Do the defects in the Dominion offshore style permit-Watt get along with it?

From CFACT

“In view of the various suspected legal defects that are leased and permitted in land and offshore windstorm projects in land and offshore windstorm projects, the consequences may lead to serious damage …” This is to guide President Trump's administrative order to suspend the windpower project allowed to suspend the wind power project allowed Allow the Presidential execution command.

CFACT has criticized several offshore winds because of the omitted important issues, so the case is insufficient and incomplete. Some of the worst cases are listed below. Although Dominion is not all the themes of these criticisms, they will undoubtedly be affected by them. Coupled with the dominance permits, many criticisms have more than two years.

These features are suitable for each instance of license defects. The official document supports a large number of approval. These include authorized COP, final NEPA EIS, ESA biological opinions and MMPA accidental authorization. In each case, one or more allowed documents will ignore a key issue to make it incomplete.

Relevant federal agencies ignore these defects in each case. However, the Trump administration is currently studying the history and procedures of the offshore style permit. In every case described below, if the investigation is conducted correctly, they should find incomplete approval documents, stop approval until they are completed, and then re -issued.

The following is some of the most serious allowable defects discovered by CFACT so far:

1. NMFS comes with authorization without EIS

The lack of NMFS harassment permits can be said to be the most obvious disadvantage. For Dominion, this is a huge takeover. Due to the noise harassment during the Dominion project, only 60,000 mammals are collected.

According to the authorized documents, this authorization operation requires EIS according to NEPA. Then, the license file clearly shows that harassment EIS is included in the entire Dominion project. However, it has never been mentioned in the EIS project. Therefore, we should not start construction before the necessary EIS is completed. There is currently lack of authorized documents.

2. Do not consider the effect of harassment in biological opinions

The same argument (although more complicated) is applied in biological opinions. BIOP gave a small part of the harassment agency 3.8, but EIS did not even solve the project. The BIOP only listed the number of endangered whale species that was harassed and claimed that all feasible relief strategies had been prepared.

There is no harmful effect on harassment, which is the problem of whale death. BIOP does not declare this impact, but other NMFS assessments do exist. The license document has never discussed the important issues of harassment to induce death.

Although it is well known, harassing killing whales, CFACT warned the possibility of NMFS a long time ago, especially for the Dominion project.

Check

It is important to carefully evaluate the potential and fatal consequences of harassment.

3. No authority harassing turbine installation boat

Another example of harassment is to deploy several pushers to maintain the position of the hunter hunter, which has laid the single foundation of dominion.

According to the measurement of Rand Shengxue, the noise of the pusher is higher than the level of harassment. However, this noise has not been approved because it has not been mentioned in the harassment application. It seems that Orion cannot legally engage in the project. This may be suitable for tower, turbine and blade device and any single installation boat.

Before the construction continues, the Dominion project harassment authorization must be updated to explain all expected ship noise.

4. Don't consider using an inhaled cage instead of pile driving

A huge and huge single -hole demand is a solution to the foundation of the wind turbine. Single holes constitute the greatest harm to the offshore wind, but the damage caused by suction cage is the least. Over the years, the oil drilling machine has been anchored by the use of suction CAISSON technology. Although it is relatively new, in the scale of the US offshore project, the offshore wind is obviously feasible. For example, the 900 MW projects constructed by the world's largest developer, the world's largest developer.

In terms of minimal measures to reduce the threat of endangered whales, the ruled police, Boem EIS and NMFS harassment permits are large. However, no one considers the use of suction cage as a substitute for pile driving, which may greatly reduce the harm to endangered whales.

These three license files need to be revised to explain the suction cage rather than pile driving.

5. Breaking the “decimal” requirements of MMPA

According to the “Marine Mammals Protection Law”, only the limited number of each protected mammalian is eligible to obtain the authorization. Dominion's acoustic harassment permit covers more than 50,000 dolphins, which is obviously very large.

Similarly, 5 % of the entire population of severe endangered right whales was captured by law, which is by no means very little. If each leasing project is allowed to pay the income level per MW, the total number will be many times the population.

The Dominion Cop must be redesigned to comply with the MMPA for a small amount.

6. Do not consider the sedimentary feathers of foreign flow in the wind energy facilities

At present, marine currents pass through the standing wind array flow will have continuous sedimentary feathers, which may have serious environmental impacts. It is now the theme of a large number of scientific literature. In Dominion biological opinions, only temporary sediments feathers generated by the cable ditch can be considered. Regardless of the operation of the operating sediments that can be continuously used in the ocean. Here, the “Clean Water Law” may be related.

7. Failure to consider the contribution of the project's overall impact on multiple projects

Compared with the simple summary of a single plan, the cumulative impact may be greater. For example, avoiding project portfolios can greatly extend the time spent on a large number of ship activities or fishing areas. The migration path of the right whale will be doubled by the second CVOW project proposed by Dominion.

Cumulative impact should be covered in all key Dominion project evaluation files, but not.

8. Do not consider operating noise

According to several studies, the work noise of the huge turbine array will be higher than the acoustic harassment threshold. This noise is not covered by Dominion Harassment Authority. If the project reaches the level of noise, the project will not be further developed. This effect must be included in the project evaluation. Another potential problem is temporary.

9. Do not consider physical harassment

Dominion harassment authorization only covers acoustic harassment. MMPA defines harassment as changing behavior. Avoiding a 150 -square -mile turbine array is a significant behavior transfer, which may have a negative impact. As a result, the physical existence of the project (without approval and must be correctly evaluated) is harassment.

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