Key takeaways after reviewing the BOEM/NOAA strategy document:
- The document effectively summarizes the dire state of the North Atlantic Right Whale.
- The BOEM/NOAA strategy is to monitor and further assess the impacts.
- The need for mitigation will be determined through collaborative processes.
- This industry-friendly strategy contrasts sharply with the restrictive operating requirements proposed for the more speculative Rice’s whale expanded area in the Gulf of Mexico.
NARW status (pages 7-14):
- Roughly 237 NARWs have died since the population peaked at 481 in 2011, exceeding the potential biological removal (PBR) level on average by more than 40 times for the past 5 years (Pace III et al. 2021).
- Human-caused mortality is so high that no adult NARW has been confirmed to have died from natural causes in several decades (Hayes et al. 2023).
- Most NARWs have a low probability of surviving past 40 years even though the NARW can live up to a century.
- There were no first-time mothers in 2022.
- About 42% of the population is known to be in reduced health (Hamilton et al. 2021)
- A NASEM study confirmed that offshore wind has the potential to alter local and regional hydrodynamics
- “Effects to NARWs could result from stressors generated from a single project; there is potential for these effects to be compounded by exposure to multiple projects.” (p. 14)
BOEM/NOAA strategy:
- No new mitigation is recommended pending further study.
- “BOEM and NOAA Fisheries will work together alongside our partners (including the OSW industry) to further develop the information and science the agencies will use to inform their decisions to responsibly develop OSW while protecting and recovering NARWs.” (Comment: While regulator-industry collaboration is essential for effective offshore development, be it wind or oil and gas, regulators and operating companies have distinctly different missions and responsibilities and should not be viewed as partners.)
- (p. 15): “As the OSW industry continues to grow and as projects begin construction, BOEM and NOAA Fisheries will continue to work with our partners to evaluate existing strategies and to further collect and apply newly available information to inform future decisions. This Strategy is an integral step to organize BOEM, NOAA Fisheries, and their partners around a shared vision and clear path to effectively study and manage this issue moving forward.” (???)
- (p.17): BOEM will “attempt to avoid issuing new leases in areas that may impact potential high-value habitat and/or high use areas for important life history functions such as NARW foraging, migrating, mating, or calving. For areas that are leased, permitting activities should minimize any known or potential threat to NARWs and their habitats, and developers and BOEM should support research and monitoring.”
Questions:
- How are the NARW threats identified in the NASEM study being mitigated?
- What is the status of the Nantucket Shoals conservation buffer zone recommended by NOAA (see the May 2022 letter attached to linked post)?
- Why are the Rice’s whale litigants okay with the more compelling threat to the NARW?
- What happens if the hydrodynamic threats identified by the NASEM panel are confirmed?
- Why isn’t this collaborative approach being pursued in assessing and mitigating risks to the Rice’s whale?
- Can we expect the Federal government’s leading offshore wind promoter to impose restrictions that further weaken the economics of offshore wind development?
Pictured below: density of NARWs near wind leases and hydrodynamic effects of turbines
[…] Pollution Prevention, and More” delves into the details of offshore wind development. He recently reviewed the Bureau of Ocean Energy Management and National Oceanic and Atmospheric Administration Fisheries […]