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Archive for the ‘Offshore Wind’ Category

North Atlantic Right Whale

A new NOAA biological opinion finds that that pile-driving noise associated with the Vineyard Wind project is likely to adversely affect, but not likely to jeopardize, the continued existence of whales, fish or sea turtles listed under the Endangered Species Act (ESA).

This opinion was predictable. On the one hand, denying the adverse effects from extensive pile driving would have been unacceptable to NOAA scientists. On the other hand, a jeopardy finding would have been unacceptable to their political leadership.

If you are wondering how NOAA managed to thread that needle, you will have to wait until their report is publicly available. On Aug. 23, NOAA said the opinion would be available in their library in about 10 days, but the opinion has still not been posted. How do you announce such significant findings without, at the same time, releasing the report?

Understandably, the Nantucket environmental organization ACK for whales is not pleased with either NOAA’s announcement or their failure to release the report:

We are disappointed NOAA announced the conclusions of its bi-op on the Vineyard Wind 1 construction without releasing the report or the data on which it relied,” ACK For Whales stated. “NOAA’s own data show that in 2023, there were 151 marine mammal strandings in Massachusetts alone with 75 occurring from Jun 2023 to Dec 2023, the months that pile driving was active. This compares to 77 strandings for all of 2015, before OSW activity started – essentially a 100 percent increase. Most of those strandings in 2023 (n=55) occurred from Oct to Dec when VW was racing to get foundations installed. Out of the 47 bases installed in 2023, 68 percent were installed in the last three months of the year.”

In January, BOE raised concerns about the collaborative BOEM-NOAA-wind industry strategy to protect the right whale. Per that strategy, BOEM and NOAA view themselves as partners with the wind industry. Is this biological opinion an example of NOAA working with their partners in accordance with their joint strategy? 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.

The sharp contrasts between the operating restrictions for the right whale (Atlantic wind) and the Rice’s whale (Gulf of Mexico oil and gas) demonstrate the inconsistencies in ESA regulation. Are major energy companies partners when developing wind projects and adversaries when producing oil and gas?

Lastly, a letter from NOAA’s Lead Biologist that is attached to that post further points to a disconnect between scientific concerns and wind energy regulatory policy, and is thus germane to this discussion.

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In response to a lawsuit filed by the Sierra Club et al, a Federal judge in Maryland vacated a 2020 biological opinion by the National Marine Fisheries Service (part of NOAA) that addressed risks to endangered species, most notably Rice’s whale, from oil and gas operations in the Gulf of Mexico. The decision by Federal Judge Deborah Boardman, who was appointed to her position in 2021, is attached.

Judge Boardman’s ruling is effective on Dec. 20, 2024. After that date, no new GoM leases may be issued and no new operating plans may be approved pending a new biological opinion. Existing GoM operations could also be affected. In other words, the ruling could have unprecedented effects on the OCS oil and gas program. (If you wonder how a Maryland judge can issue a ruling that could have major consequences for Louisiana and Texas, it is presumably because NOAA’s headquarters office is in Silver Spring, MD.)

The biological opinion process will likely be lengthy given the political considerations in an election year and the prospects for related litigation.

The judge’s ruling could also affect wind leasing in a manner that was perhaps unforeseen. Offshore wind leasing, which the plaintiffs strongly support despite the risks to the critically endangered North Atlantic Right Whale, could be delayed. Per a provision in the “Inflation Reduction Act,” no offshore wind leases may be issued after 12/20/2024, the one year anniversary of the last oil and gas lease sale (no. 261). Ironically, this is the same date as the effective date of the judge’s ruling.

The judge’s decision will likely further delay the next oil and gas lease sale (no. 262) well into 2025 or later, and extend the pause in issuing wind leases that begins on 12/20/2024. Perhaps with that in mind, BOEM has been forging ahead with wind auctions despite the troubling Vineyard Wind blade failure, economic challenges for the wind industry, and growing opposition from coastal residents. An editorial by the publisher of Nantucket Magazine expresses concerns that should not be overlooked in the rush to auction wind leases.

(More on a new biological opinion related to the Right Whale in a future post.)

wsj article

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Culzean facilities

Total has announced plans to install a 3 MW floating wind turbine 2 km west of the Culzean platform, 220 km off the coast of Scotland. This turbine, expected to be fully operational by the end of 2025, will supply around 20% of Culzean’s power requirement. This project is interesting from an R&D standpoint, but makes little sense otherwise. Here’s why:

  • Culzean is a gas condensate field that is capable of meeting 5% of the UK’s gas demand. There is thus ample produced gas to reliably and economically power the platform.
  • Gas will be required to meet 80% of the power requirement even after the wind turbine is operating.
  • In light of installation, maintenance, and decommissioning costs for the floating turbine, the cost of the intermittent wind power will no doubt be much higher than the cost of the power generated by platform gas.
  • Some tax benefits may be associated with adding the wind turbine, but this won’t affect the real costs, other than to perhaps make them higher.
  • In addition to affecting profitability, higher operational costs could reduce the ultimate recovery of gas and condensate from the field.
  • Gas not consumed at the offshore facilities will be marketed and consumed onshore, so there is essentially no net reduction in global CO2 emissions.
  • As JL Daeschler reminds me, the floating turbine complicates operations and could create safety issues: obstruction for helicopters and supply boats to avoid, trenching and installing power cable in a spare “J” tube, and feeding power to an electrical distribution system in accordance with standards and platform specifications. As JL notes, “I think we have plenty to do offshore already!”
  • And what if there are mooring failures and the turbine drifts toward the platforms? Turbine blade failures?
  • Bottom line: adding costs and risks for no apparent benefit.

See a related post on platform electrification in Norway.

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  • 10/31/2023: Citing economic factors, Orsted announces they “will cease development of the Ocean Wind 1 and Ocean Wind 2 projects.” (This should have resulted in termination of the leases.)
  • 1/19/2024: Orsted requests a 2 year “suspension of operations” to extend the leases they had ceased developing. (Presumably, this was a hedge with hopes of marketing the leases or getting better terms.)
  • 2/29/2024: True to form, BOEM approves the questionable 2 year suspension request. The approval letter was dated one day before the leases’ 8th anniversary when they would have presumably expired. (This is unconfirmed because the lease document and BOEM’s wind regulations lack clarity regarding lease expiration.)
  • BOEM’s approval letter (attached) curiously asserts that “suspension of the operations term is necessary for the Lessee’s full enjoyment of the lease in this circumstance to ensure sufficient time for project operations in support of the Project’s economic viability.” (Interesting wording that expresses the accommodative and promotional philosophy of the Federal wind program.)
  • 8/14/2024: The New Jersey Board of Public Utilities formally vacated all of its Orders that approved the Ocean Wind One and Ocean Wind Two offshore wind projects.
  • 8/14/2024: Cape May County comments that they are likely to amend their Federal Court filings “since the actions of the NJBPU would appear to have nullified Orsted’s federal permits.”
  • 8/27/2024: Despite the fact that Orsted has ceased development and New Jersey has vacated its approvals, the Federal leases are still active.
  • Good luck keeping an oil and gas lease if you cease development and request a suspension of operations. BSEE will rightfully deny your request.

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This real-life Spider-Man, seen on a Vineyard Wind turbine blade, is Tyler Paton. Tyler is an independent composite specialist who inspects and repairs blades on site. The Nantucket Current shared these images on X.

posted by Brian J @Mainsail23

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  • The “highly unusual and rare” talking point for turbine blade failures seems to have finally been discarded.
  • 3 new GE Haliade-X blades failed shortly after installation at Dogger Bank and Vineyard Wind. A total of only 48 turbines had been installed.
Offshore wind projectHaliade-X turbines installedblade failures
Dogger Bank272
Vineyard Wind211

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The operator of the wind farm released this short statement yesterday (8/22/2024):

We are aware of a blade failure which occurred this morning on an installed turbine at Dogger Bank A offshore wind farm, which is currently under construction. In line with safety procedures, the surrounding marine area has been restricted and relevant authorities notified. No one was injured or in the vicinity at the time the damage was sustained.

We are working closely with the turbine manufacturer, GE Vernova, which has initiated an investigation into the cause of the incident.

Further updates will be issued in due course as more information becomes available.

There have thus been at least 3 GE Vernova Haliade-X turbine failures at new offshore wind farms in 2024 – two at Dogger Bank and one at Vineyard Wind.

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In the wake of last week’s lackluster Atlantic wind lease auction (summarized above), an excellent Renewable Energy World article documents the sharp decline in participation and bidding since the massive February 2022 sale of 6 leases offshore NY and NJ. That sale garnered bids ranging from $285 million to an astounding $1.1 billion, with total high bids of $4.37 billion! The sale was touted as the “nation’s highest grossing competitive energy lease sale in history.” The extravagant bidding, which made little sense then, seems downright irrational now.

Even the December 2022 California offshore lease sale, where development will be dependent on more expensive floating turbines, attracted substantially higher bids for leases (5) smaller than those auctioned last week.

The highly promoted Gulf of Mexico wind auctions were busts with the first sale receiving only one bid for $6.5 million and the second being cancelled due to lack of interest.

Major oil companies like bp and Shell seem to have exited the market for new US offshore wind leases. That leaves Equinor (2/3 Norwegian govt ownership) as the only major oil company pursuing US offshore wind leases.

In just 2 years, cost increases, coastal resident opposition, a troubling blade failure, and developer uncertainty have dramatically changed the outlook for US offshore wind. Nonetheless, the Administration’s wind advocates continue to sing from the same song sheet:

“Today’s lease sale reflects the forward momentum we are seeing to power millions of American homes with clean energy and create good-paying, climate jobs,” said White House National Climate Advisor Ali Zaidi. “With nine commercial-scale projects approved in the last three years and more to go, we are using every available tool to grow the American offshore wind industry as we strengthen the nation’s power grid and tackle the climate crisis.”

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A close-up of the damaged GE Haliade-X turbine blade at the Vineyard Wind farm in late July. Photo by Burton Balkind

From the Nantucket Current:

Additionally, ultimate authority over the wind farm remained unclear, with various federal agencies claiming responsibility over different portions of the permitting, licensing, review, and operation of the wind farm.

“Sometimes I have a hard time figuring out, who do we talk to? Who is going to keep us safe? Who is the responsible boss here? Who is going to make the hard decision?” Select Board member Matt Fee asked.

As previously discussed, regulatory fragmentation is a safety and environmental risk factor.

Causes of regulatory fragmentation:

  • Separate legislation granting redundant or overlapping authority to different departments or agencies.
  • Legislation that is non-specific, assigning broad authority to the President or cabinet level level officials, leaving it up to the bureaus to resolve.
  • Bi- and multi-lateral agreements like MOA’s and MOU’s, which are intended to “coordinate the redundancy,” often cause more confusion than they prevent, creating gaps in the process.
  • “Fixing” problems by adding redundancy.

The Dept. of the Interior’s division of responsibilities for offshore wind, which was finalized in January 2023, inexplicably assigns review and approval of Construction and Operations Plans to the Bureau of Ocean Energy Management (i.e. the land manager, lessor, and wind energy promoter) rather than the Bureau of Safety and Environmental Enforcement (i.e. the principal regulator of the activities described in those plans).

More significantly, the offshore wind responsibilities of the 2 bureaus are so intertwined (as is also the case for offshore oil and gas), that attempts to separate the functions have, at a minimum, created inefficiencies and increased regulatory and operational costs.

FTR, the idea that having the BOEM and BSEE functions combined in a single bureau, as was the case with the predecessor bureau (MMS), had anything to do with the Macondo blowout is a complete fallacy. Regarding the accusations that were made toward MMS, the Chief Counsel for the national commission that investigated the tragic incident found no evidence that ethical lapses on the part of MMS employees played any role in causing the blowout. 

There were important regulatory changes made after the Macondo blowout. These included capping stack requirements, mandatory safety management systems, and updated rules and standards for cementing/zonal isolation and blowout preventer systems. None of these improvements were precipitated by or dependent on the division of MMS into two bureaus.

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The Town of Nantucket would like to provide you with an important update regarding the controlled detachment of the Vineyard Wind turbine blade and the ongoing efforts to manage any resulting debris.

August 11, 8:00 PM – Early this morning, portions of the remaining hanging sections of the Vineyard Wind turbine blade detached from the hub. The controlled detachment follows a series of exercises conducted late last week to pitch the blade, which, in combination with storm winds, led to the safe separation of the sections below the root of the blade.

Vineyard Wind and GE Vernova are currently assessing the situation to determine if any remaining sections pose a risk of detachment. The root of the blade, still attached to the turbine, is being monitored, and we are informed that plans are in place for its removal. Vineyard Wind has maritime crews on site to secure and contain any debris immediately.

The U.S. Coast Guard continues to enforce a 500-meter safety exclusion zone around the turbine. Vineyard Wind is utilizing ocean current and wind pattern models to predict potential debris movement. Depending on wind direction, more debris could potentially arrive on Nantucket beaches over the next hours or days. The Town of Nantucket will provide updates when necessary.

Under a federal preservation order, Vineyard Wind is responsible for retaining all debris, and only their employees, contractors, or those appointed by town officials are authorized to handle and recover debris materials. We urge the public to avoid handling any debris.

REMINDER TO THE PUBLIC 

  • DO NOT put any debris in your home garbage. 
  • DO NOT bring the debris to the landfill. 
  • DO notify the proper authorities immediately if you have debris so they can remove it for analysis and proper disposal.

Only trained employees or contractors are responsible for collecting and removing the debris. To report any remaining debris, please contact:

  • Phone: 833-609-5768 
  • Reports of debris can also be sent to the cleanup contractor here. 

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