Pasha Finberg marshalling the efforts of many
We just submitted our comments and recommendations to the California Energy Commission for the proposed development of offshore wind off our coast. This is our first of what looks like a volley of comments coming up in the next two months. And while these comments come specifically from OCR, it looks like a number of us will be pooling our efforts to aggregate comments cultivated from each of our particular specialties.
This strategy makes sense because the Biden Administration – Bureau of Ocean Energy Management (BOEM) is wasting no time getting a lot of wind projects in play. By the end of July activities will have been set in motion for Aqua Ventus (Maine), Gulf of Mexico, New York Bight, Offshore Virginia, Mayflower Wind (Massachusetts), Kittyhawk Wind (N, Carolina), California Offshore, and Vineyard Wind.
Perhaps one of the Administration’s strategies of moving ahead so rapidly on all of these projects has to do with creating enough inertia on wind energy, that should the oilmen get ahold of the tiller again, these projects will be far enough along to thwart cancellation. But with all of these offshore projects on the boards, we in the conservation business have a lot of work in front of us.
When an Environmental Assessment (EA), or Draft Environmental Impact Statement (DEIS) is sent out for public comment under the National Environmental Policy Act (NEPA), we would typically review the document and submit our comments and critiques particular to our specialties. So Environmental Defense and Southern Environmental Law Center would focus on legal issues, and we would focus on noise pollution.
But there will always be some overlaps; noise issues intersect with regulations under the Marine Mammal Protection Act and the Endangered Species Act, and guidelines for “Incidental Harassment Authorizations” often intersect noise exposure. So what this has summoned is a lot of overlapping work, often stating the same points from different angles. And with all of these projects that are similar (wind turbines on the ocean) this amounts to a ton of duplicated efforts.
Addressing this, we are having a lot of coordination meetings with other conservation groups, facilitating collaboration on the comments and critiques. This will allow each of us to focus on our areas of expertise, understanding that our backs are covered in areas where we are not as conversant.
It will also allow us to develop a larger document with nested concerns on offshore wind – impacts of surveys, siting, placement, construction, and operations, for example. And then open up the document to address site specifics dealing with particular habitats, species, and mechanical issues. This relieves some of the burden on us, but it also relieves the burden on the agencies reading and responding to the documents.
In this manner we can have the bases covered as we advance responsibly toward a sustainable energy future.
