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Archive for the ‘Offshore Wind’ Category

Should wind leasing and development be paused until the Vineyard Wind investigation is completed?

Posted in energy policy, Gulf of Mexico, Offshore Energy - General, Offshore Wind, Regulation, tagged , , , , , on July 23, 2024| 1 Comment »

The Vineyard Wind turbine incident, which littered Nantucket beaches, has also tarnished the US offshore wind program. BSEE has prudently halted Vineyard Wind operations and construction pending an investigation into the blade failure.

Offshore wind development is structure rich, so public confidence in the design of turbines and support platforms is critical. BOEM lists 37 active wind leases on the US OCS. Most of these leases have not yet reached the construction phase. A hold on the approval of any Construction and Operations Plans would seem to be appropriate pending completion of the Vineyard Wind investigations.

Per the leasing schedule below, BOEM intends to hold 4 wind sales during the remainder of 2024, all within a 3 month period. Only 1 sale is scheduled for each of the following 2 years. Deferring the 2024 sales until the investigations are complete would assist potential lessees by ensuring that the issues of concern were fully understood.

Unfortunately, BOEM’s failure to conduct a 2024 oil and gas lease sale has boxed in the wind program. The Inflation Reduction Act prohibits BOEM from issuing wind leases unless an oil and gas sale has been held within the previous year. Lease Sale 261 was held on 12/20/23 meaning that no wind leases may be issued after 12/20/24. BOEM has compressed the wind leasing schedule, presumably to beat the legislative deadline. It would have been better for both the oil and gas and the wind programs if at least one oil and gas sale had been held in 2024 as has been customary since the 1950s.

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Vineyard Wind’s financial assurance waiver cites robust insurance policies, proven technology, and guaranteed electricity sales

Posted in accidents, decommissioning, Offshore Wind, tagged , , , , , on July 22, 2024| 2 Comments »

Nantucket Current photo: damaged Vineyard Wind turbine

Pasted below is an excerpt from the BOEM letter waiving the“pay as you build” financial assurance requirement for the Vineyard Wind project.

Comments on the 3 risk reduction factors cited in the letter:

Factor 1: Those “robust insurance policies” may soon be tested given the costs associated with the turbine blade incident and potential law suits. (The notice pasted below informs that Nantucket officials will meet on Tuesday to consider litigation. A question for attorneys is the extent to which Nantucket is compromised by their good “Good Neighbor Agreement” with Vineyard Wind. That agreement essentially calls on Nantucket to promote the Vineyard Wind projects in return for payments that seem modest relative to the economic benefits from tourism and fishing.)

Factor 2: To the extent that GE Vernova Haliade-X 13 megawatt turbines are proven technology (and that is very much in doubt), the use of proven technology doesn’t prevent premature abandonment associated with unexpected incidents.

Factor 3: Reliable power generation and predictable long-term income remain to be demonstrated.

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Vineyard Wind: regulatory observations

Posted in accidents, Offshore Wind, tagged , , , , on July 19, 2024| 1 Comment »

Nantucket Current photo: Vineyard Wind turbine AW38 with a damaged blade that has caused thousands of pieces of debris to wash ashore on Nantucket since Tuesday.

Vineyard Wind statement (7/18):

  • “This morning, a significant part of the remaining GE Vernova blade detached from the turbine. Maritime crews were onsite overnight preparing to respond to this development, though current weather conditions create a difficult working environment.”
  • “We are staying apprised of GE Vernova’s efforts to manage the situation, including the removal and recovery of the remaining blade attached to the turbine.”
  • Staying apprised? As operator, Vineyard Wind is fully responsible. This is their situation to manage.

BSEE statement:

  • BSEE has ordered Vineyard Wind to suspend power production and wind turbine generator construction.
  • Kudos to BSEE for their decisive and timely action. They need to better understand what happened before allowing operations and construction to continue.
  • Imagine the pressure on the regulator if the project was providing a significant portion of the region’s electricity.
  • BSEE’s comment that there has been “no harm to any marine resources or mammals from the incident” is premature given the extensive marine debris and the associated risks to mammals.

What about the CVA?

  • The regulations at 30 CFR § 285.707-712 assign important responsibilities to Certified Verification Agents (CVAs), independent third parties with established technical expertise. These responsibilities include detailed reviews of the design, fabrication, and installation plans.
  • Oddly, the CVA’s “Statement of Qualifications” and “Scope of Work and Verification Plan” have been redacted in their entirety from Vineyard Wind’s Construction and Operations Plan (COP) (see Appendix I-C and I-D).
  • Who was the CVA and why was that important information redacted?
  • Were any of the CVA requirements waived per 258.705?

BOEM:

  • Will BOEM, the lessor and Federal wind program manager, be making a statement? Will they be reassessing their COP review procedures?
  • BOEM should temper their over-the-top promotion of offshore wind. The complete shutdown of the first utility scale offshore wind farm heightens public concerns about the intermittency of this power source, and the need for reliable backup sources.

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Debris poses a significant risk to marine mammals

Posted in accidents, Offshore Wind, tagged , , , , on July 17, 2024| 1 Comment »

In the wake of the Vineyard Wind turbine blade incident, it’s important to note that marine debris is a significant risk factor for mammals. This is a particular concern for baleen whales, like the endangered right whale, which filter large amounts of water. Per NOAA:

Marine Mammals: Many species of marine mammals have also been confirmed to eat marine debris. A review by Kühn and van Franeker found that 69 species of marine mammals have been found to ingest debris – that’s 56% of all marine mammals! This includes 44 species of odontocetes (toothed whales), manatees, and multiple seal species. Marine mammals are highly protected, which can make it difficult to research them. Most research on marine mammals takes place after an animal dies, making it difficult to understand what marine debris live animals eat. However, we do know that because baleen whales filter extremely large amounts of water while feeding, they may get plastic debris entangled in their baleen plates. 

An Argentinian study describes the “finding of plastic litter in the digestive tract of a southern right whale (Eubalaena australis) juvenile male, which was found dead on the shores of Golfo Nuevo, Chubut, Argentina in 2014.”

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Vineyard Wind operations shut down

Posted in accidents, Offshore Wind, tagged , , , on July 17, 2024| 1 Comment »

Nantucket Current photo

Appropriate response by BSEE.

Late Tuesday afternoon, the Bureau of Safety and Environmental Enforcement said all operations are shut down until further notice.

“A team of BSEE experts is onsite to work closely with Vineyard Wind on an analysis of the cause of the incident and next steps,” the agency said in a statement.  

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Vineyard Wind turbine blade incident

Posted in accidents, Offshore Energy - General, Offshore Wind, tagged , , , , , , on July 17, 2024| 2 Comments »

Photo by Capt. Carl Bois shared with the Nantucket Current
Ack4whales photo of the damaged turbine

On Sunday (7/14), Capt. Carl Bois, of the fishing charter Topspin out of Nantucket, told the Current he noticed a significant amount of debris in the Vineyard Wind lease area.

“There was so much debris at the wind farm,” Bois said. “We covered many miles and only saw the debris at the wind farm site: big sheets of fiberglass with foam core and lots of loose foam.”

On Saturday night (7/13) the Coast Guard warned Mariners as follows: “Coast Guard received a report of 03 floating debris 10 meters by 2 meters in the vicinity of approximately 26 NM SE of Marthas Vineyard and 22 NM SW of Nantucket in position 40 59.559N 070 25.404W. All marines are requested to use extreme caution while transiting the area.“

On Monday (7/15), Vineyard Wind confirmed that a turbine blade incident occurred on 7/13: “On Saturday evening, Vineyard Wind experienced blade damage on a wind turbine in its offshore development area. No personnel or third parties were in the vicinity of the turbine at the time, and all employees of Vineyard Wind and its contractors are safe and secure.”

On 7/16, Vineyard Wind issued another statement advising that they were deploying teams to Nantucket to clean up debris from the incident.

Comments:

  • Not a good look for the first large-scale offshore wind project in the US.
  • It’s unclear what the status of operations was at the time of the incident.
  • Vineyard Wind seems to be passing the buck a bit when they note that “GE, as the project’s turbine and blade manufacturer and installation contractor, will now be conducting the analysis into the root cause of the incident.” While GE’s findings are critical, Vineyard Wind, as operator, is fully responsible and accountable for the incident and should be leading the analysis.
  • Was their a third party review of the turbine design?
  • Was the incident reported to BSEE, the safety regulator for offshore wind? State and local government?
  • BSEE and the Coast Guard should ensure that Vineyard Wind’s findings and their own independent report are made publicly available in a timely manner. Ditto for Safety Alerts.
  • What other incidents have occurred during offshore wind facility construction and operations?
  • In 2017, Vineyard Wind requested to defer providing the full amount of the required financial assurance until year 15 of actual operations. That request was denied, but was approved when resubmitted in 2021. The regulations have now been revised to allow such deferrals of financial assurance on all offshore wind projects.

Vineyard Wind is a joint venture between Avangrid, a Spanish company, and Copenhagen Infrastructure Partners. They were

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Offshore wind development is rich in structures. Are the financial assurance provisions adequate?

Posted in decommissioning, Offshore Wind, Regulation, tagged , , , , , , on July 10, 2024| 2 Comments »

BOEM’s land rush approach to offshore wind leasing will add up to 1086 turbine towers and 28 offshore substations (OSSs) in the Atlantic just from active projects with approved Records of Decision (RODs). (See the table below.) Another 17 active Atlantic commercial projects have yet to reach the ROD stage. Those projects should increase the total number of structures to >3000. Five more Atlantic wind lease sales are scheduled.

projectturbine towersoffshore substations
Coastal VA Offshore Wind2023
Revolution Wind1002
Sunrise Wind941
Atlantic Shores South200up to 10
Ocean Wind 198up to 3
Vineyard Wind 11002
Empire Wind 1 & 21472
New England Wind (phases 1&2)1505

Per the Construction and Operations Plan (COP) for Vineyard Wind, the topsides for a conventional electrical service platform (ESP) (also known as an offshore substation or OSS) are 45 x 70 x 38 m, which is larger in surface area than a typical 6-pile oil and gas platform (~30 x 30 m), and is comparable in size to a large jackup drilling rig.

The Atlantic Shores plan calls for 10 small, 5 medium, or 4 large OSSs. (Uncertainty regarding the number and types of structures seems rather common in wind COPs.) The large OSSs have topsides that are 90 m by 50 m and rise to 63 m above MLLW. These are large offshore structures whether for wind or oil and gas.

Vineyard Wind ESP

Despite the looming decommissioning obligations, BOEM’s financial assurance requirements have been relaxed to facilitate wind development.

Per BOEM, the “Rule to Streamline and Modernize Offshore Renewable Energy Development” is intended to “make offshore renewable energy development more efficient, [and] save billions of dollars. Unfortunately, the savings associated with relaxed financial assurance requirements translates to increased risk for power customers and taxpayers.

BOEM signaled their intentions on offshore wind (OSW) decommissioning three years ago when they granted a precedent setting financial assurance waiver to Vineyard Wind. Despite compelling concerns raised by commenters, the “streamlining” regulations codified this decision.

No one knows what the financial future will be for wind projects and the responsible companies. Financial assurance should therefore be established when the structures are installed, not years into the future as allowed by the revised regulations. What leverage will BOEM have then?

Nordsee One substation, Germany. Rystad Energy projects 137 new power substations offshore continental Europe this decade, requiring $20 billion in total investment.

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One of the first Americans on Utah Beach during D-Day …

Posted in energy policy, Offshore Wind, Uncategorized, tagged , , , , , on June 7, 2024| Leave a Comment »

…Rick Carrier became the first allied soldier to discover the Buchenwald concentration camp. The next day, April 11, 1945, he marched into the camp with Patton’s Third Army and liberated the prisoners.

More than a half century later, and after leading a successful effort to protect the American bald eagle, he was the first person to submit an offshore wind application to the Minerals Management Service.

Rick Carrier with life partner Lynn Ramsey, in Poland, following the 2012 March of the Living. Photo courtesy Lynn Ramsey.

Rick wanted nothing from the government except the opportunity to demonstrate his green hydrogen concept with a single turbine in the Atlantic. He did not ask for any subsidies or research grants. This war hero from the greatest generation just wanted to continue doing great things for the country and the world.

Unfortunately, the Energy Policy Act of 2005 had yet to be enacted, and the framework for permitting such projects had not been established. While we tried to find a way to make the project possible, the legal obstacles were too great.

It was an honor to have worked with Rick on his green hydrogen initiative. RIP.

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Offshore wind: New Bedford Light examines the glauconite challenge

Posted in decommissioning, Offshore Wind, tagged , , , , on May 22, 2024| 1 Comment »

Illustration credit: Kellen Riell / The New Bedford Light
Glauconite has been identified within the boundaries of lease areas marked with green. Credit: Kellen Riell / The New Bedford Light

Anastasia Lennon has published several informative articles in the New Bedford Light on the challenges posed by the presence of glauconite on North Atlantic wind leases. The above illustrations explain those challenges and identify where glauconite has been found to date. Per her latest article:

Preliminary geotechnical analysis for New England Wind, an Avangrid project, showed a risk of turbine pile foundation refusal in 50 of nearly 130 turbine locations, or about 40%, according to 2023 records obtained through a Freedom of Information Act request. 

The mineral’s behavior poses a “significant risk” to offshore wind development, said BOEM, the federal regulator of offshore wind, in a paper last year. 

The potential for foundation problems associated with glauconite and other geotechnical factors are among the reasons why decommissioning financial assurance should be demonstrated in full when turbines and other facilities are installed, not years later.

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Wind energy rule codifies increased financial risk for taxpayers

Posted in decommissioning, energy policy, hurricanes, Offshore Energy - General, Offshore Wind, tagged , , , , , , on May 13, 2024| Leave a Comment »

Decommissioning Vindeby wind project, Denmark

BOEM’s “Rule to Streamline and Modernize Offshore Renewable Energy Development” is intended to “make offshore renewable energy development more efficient, [and] save billions of dollars. Unfortunately, the savings associated with relaxed decommissioning financial assurance requirements translates to increased risk for customers and taxpayers.

BOEM signaled their intentions on offshore wind (OSW) decommissioning three years ago when they granted a precedent setting financial assurance waiver to Vineyard Wind. Despite compelling concerns raised by commenters, the “streamlining” regulations have codified this decision.

Cape May County, New Jersey, was among the commenters objecting to BOEM’s departure from the prudent “pay as you build” financial assurance requirement. The County commented as follows (full comment letter attached):

“[e]nergy-utility projects are in essence traditional public-private partnerships where technical and financial risks are transferred to the private sector in exchange for the opportunity to generate revenues and profit. Under the proposed rule, the Federal government is instead transferring risks associated with decommissioning to the consumer rather than to the private sector.”

Cape May added:

“[w]hile BOEM believes that if a developer becomes insolvent during commercial activity that a solvent entity would assume or purchase control, the County believes this is a risky assumption as the most likely reason for default is that a constructed wind farm developer is unable to meet its contractual obligations set forth under a Power Purchase Agreement (PPA) because its energy production revenues are not in excess of its operating costs. A change of hands would not remove these circumstances or make the project profitable.”

Cape May and others also commented on the threat of premature decommissioning as a result of storm damage. In response, BOEM asserts that these risks have been addressed in the latest standard for North American offshore wind turbines (Offshore Compliance Recommended Practices: 2022 Edition (OCRP-1-2022)). However, design standards, particularly those for offshore facilities, are not static. The recommended practice for OSW is likely to change multiple times in the coming years as storm, operating, and turbine performance data are updated and analyzed. The design standard for Gulf of Mexico platforms has been repeatedly refined and improved and is now in its 22nd edition.

In their response to public comments on the decommissioning risks, BOEM repeatedly asserts that they can adjust the amount and timing of required financial assurance as they monitor a lessee’s financial health. Unfortunately, a company’s finances can change quickly and BOEM’s options will be limited when it does. Increasing the financial burden on a struggling company that is providing power to a regional power grid will not be a simple proposition.

Strong comments from Cape May County:

boem-2023-0005-0138_attachment_1Download

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