By CFACT
By David Wojick
Last month, I analyzed several gaps in the federal draft California Programmatic EIS (PEIS) for offshore wind energy. See.
Now a new report shows that these seemingly large holes are tiny compared to the huge programmatic EIS gap created by the federal West Coast Offshore Wind Development Action Plan.
First of all, the entire California program is huge compared to the paltry five leases covered by the so-called California PEIS. The document I wrote about should better be called “Starter Kit EIS”. There is also a lot of development in Oregon and Washington.
I previously pointed out that the PEIS document does not address the cumulative impact of these five leases; Only the general effects of a rental agreement were examined. But what is really missing is an environmental impact assessment for the entire West Coast program.
The new report has the long title: “AN ACTION PLAN FOR Offshore Wind Transmission Development in the US West Coast Region” (in the original only capital letters).
See
The action plan is a conceptual design for the transmission of offshore power generation. However, in order to create this design, you need to know where the electricity generation is located so that it can be taken into account in great detail.
Instead of just five rental agreements taken into account in this draft environmental impact study, the action plan covers around a hundred rental agreements until 2035. These typically take place in clusters of 5 to 20 rental agreements. In addition, the total generation capacity in 2035 is 15,000 MW, increasing to 33,000 MW in 2050.
Each lease includes numerous giant floating turbines, each anchored thousands of feet below the ocean's surface with multiple mooring lines. So the environmental impact of each cluster is potentially enormous.
Worse still, a number of these clusters essentially line the coast, particularly in northern California and southern Oregon. Migratory species could encounter and be affected by this entire series.
The list of endangered or protected species that are threatened is quite long. As I discussed in my previous article, these giant 3D cable arrays represent a new form of nuisance under the Marine Mammal Protection Act. Endangered sea turtles, giant rays, etc. are also at risk.
According to PEIS, a single turbine float may require up to 12 mooring lines to keep it stable and in place in heavy weather. Assuming 15 MW turbines with a dozen lines each, the 15,000 MW project would have 12,000 mooring lines. The 33,000 MW case would have an incredible 26,400 mooring lines, many over 4,000 feet long.
We're talking thousands of square miles of deep sea literally filled with cable networks. Harassment is defined in the Marine Mammal Protection Act as a change in the behavior of a protected animal, and these monstrous nets are sure to do that. This ongoing, large-scale harassment should be carefully examined.
The PEIS also briefly mentions the risk of “secondary entanglement” in the nets, lines and other debris that become entangled in these cables over time. The potential negative impacts of this deadly buildup must be assessed in detail before offshore projects are approved.
The clear solution to these mooring threats is to severely limit the number of nuisance permits. With these very limited permits, very few new offshore wind projects can be built. This should not be the case as they are harmful to the environment. Each project requires a large number of permits, so drastically reducing their number will drastically reduce the number of offshore wind projects.
The easiest way to achieve this is to limit the total number of wind permits issued to a given exposed population over the course of the program. This is comparable to limiting the emission of dangerous pollutants. One could even institute a cap-and-trade program where developers bid for permits the same way they now bid for leases. The 1990 cap and trade program for sulfur dioxide emissions from power plants is an obvious analogy.
If cumulative harassment were limited to approximately 10% of the exposed population of each threatened species, this would significantly limit offshore wind development.
In summary, the so-called California Programmatic Environmental Impact Statement is nothing of the sort. The full offshore wind program must be assessed for the entire West Coast before a project is approved for construction. This required judgment is missing in action.
Based on this assessment, the cumulative impacts must then be minimized. Limiting permissible harassment of any threatened species may be the best way to avoid destructive impacts.
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