CFACT's comment on the Environmental Impact Statement on Offshore Wind Energy Programming (PEIS) in California – Watt?

From cfact

CFACT's comment on the Environmental Impact Statement on Offshore Wind Energy Programming (PEI) in California

By President Craig Rucker

cfact

https://www.cfact.org

Submit to https://www.regulation.gov/document/boem-2023-0061-0189

February 12, 2025

Overview of our concerns

Boem commented on five floating wind leases for five floating wind leases on the California coast. This is Boem's second offshore wind vein. First up is in a series of leases near New York, including fixed bottom turbines. This is the first PEI for floating wind turbines, which is very different from the fixed turbines built along the Atlantic coast.

Floating wind is still an immature technology, and none of its recommended designs have been tested by the commercial utility scale. There are only a few small demonstration scale projects in the world.

There are at least two useful things in this PEI. First is a great tutorial on floating wind, focusing on the California case. This is Appendix A, completed by the National Renewable Energy Laboratory. They ruled out many design options, including the proven most popular Spar Floater. The various options they propose show the immaturity of the technology

Second, PEIS includes encyclopedia discussions on numerous potential adverse effects on the general floating wind project. These effects are limited to everything considered in each of the five leases, so when all five leases are combined, it is clear that the plan will be environmentally destructive. These adverse effects cannot be mitigated, so the right decision is that the plan should not continue. The choice without any action is the right choice.

This is just a short list of some of the major flaws in PEIS

1. By far, the biggest drawback is the absence of cumulative multi-leasing impact assessments. The focus of PEI is on such an evaluation of the entire procedure. The cumulative impact may be much larger than the sum of the impacts of a single project, especially in this case where two or more projects are closely clustered. Therefore, it is completely insufficient to list individual items only.

2. In many cases only adverse effects are mentioned without assessing potential harm. This should be an impact assessment, not just an impact list.

3. There will certainly be a large number of systemic harassment by endangered and protected whales and other animal species, but there is no discussion. In fact, the term “harassment” only occurred twice throughout the main report. Death caused by noise harassment that causes fatal behavior is one of the biggest adverse effects of offshore winds.

4. In addition, floating winds introduce major forms of harassment in non-acoustic forms. This is a 3D network, which can be thousands of moored cables, each of which can be within a mile of length. We're talking about hundreds of square miles of deep seas, which are literally filled with cable nets. Harassment is defined by the Marine Mammal Protection Act as the behavior that leads to a change in behavior of protected animals, and these terrible nets will certainly do so. This very large-scale continuous harassment should be carefully evaluated.

5. PEIS does briefly mention the threat of “secondary entanglement” captured on the cable over time in the mesh, wires and other debris. The potential adverse effects of this fatal accumulation require detailed assessment.

6. Finally there is a broad economics section, but no mention of the cost. The development of these five leases could cost taxpayers and taxpayers tens of thousands, or even hundreds of billions of dollars. The cost of the entire plan should exceed one trillion dollars, but these amazing amounts will never be quantified. When jobs are actually a cost, creating jobs is a benefit. Total cost needs to be estimated.

It is obvious that the deficiency of this PEI is insufficient. In fact, it specifically avoids problems that justify canceling the procedure. The cumulative impact threat is addressed in more detail below.

The entire western offshore wind energy program must be evaluated

The five leases are small compared to the yawning programming EIS gap created by the Federal West Coast Offshore Wind Energy Development Action Plan. First, California’s full plan is huge compared to the five leases covered by the so-called California PEIS. The current PEIS file will be better known as the Starter Kit EIS. Plus, Oregon and Washington have a lot of developments.

As noted above the PEIS document, the cumulative impact of these five leases is not addressed; it simply looks at the general impact of one lease. But the real lack of action is the environmental impact assessment of the entire West Coast program.

The new report comes with a long title: “Action Plan for Ocean Wind Transmission Development in the West Coast of the United States” (original all caps). Action planning is a conceptual design for transmission offshore generation, but in order to do this you have to know where a generation is, so it can be included in detail.

In the current draft PEIS, only five leases considered in the action plan include approximately one hundred leases by 2035. These leases usually appear in clusters of 5 to 20 leases. Additionally, while the total power generation capacity in 2035 is 15,000 MW, this has grown to 33,000 MW in 2050.

Each lease contains many huge floating turbines, each anchored thousands of feet below the sea and has multiple mooring lines. Therefore, the environmental impact of each cluster can be huge.

To make matters worse, these clusters are basically on the coast, especially in Northern California and southern Oregon. Migrating species may encounter and be adversely affected by the entire series.

The list of threatened endangered or protected species is long. As mentioned above, these huge arrays of 3D cables are a new form of harassment under the Marine Mammal Protection Act. In danger, there are also endangered sea turtles, giant rays, etc.

PEIS Appendix A says a single turbine float requires up to 12 mooring lines to remain stable and stable in heavy weather. Assuming a 15 MW turbine has twelve lines, then a 15,000 MW development will have 12,000 mooring lines. The 33,000 MW box will have an amazing 26,400 moorings and is 4,000 feet long.

We are talking about thousands of square miles of deep seas, literally filled with a net of cables. Harassment is defined by the Marine Mammal Protection Act as the behavior that leads to a change in behavior of protected animals, and these terrible nets will certainly do so. This very large-scale continuous harassment should be carefully evaluated.

PEIS also describes the threat of “secondary entanglement” captured on these cables over time in the mesh, wires and other debris on these cables. The potential adverse effects of such fatal accumulation need to be evaluated in detail before any offshore projects are approved. Note that this threat accumulates over time throughout the life of the project.

Cap harassment reduces the adverse effects of this offshore wind development

The clear solution to these mooring line threats is to severely limit the number of harassment authorizations. With these very limited mandates, few new offshore wind projects can be built. Nor should they be due to their environmental destructiveness. Each project requires a large amount of authorization, thus greatly reducing its number and greatly reducing the number of offshore wind projects.

The easiest way to do this is to send the total number of wind power authorizations to specific exposed populations throughout the program. This is similar to limiting the emissions of hazardous pollutants. It is even possible to create a cap and trade plan where developers now bid for authorization, just as they now bid for leases. The 1990 cap on sulfur dioxide emissions of power plants and the trade plan is a clear analog.

If cumulative harassment is limited to saying that 10% of the exposed population of each threatened species will severely limit the development of offshore winds.

All in all, the so-called California program environmental impact statement is nothing more than. The entire offshore wind planning is required for the entire West Coast before any project is approved for construction. This necessary assessment was missing in action.

Based on this assessment, the cumulative impact must be minimized. Limiting authorized harassment to each threatened species may be the best way to avoid destructive effects.

Submit respectfully

Craig Rucker

President

cfact

Washington, DC

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