The response by the Nantucket group’s attorneys is attached. Key excerpt:
“NMFS absurdly argues that agency officials, in preparing a biological opinion for a project, must ignore information about impacts on endangered species from other offshore wind turbine projects that are planned and in various stages of development and governmental review. Perhaps even more bizarrely, NMFS contends that, in preparing a biological opinion for a project, it must consider the cumulative impacts of planned state and local projects but ignore the impacts of planned federal projects.“
Forbes (USGS map of active wind turbines): “The U.S. Wind Turbine Database contains more than74,695 wind turbines built since 1980, spread between 1,699 wind power projects in 45 states. However, thousands of wind turbines are reaching the end of their operational lifespan and need to be either repowered to make way for updated (often larger) turbines or entirely decommissioned to allow for new uses of the land they occupy. Unfortunately, there is no uniform legal framework to regulate the steps involved, nor is there an accepted industry-wide set of best practices, and the environmental costs are considerable.”
Forbes: “As is often the case when new technologies come to market, unintended downstream consequences are not always immediately obvious to the players. Enthusiasm for clean energy initially pushed the first wind turbines into existence in the U.S. without considering the environmental and monetary costs that would be involved in either upgrading or bringing projects to a close later in their life cycle. “
From the Protect Our Coast – NJ Facebook page: “During his interview with Radio Host Dom Giordano on Monday, December 23, NJ Congressman Jeff VanDrew (pictured), stated an executive order, to be signed by President Trump on January 20, 2025 will place a 6 months pause on further construction of Offshore Wind Turbines while our new administration reviews all aspects of these highly controversial structures in our ocean.“
We’ll see what transpires, and if this post is accurate, await clarification and reactions.
The petitioners’ “sole argument” is rather compelling to this non-attorney. Given that multiple offshore wind projects are planned for Right whale habitat, how do you fulfill your endangered species responsibilities by only considering the first project (I.e. Vineyard Wind 1)?
(In light of Vineyard Wind’s performance to date, one could also argue that the Right whale is jeopardized by the Vineyard Wind project alone.)
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).
Although the 4 leases receiving bids at the most recent wind sale (10/29/2024, Gulf of Maine) have presumably been issued, BOEM’s lease table does not reflect that. If those leases have not been issued, it’s too late now.
Assuming that the Gulf of Maine leases have in fact already been issued, the legislative restriction on issuing new leases should not be an issue. A qualifying oil and gas lease sale will likely be held in the Gulf of Mexico in the first half of 2025.
The bigger question is whether the new administration will hold any wind lease sales. Pre-election energy policy comments imply that new wind sales are unlikely.
“At the heart of the dispute are rules from the federal Bureau of Ocean Energy Management – BOEM – which require energy producers in the Outer Continental Shelf to provide a bond to pay for well, platform, pipeline and facilities cleanup if the operating company fails to do so.”
“These insurance companies and their unreasonable demands for increased collateral pose an existential threat to independent operators like W&T.”
Comment: If insuring offshore decommissioning is so risk-free and lucrative, why aren’t other companies entering the market?
“Several states, including Texas, are challenging the BOEM rule and in one case they specifically cite W&T as an example of how the rule could be misused to irreparably harm energy producers.“
Comment:As previously posted, the concerned States should propose alternative solutions that would promote production while also protecting taxpayer interests. Arguing that decommissioning financial risks are not a problem is neither accurate nor a solution.
“In over 70 years of producer operations in the Gulf of Mexico, the federal government has never been forced to pay for any abandonment cleanup operations associated with well, platform facility, or pipeline operations.”
Comment: Shamefully, from the standpoints of both the offshore industry and the Federal government, that statement is no longer true. The taxpayer has now funded decommissioning operations in the Matagorda Island Area offshore Texas (BSEE photo below) and more significant decommissioning liabilities loom.
The Town of Nantucket calls on you to help safeguard one of the nation’s most treasured National Historic Landmarks. We ask that you contact the Advisory Council on Historic Preservation (ACHP) and the Massachusetts State Historic Preservation Officer (SHPO) to urge them to decline signing the Section 106 Memorandum of Agreement (MOA) for SouthCoast Wind. Section 106 requires federal agencies to consider the effects on historic properties of projects they carry out, assist, fund, permit, license, or approve throughout the country, and to find ways to avoid, minimize, or mitigate adverse effects on those properties.
BusinessWire: “These turbines destroy our culturally sacred viewshed, destroy our traditional and historic fishing grounds, and threaten the continued existence of the North Atlantic right whale,” said William “Buddy” Vanderhoop, a member of the Wampanoag Tribe of Gay Head.
“We are known as ‘The People of the First Light,’” said Tribal Chairwoman Cheryl Andrews-Maltais. “The unobstructed eastern view of the ocean from our ancestral lands from Nantucket, Cape Cod, Martha’s Vineyard (‘Noepe’) and southeastern Massachusetts is inextricably intertwined with who we are as a people and our cosmology, and is essential to our spiritual beliefs and practices.”
“GE Vernova is aiming to deploy small nuclear reactors across the developed world over the next decade, staking out a leadership position in a budding technology that could play a central role in meeting surging electricity demand and reducing carbon dioxide emissions.“