From CFACT

By David Wojick

When the Feds finally do the cumulative environmental impact analysis for whales as mandated by the Endangered Species Act there are a number of basic issues to be resolved. Here is a quick look at some for the desperately endangered North Atlantic Right Whale (NARW).

Cumulative refers to the combined impact of multiple offshore projects. The first issue is which projects to combine for analysis. NARW are found along the entire Atlantic coastal waters which bounds the geography. Other endangered critters are found along the Gulf and West Coasts.

Projects can be in very different stages of development. Here is a hierarchy of sorts that gives several obvious options, from relatively small to enormous.

1. Projects built or approved for construction. There are about 10 of these. They are the immediate threat, but the overall threat to the NARW is, of course, much greater than this. Given that they have been approved for construction, it might be difficult to make big changes to protect the NARW, although not impossible.

2. The above, plus the projects actively seeking near-term approval. This is more like 30 projects, and the combined threat is very real. Cumulative impact analysis might seriously constrain this long list.

3. Next come the many projects listed in “AN ACTION PLAN FOR OFFSHORE WIND TRANSMISSION DEVELOPMENT IN THE U.S. ATLANTIC REGION“. This Action Plan is from the Energy Department and the Bureau of Ocean Energy Management (BOEM), which is actually building the combined offshore wind monster.

The Action Plan shows specific projects in ever-increasing numbers by five-year increments, from 30,000 MW in 2030 to 85,000 MW in 2050. These projects are somewhat speculative, but since this is a BOEM Plan, its cumulative impact on the NARW should certainly be assessed for each five-year increment. It is likely that such a massive plan would be constrained by the results of this assessment.

For each cumulative impact assessment, the next question is, what potential impacts on the NARW to look at? Here are some obvious examples that I have discussed in prior articles.

A. Acoustic noise harassment from sources such as sonar surveys, site construction, as well as operation. Given that some approved individual projects have construction harassment estimates alone over 200 NARW each, the combined total harassment for all projects and sources could be enormous.

B. Moreover, it is likely that combined noises will create new levels of harassment. The potential for NARW extinction is obvious, given that their entire population is less than 350, with just 70 or so breeding females.

C. Adverse wake effects, such as reduced-energy air plumes and suspended sediment plumes that reduce food supplies. Here, clusters of nearby projects will be especially important. The Action Plan consists of numerous large clusters of projects.

D. Forced changes in navigation routes and fishing grounds which can lead to concentrated threats of deadly ship strikes and entanglement drownings. It is easy to forget that whales cannot breathe underwater.

It should be noted that adverse impacts can combine over time as well as space. The migratory NARW will be forced to run a gauntlet of successive projects stretching at least from Georgia to Maine.

Here is BOEM’s own discussion of the combined impacts over time for pile driving during construction of projects. I could not have said it better.

“It is possible that pile driving could displace animals into areas with lower habitat quality or higher risk of vessel collision or fisheries interaction. Multiple construction activities within the same calendar year could potentially affect migration, foraging, calving, and individual fitness. The magnitude of impacts would depend upon the locations, duration, and timing of concurrent construction. Such impacts could be long term, of high intensity, and of high exposure level. Generally, the more frequently an individual’s normal behaviors are disrupted or the longer the duration of the disruption, the greater the potential for biologically significant consequences to individual fitness. The potential for biologically significant effects is expected to increase with the number of pile-driving events to which an individual is exposed.”

Empire Wind, Draft Environmental Impact Statement v.1, Page 3.15-14, PDF page 372

No doubt there are other important issues to consider in a proper cumulative impact analysis.

Collectively, offshore wind is a massive proposed multi-project program with equally massive combined environmental impacts. These cumulative impacts must be assessed under the Endangered Species Act for the desperately endangered North Atlantic Right Whale and all the other listed critters that would be affected.

Constraint in project impact should be the order of the day.