Several conservation groups, including the American Bird Conservancy’s Wind Campaign and the Audubon Society, are pushing for the enforcement of federal laws that protect migratory birds to apply to the wind energy industry. Under the Migratory Bird Treaty Act and Bald and the Golden Eagle Protection Act, no citizen-suit provisions exist for a private plaintiff to bring action against a wind energy company, while the Endangered Species Act offers such provisions. Unlike other energy industries that have been convicted under the Migratory Bird Treaty Act, the wind industry has yet to face any federal prosecution for migratory bird mortality.