North American Windpower, Apr. 2014, by Richard Harris Podolsky.
http://www.nawindpower.com/issues/NAW1404/FEAT_03_Feds-Step-Up-Avian-Enforcement-Will-You-Be-Ready.html

"There is a triple whammy emerging in the wind industry that will require developers to be far more proactive than they have been regarding bird and bat issues."