By cfact
“In view of the various alleged legal deficiencies that are based on leasing and permission of onshore and offshore wind projects by the federal government, the consequences of serious damage can lead to serious damage …”
CFACT has already criticized several offshore winds in which cases are approved that are inadequate due to the elimination of important problems, which makes it incomplete. Some of the worst cases are listed below. Although Dominion was not the subject of all these points of criticism, they are undoubtedly affected by them. In addition, the Dominion approvals were the focus of many of these criticisms, which went back more than two years.
These properties apply to every authority of a lack of approval. A significant approval is supported by a formal document. This includes the authorized COP, the final NEPA ice cream, the biological statement of the ESA and the MMPa granting. In any case, a critical problem is overlooked in one or more of these permissible documents, which makes it incomplete.
In any case, the responsible federal authority has not taken into account these defects. However, the Trump administration is currently examining the history and the procedure of offshore wind permits. Under the following circumstances, if the examination is carried out correctly, you should determine incomplete approval documents, set the approval until it is finished and then issue it again.
The following are some of the worst permissible defects that CFACT has found so far:
1. The NMFS granting has no ice cream
The lack of an ice cream for the permission of the nuisance of NMFS is probably the most obvious deficiency. This is a great takeover for Dominion. Around 60,000 mammals are permitted due to noise pollution during the Dominion project.
According to the authorization document, this authorization campaign requires ice cream in accordance with NEPA. The permission document then makes it clear that the nuisance of ice cream in the Dominion Project Eis is included as a whole. However, taking it is never mentioned in the ice cream. Until the necessary ice is complete, we should not start building. The currently existing authorization documents are missing.
2. The effects of harassment are not taken into account in biological opinion
The same argument – even if one that is more complex – is in biological opinion. The biop gave the nuisance authority a small section 3.8, but the ice cream does not even deal with the ice cream. The biop lists only the number of endangered whale species that are bothered and claims to have prepared every realizable reduction strategy.
There is no evaluation of the adverse effects of harassment, which is the problem of the walk label. In the biop, there is no such effects, other NMFS reviews. This important problem of death induced by harassment is never discussed in the approval documentation.
Although it is now known that harassment kills whales, CFACT NMFS warned a long time ago a long time ago, especially for the Dominion project.
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It is important to carefully evaluate the potentially fatal consequences of harassment.
3. The turbine installation ship is not entitled to harass
Another example of harassment is the use of several engines in order to maintain the position through the Orion pile draft ship, which the Monopile foundations of Dominion laid.
According to the Rand Acoustics, the scattering sound is above the nuisance level. However, such a noise was not approved, since this was not mentioned in the application of harassment. It seems that Orion is unable to work lawfully on the project. This probably applies to tower, turbine and leaf installations as well as a monopile installation ship.
Before the construction can be continued, the approval of the Dominion Project harassment must be updated in order to take into account all expected installation ships.
4. The use of suction caissons instead of stacking is not taken into account
A solution for wind turbines, which relies on the requirement for the enormous loud, gigantic monopile, is the suction ceson. Monopile show the greatest damage to the whales by offshore wind, but suction kaissons give minimal damage. Offshore oil drilling islands have been anchored with the Caisson technology suction for many years. Although it is relatively new, offshore -Wind is obviously practical in the size of USOffHore projects, such as the 900 MW project, which is currently under construction by Ørsted, the world's largest developer, before Taiwan.
With regard to minor reduction measures to reduce the threats from the construction of endangered whales, the Dominion COP, BOEM EIS and the NMFS permits for harassment will operate significant lengths. However, none of them takes into account the use of suction caissons as an alternative to pile driving, which can significantly reduce the danger to endangered whales.
These three authorization documents must be revised to take into account suction huts instead of stacking.
5. Break the requirement of the “small numbers” of the MMPA
Only a limited number of any types of protected mammals can be justified according to the marine mammal protection law. More than 50,000 dolphins are covered by the permission to acoustic harassment of Dominion, which is obviously a considerable amount.
5% of the total population of the right whale at risk of criticism is also legally taken, which is by no means a tiny number. The total amount of occupancy would be a multiple of the population if every rented project would take this level of MW.
The Dominion COP has to be redesigned to adhere to the requirements of the small numbers of the MMPA.
6. Sedimen flags from sea currents that flow over wind towns are not taken into account
The idea that the flow flow via a standing wind array creates a continued sediment flag that could have a serious environmental impact is the subject of a significant group of scientific literature today. In the Dominion of biological opinion, only the temporary sedimation flags generated by cable ditch are taken into account. The operative sediment flag that can exist for so long, as long as the project is in the ocean, is not taken into account. Here the law on clean water could be relevant.
7. Not into account the contribution of the project to the overall effects of several projects
Compared to the simpler aggregate of the individual initiatives, the cumulative influence can be far greater. For example, if you avoid project combinations, this can significantly extend the time in regions with a lot of ship activity or fishing. The migration path of the right whale is doubled by Dominion proposed second CVOW project.
The cumulative effects should be treated in all important Dominion project assessment documents, but none.
8. Company noise is not taken into account
According to several studies, the operating noise of the massive turbine array will be higher than the threshold value of acoustic harassment. This noise is not covered by the Dominion's authority. The project cannot continue to move with the current construction and operating license if it reaches this noise level. These effects must be included in the project assessment. Another potential problem is infrastar.
9. Body management is not based
Only acoustic harassment is treated by the authorization of the Dominion nuisance. Nasting is defined as behavioral behavior by the MMPA. Avoiding the 150 square miles of large turbines is a significant shift in behavior that could have negative effects. As a result, the physical presence of the project, which does not have to be approved and properly evaluated – is evaluated.
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