From CFACT

By David Wojick

NOAA recently took comments on a lengthy draft document that they termed “regional monitoring standards for evaluating the effects of fixed-foundation offshore wind development.” A group of experts on the impact of U.S. offshore wind projects blasted it as not just bad but not even being standards.

The comments are long and technical. Here is their succinct, non-technical summary.

“As written, the draft fails to constitute a regulatory standard and does not fulfill NOAA’s obligations under the MMPA, ESA, NEPA, or BOEM-coordinated offshore wind oversight. We respectfully request that NOAA revise the document to include useful, enforceable, and scientifically robust monitoring standards, and reissue it for comment.”

These strongly critical comments are from Save Long Beach Island (SLBI) which has a long history of technical criticism of NOAA claims regarding the limited impact of offshore wind.

The SLBI comments are here.

The scope of the proposed monitoring standards is very broad, making their quality a very important issue when it comes to the viability of offshore wind. Here is NOAA’s overview:

“The monitoring standards focus on the Mid-Atlantic Bight and Southern New England portions of the Northeast U.S. Continental Shelf ecosystem. They’re meant to guide the planning and implementation of monitoring programs. Monitoring programs will evaluate the effects of fixed-foundation offshore wind development on the marine ecosystem including:

— protected species

— fisheries species

— hydrodynamics and oceanography

— socio-economic conditions

The monitoring standards are based on the best scientific information available to achieve standardization of monitoring methods. Standardizing monitoring across individual wind projects—within and across lease areas—will ensure that data can be compared across all projects and used in ecosystem and socio-economic analyses and models. Information from analyses and models can then be used to inform future marine resource conservation and fishery management decisions.”

See the draft here.

That these standards are to be “based on the best scientific information available to achieve standardization of monitoring methods” is part of SLBI’s criticism. But more deeply, their point is that these are not standards, just suggestions. Here is how they put it:

“The monitoring standard as drafted relegates almost complete discretion to the developer to decide the content of the monitoring plan, even including the questions to be resolved. This is an inappropriate abrogation of NOAA responsibilities under the MMPA, the ESA, and of the BOEM-managed responsibilities under the Outer Continental Shelf Lands Act. The standards should address the issues that NOAA and BOEM need to resolve through monitoring.”

So, the lengthy draft is not actually standards, or even guidance. It really just says “Do what you think is appropriate.”

The real problem is that NOAA does not want to admit to the issues that need to be resolved. They have systematically ignored these central issues, like stress-induced deadly behavior changes or disruption of fisheries.

For example, you can search the entire document, and the word “harassment” does not appear, even though the death rate of the hundreds of thousands of authorized harassments is a central issue. In fact, the word “death” only occurs in the repeated requirement that if monitoring kills a protected animal, it has to be documented. The fact that offshore wind kills is ignored.

If the questions to be asked are left to the project developer, these hard questions will never be asked. As the SLBI comments make clear, the monitoring must be driven by the questions. The present draft does not address the hard questions that offshore wind must face.

This draft monitoring standard must be thoroughly revised to reflect the huge issues with offshore wind.