The CLC has submitted comments (together with American Bird Conservancy) on the Draft Upper Great Plains Wind Energy Programmatic Environmental Impact Statement (PEIS). The U.S. Fish and Wildlife Service and the Western Area Power Administration are jointly seeking to streamline the environmental review process under the National Environmental Policy Act and the Endangered Species Act for wind energy development in the six state UGP region. For wind facilities seeking to interconnect to Western’s transmission system or for wind facilities seeking accommodation on FWS-managed easements, the agencies are proposing to require implementation of certain best management practices, avoidance measures, and mitigation as a condition to tiering to the PEIS. The CLC's comments emphasized the need for stricter avoidance and minimization measures, clearer best management practices, stronger mitigation requirements, and site-specific consultation under the ESA for listed species. Additionally, the CLC stressed the lack of relevant data in the agencies' discussion of potential impacts to wildlife and habitat, focusing particularly on the need for revisions to the avian and bat mortality estimates. The comments also highlighted the inadequacy of the PEIS's cumulative impacts section, noting that the analysis should be reexamined rather than left for the tiered site-specific analysis.