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Archive for the ‘Offshore Wind’ Category

BOEM/NOAA Right Whale and Offshore Wind Strategy (January 2024)

Posted in energy policy, Offshore Wind, tagged , , , , , , on January 29, 2024| 2 Comments »

North Atlantic Right Whale

Key takeaways after reviewing the BOEM/NOAA strategy document:

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:

Pictured below: density of NARWs near wind leases and hydrodynamic effects of turbines

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Floating turbine maintenance and California offshore wind development

Posted in California, decommissioning, Norway, Offshore Energy - General, Offshore Wind, UK, tagged , , , , , , on January 22, 2024| 1 Comment »

Hywind Scotland, Equinor

It’s prudent, if not imperative, to tow floating wind turbines to sheltered coastal locations for major maintenance. For that reason, Hywind, the world’s first floating wind farm will be offline for up to 4 months this summer.

Hywind Scotland‘s operator, Norwegian power giant Equinor, says that operational data has indicated that its wind turbines need work. The pilot project has been in operation since 2017.

The five Siemens Gamesa turbines will be towed to Norway this summer. An Equinor spokesperson said, “This is the first such operation for a floating farm, and the safest method to do this is to tow the turbines to shore and execute the operations in sheltered conditions.”

electrek

Published data indicate that Hywind has been the UK’s best performing offshore wind farm. Performance data for Hywind, and a chart illustrating the capacity factors since commissioning, are posted below. The 2024 capacity factor will, of course, be substantially reduced as a result of the essential offsite maintenance.

rolling 12 month capacity factor
ending 5/2022		life capacity
factor		age
(years)		installed
capacity
(MWp)		total elec
generated
(GWh)		power/
unit area spanned
(W/m2)
Hywind Scotland49.5%52.6%4.6306421.0
capacity factor = total energy generated/(hours since commissioning x capacity)

The first US floating turbines are expected to be at these California offshore leases, and Hywind operator Equinor is one of the lessees:

Given the financial challenges facing the offshore wind industry, the still emerging technology, and the risks inherent in California offshore development, the amounts bid on these leases only 13 months ago are stunning.

Some Central Coast residents are not enamoured with “another attempt to industrialize the coast.” Although the turbines will be >20 miles offshore, they will have to be towed to shore for major maintenance. For the Central California leases, nearby harbor areas like Morro Bay (pictured below) would be overwhelmed by the large structures and the maintenance and repair operations. Towing the towers to LA/Long Beach, albeit rather distant from the leases, would seem to be the preferred option for such work.

Ironically, a report for BOEM, points to synergies between the offshore wind industry and oil and gas decommissioning industry. Such synergies will only be possible if longstanding oil and gas decommissioning obstacles are satisfactorily addressed and the offshore wind projects proceed as planned.

Which will come first – platform decommissioning or wind turbine commissioning? For those young enough to find out, what is the over-under for the years until (1) half of those platforms are decommissioned, and (2) half of the wind turbines commissioned? Any number <10 is unrealistic for either.

Morro Bay Harbor

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Precedent setting financial assurance waiver significantly increases the public’s risk exposure

Posted in decommissioning, energy policy, Offshore Energy - General, Offshore Wind, tagged , , , , on January 18, 2024| 10 Comments »

Vineyard Wind project

BOEM is charged with protecting the public from financial risks associated with the decommissioning of offshore facilities. Previous posts have addressed oil and gas facility decommissioning issues and proposed revisions to BOEM’s financial assurance regulations for those operations.

Recent disclosures indicate that BOEM, which very publicly promotes the offshore wind projects that it regulates, has waived a fundamental financial assurance requirement at the request of Vineyard Wind (approval letter attached). Given its broad applicability, this precedential waiver could have the effect of revising a significant provision of the offshore wind decommissioning regulations without public review and comment.

The issue is the “pay as you build” financial assurance requirement at 30 CFR § 585.516, which was waived by BOEM. This requirement, which is intended to project the public from decommissioning liability, is fair and reasonable given that wind developers must only provide financial assurance “in accordance with the number of facilities installed or being installed.” Companies that don’t have sufficient financial strength to comply with this requirement should not be installing and operating offshore wind turbines.

Vineyard Wind was either unable or unwilling to comply with the requirement. They instead requested to defer providing the full amount of the required financial assurance until year 15 of actual operations. The waiver changes “provide assurance when you install” to provide assurance 15 years after installation if everything goes as planned (hoped?).

After their waiver request was denied in 2017, Vineyard Wind resubmitted the request in 2021 seeking a favorable decision from an administration concerned that project cancellation or delay might tarnish the program that they were enthusiastically promoting.

BOEM (as directed from above?) granted the waiver, citing the general departure authority at 30 CFR § 585.103. However, that authority is intended for special situations, not for broadly applicable waivers that have the effect of revising the regulations without the public review required by the Administrative Procedures Act and Executive Orders 12866 and 13563.

There are no criteria in the Vineyard Wind waiver approval that could not apply to other wind developers. Vineyard Wind has simply committed to the same “risk-reduction factors” that apply to all offshore wind projects: damage insurance, the “use of proven turbine technology,” and long-term power purchase agreements. How could BOEM deny the same request from other companies?

It’s noteworthy that the regulations specific to financial assurance at 30 CFR § 585.516 provide no criteria for waiving the assurance requirements; nor do the regulations provide for the 15-year payment plan approved by BOEM. Given the precedential nature of the BOEM action and its enormous financial implications, a revision to the decommissioning regulations that provides criteria for such payment schemes should be promulgating before any similar departures are approved.

In light of the waiver, the public will likely incur substantial costs if Vineyard Wind fails, walks away, doesn’t fully fund their decommissioning account in a timely manner, or seeks new concessions after some or all of the 62 turbines have been installed.

Given the decommissioning obligations, what company would want to step in and assume responsibility for a failing project 10-15 years from now? What happens if Vineyard Wind’s project revenues don’t meet expectations and contributions to their decommissioning account are insufficient or used improperly? More concessions? We’ve seen this dance before.

Whether the project is for oil, gas, or wind energy, protecting the public from decommissioning liabilities should always be prioritized over facilitating development.

vineyard-wind-financial-assurance-deferralDownload

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DOI publishes backhanded 5 year leasing plan

Posted in energy policy, Gulf of Mexico, Offshore Energy - General, Offshore Wind, tagged , , on December 18, 2023| Leave a Comment »

The announcement boasts about “the fewest oil and gas lease sales in history” while seemingly apologizing for holding any sales at all.

Consistent with the requirements of the Inflation Reduction Act (IRA) concerning offshore conventional and renewable energy leasing, the Department of the Interior today published the final 2024–2029 National Outer Continental Shelf Oil and Gas Leasing Program (Program) with the fewest oil and gas lease sales in history.

These three lease sales are the minimum number that will enable the Interior Department’s offshore wind energy program to continue issuing leases in a way that will ensure continued progress towards the Administration’s goal of 30 gigawatts of offshore wind by 2030.  

DOI

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Important NOAA Woods Hole study: “Establishing baselines for predicting change in ambient sound metrics, marine mammal, and vessel occurrence within a US offshore wind energy area”

Posted in energy policy, Georges Bank, Offshore Wind, tagged , , , , , on December 18, 2023| Leave a Comment »

This impressive NOAA study confirms the importance of Nantucket Shoals as a feeding ground for right whales and implies a need for protective measures in months (October through December) when the existing restrictions do not apply.

“The importance of Nantucket Shoals as a feeding ground for the critically endangered North Atlantic right whales within the southern New England wind energy is well understood (Leiter et al., 2017; Quintana-Rizzo et al., 2021; Estabrook et al., 2022). Similarly, year round presence of this species has been demonstrated since as early as 2011 (Quintana-Rizzo et al., 2021; Estabrook et al., 2022), showing that North Atlantic right whales have consistently used this region for well over a decade. Currently, the National Marine Fisheries Services and Bureau of Ocean Energy Managements policy is to exclude pile driving during the months of January through April in the southern New England wind energy area. Evaluation of the need for further management protections are needed for North Atlantic right whales especially in October through December, along with further assessment of risk to this species (Southall et al., 2023).

A map of the southern New England planned offshore wind energy lease areas off the East Coast of the United States (insert). Passive acoustic recorders (SoundTrap and F-POD recorders) were deployed for varying time periods (see Table 1) between January 2020 and November 2022 at seven sites surrounding the wind energy areas.

Note (below) the acoustic presence of the North Atlantic Right Whale (NARW) from Oct. through April.

Weekly acoustic presence summary of eight cetacean species (harbour porpoise, sperm whale, humpback whale, minke whale, North Atlantic right whale (NARW), sei whale, fin whale, blue whale) and one family (Delphinid sp.). The boxplots represent the median number of days of acoustic presence per calendar week across all data at four recording sites, in the southern New England offshore wind energy area. Only recorders with 2 or more years of data (NS01, NS02, COX01, and COX02) were used. Horizontal lines within the boxes indicate the median, box boundaries indicate the 25th (lower quartile) and 75th (upper quartile) percentiles, vertical lines indicate the largest (upper whisker) and smallest (lower whisker) values no further than 1.5 times the interquartile range, and black dots represent outliers.

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Perhaps a bit less offshore wind hyperbole would be prudent

Posted in energy policy, Offshore Wind, Regulation, tagged , , on December 11, 2023| 1 Comment »

BOEM diminishes the credibility of their important (and generally excellent) scientific, lease administration, and regulatory work with over-the-top wind energy promotion. The tweet below is a recent example.

This is not a good look for the bureau that is expected to objectively evaluate offshore wind projects. Leave the hype to the wind industry and its NGO supporters.

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NAS study identifies potential ecological impacts of offshore wind turbines and calls for robust monitoring

Posted in Offshore Wind, Wind Energy, tagged , , , , , , on November 15, 2023| Leave a Comment »

Study: Potential Hydrodynamic Impacts of Offshore Wind Energy on Nantucket Shoals Regional Ecology: An Evaluation from Wind to Whales, National Academies of Sciences, Engineering, and Medicine.

Comments:

  • Kudos to BOEM for sponsoring this important study which identifies the potential ecological effects of offshore wind farms on the endangered North Atlantic Right Whale.
  • BOEM must now consider, and presumably implement, the committee’s recommendations. This could prove to be especially challenging given BOEM’s prominent wind advocacy role.
  • All 9 of the study committee members are scientists with appropriate backgrounds and specialties (see Appendix A of the report).
  • As a rule, the NAS notes potential conflicts of interest in the biographical statements. Two possible conflicts were identified: one committee member was a “compensated member of a review panel for Ortsted’s Offshore Wind Research Plan in 2021,” and another works for a firm that “has been partially funded by offshore wind development companies.”
  • The panel recommends robust monitoring during all phases of wind development and operations in the North Atlantic region. Is that sufficient given that hundreds of turbines could be installed before the data have been acquired and analyzed?
  • The concerns raised by the NAS committee are not new. 18 months ago, NOAA’s Chief of Protected Species cited some of the same concerns in recommending a conservation buffer zone adjacent to Nantucket Shoals.

. Background graphics, excerpts, and recommendations are pasted below.

Important excerpts:

  • p.2: A single offshore wind turbine can alter local hydrodynamics by interrupting circulation processes through a wake effect and induce turbulence in the water column surrounding and downstream of the turbine supporting structure, the pile. Moving away from single turbine effects and looking at arrays of turbines in a wind farm or at multiple adjacent offshore wind farms, these effects become more complex with implications for both local and regional circulation.
  • p.4: At the wind farm scale, the potential impacts include reductions in ocean current speeds, stratification, ocean surface wind speed, and deflection of the pycnocline. At the regional scale, perturbations due to offshore wind turbines are difficult to quantify because of the natural processes that drive significant environmental variability across the region.
  • p.6: Recommendation: The Bureau of Ocean Energy Management, National Oceanic Atmospheric Administration, and others should support, and where possible require, the collection of oceanographic and ecological observations through robust integrated monitoring programs within the Nantucket Shoals region and in the region surrounding wind energy areas before and during all phases of wind energy development: surveying, construction, operation, and decommissioning. This is especially important as right whale use of the Nantucket Shoals region continues to evolve due to oceanographic changes and/or the activities and conditions relevant to offshore wind farms.
  • p.7: Recommendation: The Bureau of Ocean Energy Management, National Oceanic Atmospheric Administration, and others should support, and where possible require, oceanographic and ecological modeling of the Nantucket Shoals region before and during all phases of wind energy development: surveying, construction, operation, and decommissioning. This critical information will help guide regional policies that protect right whales and improve predictions of ecological impacts from wind development at other lease sites.

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Ouch! Orsted scraps Ocean Wind 1 and 2!

Posted in energy policy, Offshore Wind, Wind Energy, tagged , , , , , on November 1, 2023| Leave a Comment »

NJ Governor Murphy, an offshore wind promoter, is not pleased:

“Today’s decision by Orsted to abandon its commitments to New Jersey is outrageous and calls into question the company’s credibility and competence,” the Democratic governor said. “As recently as several weeks ago, the company made public statements regarding the viability and progress of the Ocean Wind I project.”

6ABC NJ

Perhaps the Governor’s credibility and competence is also taking a hit, as is staking the State’s energy future on highly uncertain, intermittent, and facility-intensive power systems. .

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Extravagant wind lease bidding is looking even more nonsensical as power purchase agreements are terminated

Posted in climate, energy policy, Offshore Wind, Uncategorized, tagged , , , , , on September 20, 2023| Leave a Comment »

A BOE post from last December commented on the seemingly irrational bidding for Atlantic and Pacific wind leases. More recent posts have reported on the woes of Atlantic leaseholders.

Two Atlantic lessees, Commonwealth Wind and SouthCoast Wind, which paid $135 million for each of their North Atlantic leases, have now agreed to pay $48 million and $60 million respectively to cancel their power purchase agreements with electric utilities. Perhaps the effective date of these leases (see below) reflects on the wisdom of their purchase.🍋

Both Commonwealth Wind and SouthCoast Wind are hoping to rebid their projects in a Massachusetts offshore wind procurement scheduled for next year. 

Commonwealth Magazine

Some northeast states and their public utilities may be in a bit of a bind. Either they accept higher electric rates and the likely public backlash, or they deviate from their staunch anti-gas, anti-nuclear orthodoxy. Similarly, oil companies that have invested heavily in offshore wind may find that they are not just less profitable, but (even) less popular.

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Comparing the operating restrictions for the Right whale (Atlantic wind) and Rice’s whale (Gulf of Mexico oil and gas)

Posted in energy policy, Gulf of Mexico, Offshore Energy - General, Offshore Wind, Regulation, tagged , , , , , on September 11, 2023| 2 Comments »

Right whale – Atlantic
Rice’s whale – Gulf of Mexico

Both species are endangered, but the operating restrictions differ significantly:

North Atlantic wind leases: right whale restrictions GoM Lease sale 261: Rice’s whale restrictions
No leasing prohibitions or turbine-free areas have been established despite concerns raised by NOAA (see attached letter)All of the expanded Rice’s whale area is excluded from leasing (i.e. the entire area between the 100 and 400 m isobaths across the GoM)
seasonal 10 kt max speed for vessels > 65′year round 10 kt max for all vessels
vessel separation distance of 500 m for any sighted right whale or unidentified large marine mammalseparation distance of 500 m for any sighted Rice’s whale; if unsure, must assume whale is Rice’s
no visibility restrictions for vessel operationsvessels must avoid transit between dusk and dawn and other times of low visibility
no automatic identification system (AIS) requirementsvessels > 65′ must have AIS functioning at all times
no documentation requirementsmust maintain records to document compliance

Note (below) the proximity of existing and planned wind leases to moderate to high density RIght whale areas compared to the more speculative expanded Rice’s whale area in the central and western GoM that is predicted based on passive acoustic recordings.

ur1-2023-000009_10_17_2022Download

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