden (Menhaden are also known as "bunker"). These two fishes are keystone prey for many larger species of fish in the Hudson and Atlantic Ocean and for sea mammals such as whales and seals. Increasingly cleaner and cleaner ocean waters off the coast of New York and New Jersey between 1980 and 2000 was the result of much hard work and political will. A 1977 amendment to the Ocean Dumping Act mandated the cessation, after 1981, of ocean dumping of sewage that unreasonably degrades the marine environment. This was followed by bipartisan effort to improve monitoring of the ocean waters which had suffered from dumping of chemical and medical waste, and sewage for many years prior, as was documented in this Congressional Hearing, in which a New Jersey organization, Clean Ocean Action, testified. In recent decades the reaped benefit has been clean water and the booming health of menhaden populations including in the Hudson, which has brought whales to New York Harbor, in view of the New York City skyline.
Whales are in New York City: An organization in New York City ("gotham" city), named Gotham Whale, serves as a conduit of information between ordinary citizens on NYC tour boats who make whale sightings and naturalists who document and share sighting and visual tracking data with scientists.
New York's Scenic Hudson River, home to menhaden and shad, two specialized fishes that serve important roles as "keystone prey" which support large populations of other aquatic animals, including humpback whales and fishes important for human consumption. Indian Point Nuclear Power Plant sits on the shore of this 315-mile river, about 40 miles north from New York City.
Holtec is the company responsible for decommissioning the Indian Point Nuclear Power Plant. Holtec, in the Summer of 2022, was preparing to dump a million gallons of radioactive wastewater from another power plant, the Pilgrim nuclear plant, without the proper permits, into Cape Cod Bay in Massachusetts, when it was paused by a U.S. Senator in response to public objection in Plymouth and surrounding areas. Holtec ultimately committed to delaying the release, if need be, and to holding the processed water inside the plant for as long as necessary if scientific opinion advised against the discharge.
Sea Life Conservation, which learns of new advances in science to ensure the best decisions are being made to protect our marine, coastal, wetlands and waterway ecosystems, is sharing a new, effective method of removing radioactive compounds from waste water that has been discovered by researchers in Australia. To assess whether the planned Holtec discharge into the Hudson River should be stayed pending evaluation of application of this new method for greatly reducing harmful radionuclides, depends on whether the radionuclide removal from the water has already been completed so as to reduce them to safe levels. Sea Life Conservation has begun to monitor the decommissioning process for opportunities to make it safer for the River.
"SafeStor", is a process whereby much of the nuclear material decays (transforms itself) into safe material before it is removed from the site and before the facility is broken down. This would be the Indian Point plant decomissioning option that is best for the river, but it would delay the sale and reuse of the site. Holtec has chosen a faster option, likely because it is more profitable. The route chosen by Holtec involves transporting the waste and demolishing the facility including dismantling the reactor now, while it still has much radioactivity even though its radiation levels would have a chance to decline prior to demolition if more time were allowed to pass. Transport of remaining waste, metal grinding, and other demolition activities carry far less risk for surrounding human and ecological communities if they are carried out at a later time when much of the radioactive material has transformed into harmless material through a process known as decay.
At the end of a two week negotiation in New York, August 26, delegates from around the world had failed to reach consensus on a high-stakes, legally binding treaty to conserve ocean life on what are known as "the high seas" the areas more than 200 nautical miles from coastlines. These areas beyond national jurisdictions comprise two-thirds of the global ocean, a vast global commons. Thus, they are currently beyond the law. Severe overfishing has resulted in depletion of fish stocks. Without an agreement governing resource extraction or conservation, the populations of several species important for human consumption can be 'overfished down' to levels that will not recover for decades or centuries.
Fishing is *not* covered by the U.N. Convention on The Law of The Sea (also known as UNCLOS), which was adopted in 1982 prior to the emergence of concerns over biodiversity loss. The meeting was the fifth of planned diplomatic sessions that began in 2017 following more than 10 years of discussion. It ended only with a commitment to reconvene before the year is over. A systemic solution to overfishing is needed address the decline in marine life. The drive for profits that maximizes short term gains also puts sea life populations at risk to the detriment of all future generations who would otherwise benefit. Fishing is an important commercial industry for many nations and a good source of nutrition on which many people rely as their primary or secondary source of protein. The health of our fish populations on the high seas is thus important for future global human health.
A field of mathematics known as 'game theory' demonstrates that everyone has to play by established rules, or else those who do not will both have an advantage over those that do, and thus motivate all players to disregard the rules in a 'race to the bottom' where, given that the populations are going to necessarily crash from overfishing anyway (from 'bad' players) it is logical to gain financially before the crash by participating in the overfishing that is its cause. This phenomenon is also known as 'tragedy of the commons'. Penalties for transgressions and appropriate enforcement to detect rule-breaking thus must be essential elements of a system of protection.
More than 3 billion people rely on ocean life as their primary source of protein, and nearly 600 million rely on for their livelihoods, according to a 2022 from the U.N.’s Food and Agriculture Organization
The treaty the delegates sought to form would have protected 30% of the ocean by 2030. This would have required 11 million acres to be turned into Marine Protection Areas (MPAs), but the countries could not agree on where those areas should be.
Due to technological advances in fishing, a sharp 400% rise in catch by developed nations was experienced. But it was short-lived. Populations of fish are in serious decline. Despite further advances in technology, catch rates have flatlined as the advances have only accelerated the decline. Direct overexploitation is so impactful a cause of population decline and species extinction, it dwarfs that of climate change and habitat degradation for targeted species. It also has serious adverse impact to "by catch"(species caught unintentionally). Millions of tons of "by catch", or unintended catch are cast overboard dead, killed as collateral damage from high seas fishing each year.
Wildlife and Energy Policy Choices: How do the different forms of low-carbon types of energy production stack up against one another? Let's take a look.
Old-style Nuclear power plants in use since the 1960's were associated with harm to aquatic life because they required that large volumes of cooling water be cycled through the units. Because traditional nuclear power plants required high flow rates, they were typically placed on or at the shores of rivers, lakes, seas, or oceans. Although today's modern nuclear reactors do not require processing of such large volumes of water for their operation, the nuclear reactors of the past resulted in much damage to aquatic life. A large biomass of aquatic organisms would get trapped against "impinged on" (i.e. pinned against) filters, and die from be unable to move to carry out basic life functions, such as moving their gills to breathe or feeding. Many animals, namely those too small to be trapped by the filter, would get "entrained", meaning actually enter the power plant in the stream of cooling water, and die from blunt force injuries suffered during the perilous trip. Animals smaller than 1 square centimeter, such as very small fish, fish larvae, eggs, algae, bacteria, and fungi are typically those that would become "entrained" (pass through).
In the year 2004, the U.S. Environmental Protection Agency issued a rule to implement Section 316(b) of the Clean Water Act requiring technological or operational measures to be taken so as to determine the feasibility, effectiveness, and cost of reducing impingement mortality by 80%-95% and of reducing entrainment by between 60% and 90%. The requirement is that the intake system be reasonable to implement and that it reflect the best technology available for minimizing adverse environmental impact on aquatic organisms.
All nuclear reactors have a very low carbon footprint. The median carbon footprint for nuclear power plants is on the low end of the range for renewable energy.
Land-based Solar and Wind Power plants and Marine (Offshore) Wind Power plants use, impair, and degrade extremely large areas of vital wildlife and marine habitats. A typical one Gigawatt electrical Nuclear Power Plant in the USA (one Gigawatt is 1000 Megawatts or a billion watts) requires only 1 square mile of land. In order to produce the same amount of power as that 1-square-mile nuclear plant, a land-based wind turbine power plant requires approximately thirty thousand percent more land.
How much extra harm the extreme land use requirement of renewable energy is expected to present depends on what is the current use of the land (or ocean area) by wildlife (or marine life) at the time the power plant is proposed. If the power plant was built on land that represents habitat already lost (such as land highly modified by commercial agriculture or industrialization), the differential harm is less substantial than where such power plants usurp and impair untouched habitat or areas that serve important ecological purposes.
PHOTOVOLTAIC SOLAR PLANTS (NON-THERMAL)
Photovoltaic panels contain cells that absorb light. The energy from the light puts electrons into an excited state, and they move more freely in the material. Then, an electric current is created by a chain reaction of localized electron flow. The electrical current is captured and transferred to wires that are ultimately connected to the electric grid. Both Thermal Solar Power Plants and Photovoltaic Solar Power Plants use and degrade far more land per unit energy produced than do nuclear plants, with Photovoltaic Solar Plants being a bigger habitat destroyer per unit of energy produced than Thermal Solar. A ordinary Photovoltaic (PV) Solar plant (shown in the above photo) requires 50 to 75 times more land than does a nuclear plant to make as much power, and more than twice as much as a thermal solar plant. A Photovoltaic Solar Plant uses Solar Panels (usually blue or black in color), whereas a thermal solar plant uses mirrors to reflect and concentrate sunlight onto a substance in order to heat it up.
A United Nations report by the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services ("IPBES report") found that first, human land appropriation, and secondly, reckless overuse of animal species as commodity are the primary drivers both of catastrophic declines in populations of wildlife, decreased biodiversity, and heightened extinction risk. Climate change is only number three, the IPBES report found. [Summary at internet source: https://www.bbc.com/news/science-environment-48169783]. "Climate change is certainly one of the greatest threats that face humankind in the near future - so what does that tell us about the first and second biggest causes of decline, namely changes in land/sea use and direct exploitation? It tells us, for these causes of species and population decline (whose impact is even larger than that of climate change), that "the current situation is desperate and has been for some time". What is made clear by the United Nations IPBES report, the WWF report, and others like it is that due diligence protection of nature and natural habitats from direct harms must be a priority in addition to, in front of, and alongside, those actions to reduce climate change, actions to produce energy, and actions to obtain or produce food and goods for human consumption and survival, because such measures are essential to avoiding catastrophic losses of wildlife and the concomitant extinction risks that can challenge the very ability of the earth to support the humans on it. [Quote from BBC coverage in May 2019 of the IPBES UN Report. Internet Source: https://www.bbc.com/news/scienceenvironment-48169783, statement by Dr. John Spicer from the University of Plymouth, an IPBES report contributor]. The situation is dire. In just a little over 4 decades, 70% of the globe's wildlife population is gone. 32,000 populations of over 5,000 species were tracked in the study. Climate change is a serious problem that demands our attention. However, even if climate change could be instantly and satisfactorily addressed, if we fail to address the two leading causes of wildlife population decline (habitat appropriation for use by humans, and reckless overuse of animals and plants as commodity), we can expect to see further collapse of wildlife populations and extinctions worldwide.
[Trend summaries: video 1 , video 2, video 3 . Video tours of photovoltaic solar plants: video A, video B, video C.]
A photovoltaic solar power plant in India stretches as far as the eye can see but has only about 550 Megawatt electrical capacity.
For this thirty two Megawatt electric capacity solar power plant in New York on Long Island (shown below), twenty thousand trees were destroyed. [Project details] In addition to the destruction of trees, the entire understory was also cleared of all vegetation. The project reviewers stated in the Environmental Assessment of the project that the cleared area would be replanted "providing improved habitat for many threatened and endangered species", a fraudulent claim.
A portion of the Long Island Pine Barrens area was used for the above project. The Pine Barrens sit over a large aquifer and the untouched vegetation over these tracts of land is key to protecting the drinking water for the public. The environmental review of the project also did not even consider any adverse effects on wildlife populations due to habitat fragmentation. The solar plant separated a tract of land to its southwest from the Peconic River. The solar power plant is enclosed in security fencing. The wild area to the southwest of the power plant is bounded on its west side and its south side by high-automobile-traffic freeways/highways, and is now isolated, cut off, due to the solar power plant, from access to the Peconic River and land to the northeast.
Below is a picture of Clare power plant, a Photovoltaic Solar Power Plant, in Queensland.
Photovoltaic power plants not only usurp and degrade vast quantities of habitat resources, they also fragment remaining surrounding habitat. The below photovoltaic solar power plant is surrounded by security fencing that does not allow wildlife to pass.
The security fencing and roads that invariably surround photovoltaic power plants cause or contribute to extirpation of wildlife in the fragments of remaining habitat outside of the power plant footprint, because they present barriers to emigration to, and repopulation of, areas of land whose populations may have dwindled by chance events or temporary circumstances. This can lead to extirpation or regional extinctions.
Below is a fence-restricted photovoltaic power plant in Texas. The acreage of habitat that photovoltaic solar power plants use is higher per unit of power produced than most other types of power plants. Fighting climate change is extremely important. However, habitat degradation and destruction is an even bigger contributor to wildlife population decline than is climate change, according to the United Nations reports by the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IBPES) [learn more].
THERMAL SOLAR: A thermal solar power plant (photos shown below) requires 22 times the amount of land as a nuclear plant to make the same amount of power. Not quite as horrible as Photovoltaic Solar, but still very high use of land per unit of power produced. Thermal solar works by concentrating sunlight, via mirrors, onto molten salt contained in a tall tower. Molten salt can reach extremely high temperatures and remain liquid (i.e. not vaporize).The heated-up molten salt is then stored in an insulated storage tank, then, as electricity is needed, the hot salt is used to heat up water to make steam. The steam pressure turns a standard turbine and this generates electricity. [Below photo of Noor Solar Complex is courtesy of CNN]. Each Thermal Solar Plant (photos below) kills hundreds of thousands of birds. Birds' feathers literally burn up in flight when crossing the invisible beams of concentrated light [View video. Take a deep dive here & here ]. The scorched birds, unable to fly, crash to the ground. The California Energy Commission released a study conducted by the Center for Biological Diversity which showed the harm to birds of Thermal Solar Power Plants is grave. It is estimated that the Ivanpah Thermal Solar Power Plant will kill 560,000 birds during its operation, nearly 30 thousand per year of its operation. There are over 25 such power plants in Spain, eight in the United States, nine in China, six in South Africa, two in Israel, and more in India and the Middle East. Collectively, these are estimated to result in thirty million bird deaths worldwide per 20 year lifecycle period.
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Sunlight reflecting off mirrors can be used to heat materials. In thermal solar plants, the sunbeams reflecting off the mirrors are all pointed toward the tower. Thus, near the tower, the heat from the sunlight is greatly multiplied by all the converging individual paths of light from various mirrors.
NUCLEAR MATERIAL: Being in proximity to high radioactivity is harmful to life (causes mutations and cancer), and damages the environment, if it is not handled in a way that takes this into consideration. Back in the early 1900's, it was thought that the radioactive element radium had health benefits and beneficial, even curative properties. Many consumer products were made with it and were marketed to the public. For workers who were exposed to radium during manufacture of these products, not only weren't they warned that exposure is harmful, but were actively encouraged to ingest and make contact with the radioactive material for their health. This repeated contact with radioactive materials resulted in severe damage to tissues, bones, teeth, and the development of cancers among workers who produced radioactive consumer goods. High levels of radiation cause the body's marrow to not be able to produce blood, and very high levels can cause death. Since the early 1900's, a wealth of knowledge has accumulated on radioactivity. The levels of radioactivity in different parts of a nuclear power plant and around nuclear material are carefully measured so that the workers can be kept safe.
Now that there is knowledge of the harms of radiation, proper precaution is taken to ensure that the level of radiation at any given area or near any radioactive material is known so that a safe distance can be maintained and precaution can be taken to avoid all harm.
Nuclear waste isn't stored long-term in liquid form in damage-prone metal containers that ooze, as depicted in video games, cartoons, and popular animated series such as Teenage Mutant Ninja Turtles and The Simpsons.
Properly managed nuclear waste has no currently known widespread environmental public or environmental health effects. Due to inventions such as the geiger counter, and the dosimeter, it is easy to understand what level of radiation occurs at what distance, what the radius of harm is, and easily know how to place yourself outside it. Dosimeters, for example, are worn also by health care workers and veterinary care workers to know if they are safe from x-ray radiation during the ordinary course of their daily work.
About 95% of all nuclear waste has a short enough half-life that it can decay on-site into harmless inert material during the life of the power plant. The rest is stored in ceramics surrounded by thick concrete. "Dry cask" storage, as it is called, is solid on the inside, and is usually stored on the site of the power plant. Standing right next to a dry cask, and depending on how long it has been stored already, you can expect to get a level of radiation similar to that you'd receive on a long commercial airline flight when you go on vacation (the atmosphere is thinner at higher altitudes, so the radiation on a commercial airline flight is higher owing to less shielding from radiation emanating from outer space).
Dry Cask Storage
To date, almost a half a million tons of nuclear waste has been generated, though about a third of that has been recycled. It takes time for radioactive nuclear material to decay into material that is harmless. About 2000 metric tons of spent fuel are generated in the U.S. each year alone. What is nuclear waste? Nuclear waste is anything that emits alpha, beta, or gamma particles. This is everything from spent fuel pellets, rods, equipment, and parts that have been inside or a part of the reactor or exposed to radiation. What is alpha, beta, and gamma radiation? Getting too much of it can cause mutations and health effects. However the levels of radiation are very easily detected by using simple, readily available, and easy to use equipment (such as geiger counters), so the knowledge of what levels are where and how close is safe is extremely easy to come by, and to understand. During their operation, nuclear plants emit into the atmosphere a small amount of radiation. A typical coal fossil-fuel plant emits approximately 100 times more nuclear radiation into the air in its ordinary operation, per unit time, than does a nuclear plant.
Sometimes nuclear material, such as spent fuel rods, may be moved offsite for storage elsewhere. Could something bad happen during transport, such as after it has been put into a container and before it arrives at its ultimate off-site storage facility destination? Well, two layers of thick transport containers or 'flasks' are used to transport waste. The inner flask is 14-inch thick steel. Here is a video of the double container being struck by a one-hundred-mile-an-hour runaway train, in a test: the train crash into a nuclear waste container results in a fireball ngine fuel explodes as it makes contact with the nuclear waste container.
Also see:Truck crash tests]
Long term storage of nuclear waste material is accomplished by entombing it deep underground in tunnels drilled into rock formations that are expected to be stable for millions of years.
<< Deep geologic storage in Finland, storage method shown.
Here is actual footage of the underground tunnels in Finland's deep geologic repository for nuclear waste >>
PAST NUCLEAR ACCIDENTS:
What happened in the Chernobyl disaster? Steam explosion and fires caused release of more than 1/20th of the reactor's radioactive contents to spew into the environment, depositing radioactive materials in many parts of Europe. How many people died as a result? Two Chernobyl plant workers died due to the explosion on the night of the incident, and an additional 28 people died within a few weeks as a result of acute radiation exposure. Approximately 5,000 people sufferred thyroid cancer, and this resulted in 15 fatalities. The United Nations Scientific Committee on the Effects of Atomic Radiation concluded that, apart from the 5,000 who got thyroid cancers (resulting in 15 fatalities), there wasn't evidence of other major public health impacts, even after having followed public health records for well over 20 years following the incident. It should not be without comment that well over a quarter million people were evacuated. This caused widespread inconvenience, injuries during evacuation, and grave social upheaval. The psychological cost, social cost, and stress of preparations for, and of living in, a planned evacuation zone should not be understated.
Advanced nuclear reactors designs of today do not operate under pressurized conditions and are inherently stable.
In Chernobyl, poor design of the reactor itself and of the reactor control elements, and the fact that the nuclear reactor was brought to a country (Ukraine) that did not have appropriate operating procedures and that also was not overseen by any independent safety body, significantly contributed to the scenario in which the incident occurred. Indeed, "[t]he operators deliberately and in violation of rules withdrew most control and safety rods from the core and switched off some important safety systems." [Source: The 1986 Summary Report of the Post-Accident Review Meeting on the Chernobyl Accident (INSAG-1) of the International Atomic Energy Agency's (IAEA's) Nuclear Safety Advisory Group.] It is widely understood that there is virtually a zero risk of a Chernobyl-like accident in countries which have adopted international safety standards and have independent governmental regulatory bodies in place that oversee permitting and inspections of nuclear power plant construction and operation.
Radation is harmful, yet wildlife in the areas surrounding Chernobyl appears to be a seeming post-nuclear paradise of abundant wildlife, and burgeoning populations. Why? This is not because radiation isn't dangerous or hasn't been harmful to the animals - it is and it has been. It is because reversal of habitat loss (meaning habitat gain, or increased area that can be inhabited by wildlife, due to the creation of an exclusion zone) has had so beneficial an affect on wildlife populations at Chernobyl, that its benefit to populations, appears to have overall outweighed the negative effect of high levels of radiation.
DEATH RATE, A COMPARISON:
How do the dangers to humans, in terms of the death rates from solar, wind, and nuclear power, compare against one another?
A comparison of the rate of fatalities from commercial power production from different sources of energy. Nuclear energy is safer than solar energy, hydro power, and wind.
[Source: Sovacool, Andersen, S. Sorensen, K. Sorensen, Tienda, Vainorius, Schirach, and Bjørn-Thygesen. Balancing safety with sustainability: assessing the risk of accidents for modern low-carbon energy systems. Journal of Cleaner Production, Vol. 112, part 5, 2016 pgs. 3592-3595.]
The graph on the right is from 'Our World In Data', an org who used more inclusive numbers for nuclear by adding 19 deaths to the Chernobyl death toll of survivors who died later (of such varied causes as tuberculosis, liver disease, stroke, heart attacks; and later-incurred physical injury) "most from causes not related to radiation, but it’s not possible to rule all of them out", so they were included, and by including 384 deaths that haven't happened yet but might occur in the future from consumption of milk back in 1986 from cows which likely ingested nuclear material when the grazed on grass. The authors conclude the number they propose is "highly uncertain" but said they wish to be conservative about nuclear-related deaths by including the highest estimate of deaths that have not yet occurred [Source: https://ourworldindata.org/what-was-the-death-toll-from-chernobyl-and-fukushima ; and see: https://ourworldindata.org/grapher/death-rates-from-energy-production-per-twh ]. This data (shown right) has been redistributed by Canary Media and other outlets.
Of the deaths that are caused by wind power plants, roughly 2/3 are wind industry workers or operators and 1/3 members of the public or non-industry workers. Deaths from wind turbines include electrocutions, falls, crush injuries, construction accidents (crane accidents, equipment collapses, etc), turbine collapses, and many road and shipping accidents while transporting parts, ice being thrown off rotating turbine blades, or the blades themselves or parts of them being cast off, or falling off, the turbine. Other deaths are by fires, gear box failures, turbine parts falling off their transport vehicles or colliding with structures while moving on their transport vehicles, and heightened risk of cardiac arrest from whole-body low-frequency vibration found in workers that go in close proximity to operational machinery.
According to both popularly cited and scientific sources, wind power production causes 33% to 350% more deaths than does nuclear power production.
The data used to produce the above graphs and figures do not include deaths from an expected 2% increase in the suicide rate, from exposure to wind-turbine power plants among the general populace of counties in (14-mile) proximity to the wind power plants. The linked suicide study evidences a robust connection between proximity to an operating wind power plant operating under normal conditions and increased risk of suicide. The figures also do not account for the lower expected success rates, from impaired marine search-and-rescue missions conducted each year off the eastern coast of U.S. from turbine structures' interference with radar signals during rescue operations. Also omitted are marine deaths from ships colliding with turbines in unfavorable conditions.
Solar Power Industry deaths occur in a variety of ways, electrocution from photovoltaic panels or from electrical circuits or unexpected release of energy stored in other equipment, falls from a height, thermal burns, crane and hoist accidents (including panels lunging or falling onto workers when lifted), tractor-trailer drivers getting crushed when unstrapping their transport loads to ready equipment for lifting, unexpected happenings from swing hoists or conveyors, trench cave-ins when connecting utility lines, backhoe operators who fall out of their vehicles from not using seatbelts, being pinned crushed or run over by unmanned rolling forklifts, getting caught in the feed rollers of woodchipper and being pulled through the chipper during deforestation duties, getting sucked into other powerful machines such as those that manipulate sheets of steel.
Currently in the U.S., 140,000 to 500,000 birds die each year due to turbine collisions. Bird deaths could soar to 1.4 million per year if the U.S. Department of Energy achieves its goal of expanding wind energy to 20 percent of the country’s electricity demand by 2030 [Source: U.S. Department of the Interior's Fish and Wildlife Service.]
