Greetings Nfcers,

While the phenomenon of avian towerkill is not directly related to night flight calls, it does involve night migration. I started to get involved in the avian towerkill issue back in 1996. I had been contracted to do an acoustic study of avian nocturnal migration at a proposed commercial wind energy facility in the prairie region of north-central Nebraska. I put one of my acoustic stations near the base of a 317-ft guyed radio tower, primarily to take advantage of the AC power at the site. Got lots of interesting flight calls but unexpectedly in spring 1997 I also recorded a number of avian collision sounds with the tower. This really began to open my eyes to the potential collision hazards of even short tower structures to night migrating birds.

There has been an ongoing effort to mitigate mortality of nocturnal migrant songbirds at communications towers for the past decade. The Federal Communications Commission (FCC) is currently holding another public comment period on the towerkill issue. This stems from a lawsuit led by the American Bird Conservancy & Forest Conservation Council, and a decision by the D.C. Circuit Court that prevented the FCC (under pressure from corporate lobbying) from dismissing the avian towerkill issue. While comments submitted during the previous FCC comment periods regarding this issue are still in play, this current comment period regards input on whether the FCC should conduct a programmatic Environmental Impact Assessment (EIS) on its Antennae Structure Registration program. The answer is clearly yes, because the avian towerkill issue is not as much site specific as it involves all towers -- the impact to birds is cumulative as well as site specific and the primary mitigation would involve a change in aviation obstruction lighting regulations for all towers. The FCC currently abides by an Environmental Assessment (EA) program on a tower by tower basis, but this does not address cumulative impacts. Elevating the environmental review of the FCC's antennae structure regulation program to an EIS would help assure that the avian towerkill issue gets the appropriate mitigative attention for cumulative impacts. [e.g., by some estimates, more than 1% of the Cerulean Warbler population is killed at towers annually]

One of the more significant direct conservation actions for songbirds is before us right now and the comment period ends in 9 days. An easy way to support this effort is to sign the petition at the Defenders of Wildlife webpage
https://secure.defenders.org/site/Advocacy?cmd=display&page=UserAction&id=1769

As with other issues involving federal agencies and big corporations, success in instituting strong environmental regulations is dependent upon the teamwork of large conservation organizations -- in this case American Bird Conservancy, Defenders of Wildlife, Forest Conservation Council, and National Audubon Society are all worthy of our support.

For those with more time you can find out more information and submit your own comments directly to the FCC at: http://www.fcc.gov/pea All comments submitted to the FCC on this issue since 2003 are available on the FCC webpage http://fjallfoss.fcc.gov/prod/ecfs/comsrch_v2.cgi entering 03-187 in box #1, and then clicking the Retrieve Document List button.

Yours in bird,

Bill Evans



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