The Department of Interior is preparing to sell the first West Coast offshore wind leases in Morro and Humboldt Bays. While this is good news, it is essential for Interior to strike the right balance between greenlighting clean energy projects and protecting the rich and diverse waters off the West Coast. The terms in these first West Coast wind leases will set an important precedent for the industry moving forward.
We at NRDC heartily support offshore wind. The pace of climate change is accelerating, and we have only a few years to change our trajectory. Offshore wind is a promising source of renewable energy, with West Coast waters offering significant wind generation potential. Wind energy has an important role to play in California’s future resource mix and will support a reliable, cost-effective, and affordable clean energy transition.
Still, it is essential to ensure that offshore wind proceeds in an environmentally responsible manner. Offshore wind is still a new industry, and the type of technology – floating wind turbines – needed for deep West Coast waters, is relatively untested.
The ocean ecosystem off the California coast is uniquely vibrant, supporting an array of marine mammals, sea turtles, sea birds, and many other species. Our waters also support a valuable fishing industry, and the cultural traditions and livelihoods of Native peoples. And many others enjoy the ocean in a multitude of ways. We need to make sure that the ocean stays healthy for future generations.
In our comments—developed with other West Coast environmental organizations and filed with the Department of Interior’s Bureau of Ocean Energy Management today—we urged the agency to take measures to carry out a robust analysis of environmental impacts and to ensure that developers abide by conditions that protect the environment.
We recommend that Interior conduct a comprehensive environmental review of the effects of offshore wind development along the California coast, including the effects of constructing and operating wind turbines. In addition, we recommend the Department require that prospective offshore wind developers:
- Abide by lease stipulations to prevent the entanglement of marine mammals, sea turtles, and other marine life, including designing platform infrastructure to minimize entanglement risk and using robust monitoring systems to detect entanglements if they do occur;
- Take measures to reduce the risk of vessel strikes of large whales and sea turtles, including by abiding by a 10 knot vessel speed limit and stationing observers on project-associated vessels to help spot protected species in time to avoid a collision;
- Minimize noise from siting, construction, and operation activities;
- Take measures to protect benthic habitat, including conducting detailed surveys during the site assessment and construction and operation phases, avoid intentional contact with rock outcroppings, seamounts, and deep-sea coral/sponge habitat, and where biogenic habitat cannot be avoided, develop a mitigation plan;
- Engage in robust monitoring, to develop data on bird and bat collisions, use lighting systems that minimize attraction of birds and bats, and develop strategies to minimize turbine collisions;
- Contribute to robust scientific research and develop monitoring plans, with particular attention to understanding impacts on noise, biophysical processes, oceanographic conditions like upwelling, and displacement of species; and
- Provide plans for adaptive management and compensatory mitigation, to ensure that precautionary measures are appropriately tailored as more data becomes available.
We also asked the Department of Interior to ensure that the developer incentives used in the lease sale process – bid credits, which make the price of securing a lease much cheaper for the developer – support environmental and community goals. In particular, we asked Interior to:
- Increase the cap on bid credits;
- Create a new category of bid credit, which would create a funding stream for research into the environmental effects of wind development, as well as best monitoring practices and mitigation mechanisms;
- Structure the bid credits for supply chain development and developing a trained labor force so that they truly support local economies; and
- Expand the community benefits agreement bid credit to more clearly support the work of local environmental justice organizations.
This is an exciting time for the development of renewable energy on the West Coast, with California taking a strong position as a climate champion and leader. We urge the Department of Interior to develop offshore wind responsibly from the start and make sure that the industry proceeds in an environmentally sustainable manner.