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Archive for the ‘Offshore Wind’ Category

Decommissioning certainty? How so?

Posted in California, decommissioning, Gulf of Mexico, Offshore Energy - General, Offshore Wind, tagged , , , on April 25, 2023| Leave a Comment »

“BSEE will continue to evaluate the process for issuing decommissioning orders and will continue to issue decommissioning orders to jointly and severally liable parties on a case-by-case basis.“

Final decommissioning rule (preamble). 4/18/2023

Although the news release for BSEE’s final decommissioning rule asserts that the regulations “provide the certainty requested by industry,” that does not seem to be the case. The main change in the final rule was to delete the reverse chronological order (RCO) provision which called for issuing decommissioning orders to the most recent predecessor first. Instead, BSEE may continue to issue decommissioning orders arbitrarily.

While deleting the RCO provision may be advantageous for the regulator, and in some cases for the public, claiming that the decision provides certainty for industry is quite a stretch. BSEE may continue to issue a decommissioning order to anyone in the ownership chain, whether the company was a recent lessee or one that had owned the lease decades ago. Original or early lessees may be held liable for decommissioning old facilities regardless of subsequent damage, modifications, or neglected maintenance.

The absence of a defined procedure for issuing decommissioning orders may also expose BSEE to new legal challenges, particularly in cases where a company has not held the lease for decades. A 1988 letter from the Director of the Minerals Management Service to Amoco (attached below) explicitly relieves the assignor (predecessor) of decommissioning liability after the lease has been assigned. A revised bonding rule published on May 22, 1997 reversed that policy, but decommissioning liability for leases assigned prior to the 1997 rule may still be very much in question.

Another concern is the split jurisdiction for decommissioning between BSEE and BOEM. The financial, land management, operational, and environmental aspects of decommissioning are inextricably intertwined and attempts to divide these responsibilities between two bureaus with separate regulations is a prescription for gaps, overlap, inconsistency, inefficiency, disputes, and confusion. Decommissioning should be regulated holistically, not with separate “BOEM-only” and “BSEE-only” regulations.

Finally, wind facility decommissioning may prove to be even more challenging given the higher facility density and economic uncertainties. The regulatory regime needs to be clearly established early in the development phase.

Related posts:

1988-letterDownload

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Regulatory Theory 101: Good comment from “Save LBI” on BOEM’s Renewable Energy Modernization Rule

Posted in energy policy, Offshore Energy - General, Offshore Wind, tagged , , , , , , on April 18, 2023| Leave a Comment »

This comment from Save LBI (Long Beach Island, NJ) on BOEM’s Renewable Energy Modernization Rule (proposed) highlights an important regulatory policy consideration:

Promoting the offshore wind program is a very high BOEM priority. The bureau is charged with deploying 30 gigawatts of offshore wind energy capacity by 2030, which requires extensive advocacy. However, BOEM is also a core regulator for offshore wind projects, and the concern is that their regulatory role could be compromised by their advocacy priorities.

Per Notice to Lessees 2023 N-01, which arguably should have been published for public comment given its regulatory significance, BOEM has retained important responsibilities for wind project development and operations. These include review and approval of construction and operations plans, site assessment plans, and general activities plans. BOEM may also exercise enforcement authority through the issuance of violation notices and the assessment of civil penalties.

BOEM exists because in 2010 the Administration wanted to separate the OCS program’s leasing (sales/advocacy) and safety (regulatory/enforcement) functions. The intent was to avoid conflicting missions (or the appearance thereof) in the post-Macondo era. (More on this in an upcoming post.)

Ironically, the Save LBI comment describes BSEE as “a distinct unit within BOEM.” That may seem to be the case, but BSEE is actually a separate bureau in the Department of the Interior.

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Correction

Posted in Offshore Wind, Wind Energy, tagged , , , on April 12, 2023| Leave a Comment »

On 12/14/2022 I posted that California North Floating LLC was a subsidiary of Copenhagen Infrastructure Partners (CIP), and RWE Offshore Wind Holdings, LLC, a German multinational energy company. Andrew Doba, Director of Communications, has informed me that California North Floating is owned solely by CIP, and is not affiliated with RWE in any way. That post has been updated. Many thanks to Andrew for the correction.

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Atlantic whale deaths:Imagine the furor if there were oil and gas operations in the region

Posted in climate, energy policy, Offshore Energy - General, Offshore Wind, tagged , , , on February 20, 2023| Leave a Comment »

While it’s highly unlikely that wind turbine siting activities are responsible for the alarming number of whale deaths, some of the vociferous wind industry defenders would have been among the first to point the finger at oil and gas operations if there were any in the US Atlantic.

Some quotes from a recent USA Today article followed by BOE comments:

“It’s just a cynical disinformation campaign,” said Greenpeace’s oceans director John Hocevar. “It doesn’t seem to worry them that it’s not based in any kind of evidence.” (Comment: World class chutzpah on the part of Greenpeace, the master of disinformation.)

Gib Brogan, a campaign director with Oceana, an international ocean advocacy group, said those opposed to wind power are using a spate of whale deaths in the area as an opportunity. (Comment: Does Oceana suddenly find this type of opportunism to be shocking?)

“Groups opposed to clean energy projects spread baseless misinformation that has been debunked by scientists and experts,” said JC Sandberg, chief advocacy officer with the American Clean Power Association, a renewable energy trade group. (Comments: Use of the term “clean energy” is clever advocacy that serves to discredit other forms of energy. All energy sources have pros and cons, environmentally and otherwise. Wind and solar have significant visual, space preemption, navigation, wildlife risk, and intermittency issues, and are heavily dependent on subsidies and mandates. When all issues are considered, one could argue, as we have, that offshore gas, particularly nonassociated gas, is perhaps the environmentally preferred energy alternative.)

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Standing Committee on Offshore Wind Energy and Fisheries (National Academies)

Posted in energy policy, Offshore Energy - General, Offshore Wind, tagged , , , on February 9, 2023| Leave a Comment »

The National Academies of Sciences, Engineering, and Medicine will establish a standing committee to provide ongoing assistance to the Department of the Interior’s Bureau of Ocean Energy Management (BOEM) in its efforts to manage development of the nation’s offshore wind energy resources and their potential effects on fisheries

NASEM

This seems to be a positive step and the committee members have excellent credentials, but how do you establish such a committee without any representation from the wind industry? Here are the 12 members of the committee.

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7 NJ/NY whale deaths in just over a month

Posted in Offshore Wind, Wind Energy, tagged , , , , on January 14, 2023| Leave a Comment »

OCNJDaily

While it’s unlikely that the whale strandings are the result of pre-construction activities for offshore wind development, greater transparency on the part of the developer and regulators would be helpful:

  • What surveys and other offshore activities are being conducted? Where?
  • What is the timeframe for these activities?
  • Any sightings of distressed whales?
  • Other anomalous observations?

Absent regular activity updates, accusations and protests are likely to continue and intensify.

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Despite big push from government, the offshore wind program struggles

Posted in energy policy, Offshore Energy - General, Offshore Wind, Uncategorized, tagged , , on January 2, 2023| Leave a Comment »

“Mom” (US govt) strongly and openly favors one child (offshore wind) over the other (offshore oil and gas). As a result, beneficial family synergy is not realized, and neither “child” reaches her full potential.

The wind program was intended to complement the oil and gas program, not replace it.

These articles highlight some of the challenges facing offshore wind:

  • WSJ: Soaring Costs Threaten U.S. Offshore-Wind Buildout
  • Bloomberg: US Ignored Own Scientists’ Warning in Backing Atlantic Wind Farm
  • NJ.com: Offshore wind is on N.J.’s horizon but activists worry of impact to whales, economy, the view

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Who are these companies?

Posted in California, energy, Offshore Wind, tagged , , , , , on December 14, 2022| Leave a Comment »

Only Equinor is a familiar name to the offshore oil and gas industry, so here are some blurbs about the other high bidders.

California North Floating, LLC, is a subsidiary of Copenhagen Infrastructure Partners (CIP). Since entering the US offshore market in 2016, CIP has built a leading offshore wind position through its affiliate Vineyard Offshore. This includes Vineyard Wind 1, the country’s first commercial scale offshore wind project which is currently under construction, as well as two lease areas under development totaling approximately 5.0 GW off the coast of Massachusetts and New York.

Central California Offshore Wind is managed by an East Coast offshore wind energy company, Ocean Winds North America LLC, which formed a joint venture with the Canada Pension Plan Investment Board to win the lease. Ocean Winds has more than 10 years of experience in floating offshore wind, most notably through the development and operation of Windfloat Atlantic (offshore Portugal), the world’s first fully commercially operational floating offshore wind farm

Equinor, a Norwegian company, is a major international oil and gas producer, an important wind energy investor, and a leader in the development of floating wind turbine technology. Equinor operates the Hywind Tampen floating offshore wind farm which will supply power to Norwegian offshore oil and gas fields.

Invenergy and its affiliated companies develop, own, and operate large-scale renewable and other clean energy generation and storage facilities in the Americas, Europe and Asia. Invenergy’s home office is located in Chicago, and it has regional development offices in the United States, Canada, Mexico, Spain, Japan, Poland, and Scotland.

RWE Renewables has experience covering the offshore and onshore wind energy value chain from development to construction and operation. These activities are the responsibility of two functional units, “Unit Renewables Europe & Australia” and “Unit Offshore Wind”, as well as the subsidiary RWE Renewables Americas. RWE Renewables also invests in large-scale solar projects and supports power producers, plant operators and other stakeholders in the development, construction and operation of photovoltaic and solar energy plants as well as in the construction of battery storage systems. The focus is on large-scale industrial projects.

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Offshore headwinds?

Posted in energy policy, Offshore Energy - General, Offshore Wind, tagged , , , , , , , on December 8, 2022| Leave a Comment »

Despite the spectacular 2022 lease sales, not all is rosy for US offshore wind development.

In 2011, then-Interior Secretary Ken Salazar said the Obama administration had set a goal of “10 gigawatts of offshore wind generating capacity by 2020 and 54 gigawatts by 2030.” How has that worked? Well, 11 years after Salazar’s speech, the US has seven turbines operating offshore with a total of capacity of 42 megawatts — or some 9,958 megawatts short of the goal laid out by Salazar.

Gordon Hughes, a professor of economics at the University of Edinburgh, has found that the output of Europe’s offshore wind turbines has been declining by about 4.5% per year. In a report titled “Wind Power Economics: Rhetoric and Reality,” published by the London-based Renewable Energy Foundation in 2020, Hughes concluded that declining output will result in higher operating costs that will start to exceed revenues “after 12 or 15 years.

Forbes

Opposition to NJ offshore wind projects dominate DEP hearing

…addressing climate change through ocean “industrialization” using an “inefficient, expensive and largely untested strategy” was not the right path forward – Kari Martin, Clean Ocean Action

“By undertaking an industrialization project this big, it far outweighs any (climate change) benefit anybody’s ever talked about, or even tried to quantify,” he said. “The harms of this undertaking is, in my view, far worse than any benefits we could realize.” – Michael Dean, Middletown, NJ

Offshore Wind Farms Change Marine Ecosystems

In their latest publication, (scientists at the Helmholtz-Zentrum Hereon) now show that large-scale wind farms can strongly influence marine primary production as well as the oxygen levels in and beyond the wind farm areas. Their results were published in the journal Communications Earth & Environment.

… For example, Nils Christiansen’s team proved that wake turbulences—air vortices caused by wind turbines—change the flow and stratification of the water beneath them. But the climate just above the sea surface is also being permanently changed, as another team led by Dr. Naveed Akhtar was able to show.

PHYS.org

Annual mean response of net primary productions (netPP) to atmospheric changes due to offshore wind farms

More:

Commonwealth Wind project paused indefinitely

Park City Wind project delayed

RODA files a motion for a summary judgement in its lawsuit over approval of the Vineyard Wind 1 project, touted as the nation’s first commercial scale offshore project.

Discouraging Spectator article on UK onshore wind.

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Wind sale bidding continues to baffle and amaze

Posted in California, energy policy, Offshore Wind, tagged , on December 7, 2022| Leave a Comment »

California offshore wind sale: 5 leases, $757.1 million in high bids

The California wind sale bidding, while lower than the record Atlantic sale in February, was extraordinary given that the 5 leases are relatively distant from shore (20+ miles) and in water depths (537 to 1284 m) that dictate the use of floating turbines. Generous subsidies, credits, and State mandates no doubt contributed to the seemingly inflated bidding, as did an auction system that is designed to maximize bonus payments.

Given the slow progress in US offshore wind development, the setbacks the industry is experiencing, the added challenges associated with commercial deepwater development, the potential cost burden on taxpayers and power customers, and the government’s financial and policy support, a more development-friendly leasing system would seem to be prudent. BOEM took a step in that direction with the with the limited training and supply chain credits provided for in the Sale Notice, but fundamental changes in the auction system may be desirable.

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