2 views on Vineyard Wind delay
Markey, Kennedy tone down rhetoric; fishing group urges caution
INITIALLY, MEMBERS of the Massachusetts congressional delegation were harshly critical of the Trump administration for putting off a decision about the environmental impact statement of Vineyard Wind, the 800 megawatt wind farm proposed for the waters off of Martha’s Vineyard.
Sen. Ed Markey said the move to delay the decision showed the Trump administration “will do everything in its power to cut corners for oil and gas projects while cutting the cord on the next frontier of clean energy development.” US Rep. Joseph Kennedy III accused the Trump administration of “delaying [the project] to death.”
In the letter below to two Trump cabinet secretaries, Markey, Kennedy, and others adopt a far more moderate stance, imploring two cabinet secretaries to find a way for fishing and offshore wind to coexist in “mixed-use regions offshore.”
Meanwhile, the Responsible Offshore Development Alliance, which represents fishing interests, applauded the Trump administration for slowing the process down and gathering more data.
We write regarding the supplemental Environmental Impact Statement (EIS) for the Vineyard Wind offshore energy project. As you know, the company is overseeing the development of the nation’s first utility scale offshore wind energy project, which the company says will generate enough power for approximately 400,000 homes.
We respect the need to do a cumulative impact analysis and understand the precedent this project will establish for permitting future offshore wind energy projects. It is important the departments consider concerns and evaluate all options to mitigate impacts to the New England commercial fishing industry and the environment. However, we also believe it is possible for multiple industries to coexist in mixed-use regions offshore. Therefore, we encourage your agencies to judiciously evaluate these questions to identify necessary steps to address any concerns, finalize the supplemental EIS promptly, and mitigate any additional delay that may threaten the overall project.
According to the Massachusetts Department of Energy Resources, the Vineyard Wind project will save Massachusetts ratepayers approximately 3.5cents/kWh, or $35.29/megawatt-hours (MWh) on average over the term of the contract with total net benefits of approximately $1.4 billion. The project also has the potential to reduce the state’s reliance on imported fuel including from some countries which may not share America’s values or commitment to protecting the environment. Further, Louisiana and Gulf Coast companies that have decades of experience working in the Gulf of Mexico are eager to make needed investments to support this project and future offshore wind energy projects.
We urge your departments to work together to find a solution that will address concerns raised by stakeholders, protect the environment, and allow the Vineyard Wind project to remain viable. We thank you both for your prompt attention to this issue and look forward to your reply.
The following statement was issued by the Regional Offshore Development Alliance, which represents fishing interests, on August 13.
In light of the recent decision by the Bureau of Ocean Energy Management (BOEM) to perform a cumulative impacts analysis regarding the proposed Vineyard Wind project, and the recently released communications between that agency and the National Marine Fisheries Service (NMFS), the Responsible Offshore Development Alliance would like to clarify certain statements and representations.
The RODA board of directors particularly notes the citation of its statement regarding turbine spacing and orientation in BOEM’s response to NMFS’ letter of nonconcurrence. To provide the full context of this statement, which is not readily apparent from BOEM’s letter, it is posted here in its entirety.
During the development of the Vineyard Wind Draft Environmental Impact Statement (DEIS), RODA signed a memorandum of understanding with BOEM and NMFS in order to collaborate on the science and process of offshore wind energy development on the Atlantic outer continental shelf. We value the relationships and progress we are advancing with both agencies as well as those with developers, including Vineyard Wind, through cooperation on our joint industry task force and the Responsible Offshore Science Alliance.
The size, pace, and scope of proposed offshore wind energy projects on the Atlantic outer continental shelf demand that lawmakers, regulators, developers, and the public all employ due caution to ensure that these developments can coexist with our traditional and historic fisheries. It would be unacceptable to put at stake hundreds of thousands of skilled fishing jobs, healthy and sustainable seafood, important traditional ecological knowledge, and the very fabric of our coastal cultures in a rush to welcome a new industry before the trade-offs are fully considered. In many early natural resource-based industries—including the fishing industry—a race to develop without adequate science and planning has resulted in avoidable resource catastrophes. We would like to avoid those outcomes, and taking time to understand the cumulative impacts of multiple imminent industrial projects is critical to doing so.
BOEM holds full authority to issue a decision on the DEIS’ preferred alternative, and the responsibility to ensure that its analyses are sound and complete. Commercial fishermen are extremely grateful to Secretary Bernhardt and his agency for taking the time to review the DEIS with the elevated level of scrutiny that such a monumental decision deserves. His reputation for a tireless work ethic, steady leadership, and concern for working Americans and coastal fishing communities is proving to be exceedingly genuine.
So too, our members are greatly appreciative of NMFS’ cooperation with BOEM in reviewing and assisting with the fisheries-related analysis in the document. Its leadership and staff have overcome short timelines to provide expert feedback on the spatial, ecological, and economic needs of our fishing communities as well as those of our shared marine ecosystems. We hope that NMFS will acquire full funding to help it keep up with the process and construct the collaborative science necessary to eliminate uncertainty for both industries.
Despite the importance of our relationships, RODA has repeatedly expressed concern regarding several elements of the proposed Vineyard Wind project. Primarily we are concerned with its potential for setting a negative precedent if it proceeds in a way that does not fully minimize harm to sustainable commercial fishing practices. These concerns were raised early and often by RODA, our individual members, NMFS, and others.
To cite some examples:
- Fishing businesses provided their own proprietary datato project developers and BOEM as early as 2017 to support their requests for turbine spacing and orientation that would maximally accommodate fishing.
- Dozens of fishermen and others engaged in exhaustive meetingsand provided additional confidential information in order to “negotiate” for the designation of transit lanes through the New England wind energy areas.
- Fishery representatives have consistently asked the collection of even a few seasons’ worth of baseline surveys against which to measure the impacts of an offshore wind energy facility in order to inform the design of future projects (and BOEM’s own guidelines require such surveys to begin two years before construction). These requests were made early and often; in but one example, in 2012, the Fisheries Survival Fund commented on“the need for comprehensive baseline knowledge of the benthic biological environment . . . so that impacts of leasing, site assessment activities, and wind mill installation, maintenance, and decommissioning [for the Vineyard Wind project] can be assessed.” The Vineyard Wind draft studies plan was only submitted on February 25, 2019, and NMFS was asked to review it within four days. NMFS stated at the time that “the submitted plan lack[ed] sufficient detail and critical information to evaluate its efficacy.”
- RODA directly requestedthe developer to engage in an inclusive, transparent process to determine mitigation plans including disruption payments, if necessary.
These, and many other unresolved interactions are absent from the DEIS and current project plans. This input has not been delivered at the “eleventh hour” and all occurred well within BOEM’s permitting timeline during the appropriate comment periods and as soon as the information to inform them was publicly available.
Through the memorandum of understanding and the federal environmental review process, BOEM has been attentive to our concerns and a willing partner in working toward better long-term approaches to coexistence. That said, the mere citation of RODA’s concerns does not amount to the full evidence-based analysis that should be the basis of important federal decisions. The fishing industry remains resolute that the spacing and orientation of turbines within a project area is one of the primary factors in determining what fisheries impacts will be, and thus demands the utmost diligence in consideration and analysis.
It is furthermore unclear how Secretary Bernhardt could issue a decision on the DEIS, when critical impact categories such as fishing vessel transit, disruption payments, baseline ecological information, radar interference, and others are yet to be settled.How could one possibly know that the project is designed to maximize coexistence with fishing without knowing these project elements, especially when what is known—the proposed project layout—is not consistent with the best available information?
As one of the first US large infrastructure projects to be reviewed under the new “One Federal Decision” directive, and the first large-scale offshore wind energy proposal on the outer continental shelf, we do not envy the challenges this project and its regulators face. However, the decisions made can either be a model for public-private, interagency, and cross-sector coordination, or result in the perpetuation of conflict between fishing communities and developers and—worse—unnecessary damage to hard-working American citizens and our world-class marine resources. We urge everyone to do their due diligence and get it right.