CFACT Comments on the California Offshore Wind Draft Programmatic Environmental Impact Statement (PEIS) – Watts Up With That?

From CFACT

CFACT Comments on the California Offshore Wind Draft Programmatic Environmental Impact Statement (PEIS)

By Craig Rucker, President

CFACT

https://www.cfact.org

Submitted to https://www.regulations.gov/document/BOEM-2023-0061-0189

February 12, 2025

Overview of our concerns

BOEM is taking comments on a draft Programmatic Environmental Impact Statement (PEIS) for its five floating wind offshore leases off the California coast. This is BOEM’s second offshore wind PEIS. The first was for a set of leases off New York which featured fixed bottom turbines. This is the first PEIS for floating wind turbines which are very different from the fixed turbines being built along the Atlantic coast.

Floating wind is still an immature technology with a large number of proposed designs none of which has been tested at commercial utility scale. There are just a handful of small demonstration scale projects in the world.

There are at least two useful things about this PEIS. First is a pretty good tutorial on floating wind with a focus on the California case. This is Appendix A, done by the National Renewable Energy Laboratory. They rule out a number of design options including the most popular that has been demonstrated, the spar floater. The huge range of options they present shows the immaturity of the technology

Second the PEIS includes an encyclopedic discussion of numerous potential adverse impacts of a generic floating wind project. These impacts are limited to just what is contemplated for each of the five leases so when combined for all five leases it is clear that this Program will be environmentally destructive. These adverse impacts cannot be mitigated so the correct decision is that the Program should not proceed. The No Action Alternative is the proper choice.

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

1. By far the biggest flaw is that there is no cumulative multi-lease impact assessment. The whole point of a PEIS is to do such an assessment for the entire Program. Cumulative impact can be much greater than the sum of individual project impacts especially where two or more projects are closely clustered as in this case. Thus merely listing individual project impacts is completely inadequate.

2. In many cases an adverse impact is merely mentioned with no assessment of the potential harm. This is supposed to be an impact assessment not just a list of impacts.

3. The systematic harassment of large numbers of endangered and protected species of whales and other animals is certain to occur but it is not discussed. In fact the term “harassment” only occurs twice in the entire main report. Death due to noise harassment causing deadly behavior is one of the top adverse impacts of offshore wind.

4. Moreover floating wind introduces a major non-acoustic form of harassment. This is the 3D web of potentially thousands of mooring cables each of which could be on the order of a mile long. We are talking about hundreds of square miles of deep ocean literally filled with webs of cables. Harassment is defined by the Marine Mammal Protection Act as causing behavioral change on a protected animal’s part and these monstrous webs will certainly do that. This very large scale continuous harassment should be carefully assessed.

5. The PEIS does briefly mention the threat of “secondary entanglement” in the nets, lines and other debris that are caught on the cables over time. The potential adverse effects of this deadly accumulation needs to be assessed in detail.

6. Lastly there is an extensive economics section but no mention of cost. Development of these five leases will likely cost ratepayers and taxpayers tens of billions of dollars, possibly hundreds of billions. The entire Program should cost over a trillion dollars but these staggering sums are never quantified. Job creation is treated in detail as a benefit when jobs are in fact a cost. The total cost needs to be estimated.

It is clear that this PEIS is woefully inadequate. In fact it specifically avoids those issues that justify cancelling the Program. The cumulative impact threat is treated in more detail below.

The entire Western Offshore Wind Energy Program must be assessed

A new federal report shows that these five leases are tiny compared to the yawning Programmatic EIS gap created by the Federal Action Plan for West Coast offshore wind development. To begin with the full California Program is huge compared to the measly five leases covered by the so-called California PEIS. The present PEIS document would be better called the Starter Kit EIS. Plus there is a lot of development off of Oregon and Washington.

As pointed out above the PEIS document does not address the cumulative impact of those five leases; it just looks at the generic impact of one lease. But what is really Missing In Action is an environmental impact assessment for the entire West Coast Program.

The new report bears the long title: “AN ACTION PLAN FOR Offshore Wind Transmission Development in the U.S. West Coast Region” (all caps in the original). The Action Plan is a conceptual design for transmission of offshore generation but in order to do that design you have to know where the generation is so that is included in considerable detail.

Instead of the just five leases considered in the present draft PEIS the Action Plan includes about one hundred leases by 2035. These typically occur in clusters of from 5 to 20 leases. Moreover while the total generating capacity for 2035 is 15,000 MW this grows to a massive 33,000 MW in 2050.

Each lease contains numerous huge floating turbines each anchored to the sea floor thousands of feet below with multiple mooring lines. So the environmental impact of each cluster is potentially enormous.

Even worse a series of these clusters basically line the coast especially in Northern California and Southern Oregon. Migrating species might encounter and be adversely affected by this entire series.

The list of endangered or protected species that are threatened is quite long. As pointed out above these massive 3D cable arrays are a new form of harassment under the Marine Mammal Protection Act. There are also endangered sea turtles, giant rays, etc., in jeopardy.

The PEIS Appendix A says a single turbine floater can 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 development would have 12,000 mooring lines. The 33,000 MW case would have a staggering 26,400 mooring lines, many over 4,000 feet long.

We are talking about thousands of square miles of deep ocean literally filled with webs of cables. Harassment is defined by the Marine Mammal Protection Act as causing behavioral change on a protected animal’s part and these monstrous webs will certainly do that. This very large scale continuous harassment should be carefully assessed.

The PEIS also describes the threat of “secondary entanglement” in the nets, lines and other debris that are caught on these cables over time. The potential adverse effects of this deadly accumulation needs to be assessed in detail before any offshore projects are approved. Note that this threat accumulates over time, throughout the entire life cycle of a project.

Capping harassment diminishes the adverse impact of this offshore wind development

The clear solution to these mooring line threats is to severely constrain the number of harassment authorizations. With these very limited authorizations very few new offshore wind projects can be built. Nor should they be since they are environmentally destructive. Each project requires a large number of authorizations so drastically reducing their number drastically reduces the number of offshore wind projects.

The simplest way to do this is to cap the total number of wind authorizations that will be issued throughout the Program for a given exposed population. This is analogous to capping the emission of dangerous pollutants. One could even have a cap and trade program where developers bid for authorizations just as they now bid for leases. The 1990 cap and trade program for power plant sulfur dioxide emissions is an obvious analog.

If the cumulative harassment were limited to say 10% of the exposed population of each threatened species this would severely constrain offshore wind development.

In summary the so-called California Programmatic Environmental Impact Statement is nothing of the kind. The full Offshore Wind Program needs to be assessed for the entire West Coast before any project is approved for construction. This required assessment is Missing in Action.

Based on this assessment the cumulative impacts then have to be minimized. Capping the authorized harassment of each threatened species may be the best way to avoid destructive impacts.

Respectfully submitted,

Craig Rucker

President

CFACT

Washington, D.C.